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Home My WebLink About20193072.tiffai. COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 July 11, 2019 Dear Sir or Madam: RECEIVED JUL 1 5 2019 WELD COUNTY COMMISSIONERS On July 18, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil & Gas, Inc. - Trott 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 &t 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 Polls, Governor Jill Hunsaker Ryan, MPH, Executive Director 1 u bI1c c Q /i€LA..) o-7/ti/(9 CC: PLCTP), pw( ami rCr-l/CIO 07/17/19 2019-3072 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil e Gas, Inc. - Trott Production Facility - Weld County Notice Period Begins: July 18, 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: Trott Production Facility Well Production Facility NESE SEC 7 T4N R68W Weld County The proposed project or activity is as follows: The operator is requesting permit coverage for a new synthetic minor facility The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0039 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.wv/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd®state.co.us • Send comments to our mailing address: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health ft Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Christopher Kester Package #: 391683 Received Date: 1/3/2019 Review Start Date: 4/4/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas Inc. County AIRS ID: 123 Quadrant Section Township Range NESE 7 4N -. . . Plant AIRS ID: Facility Name: Physical Address/Location: County: A01C Trott Production Facility NESE quadrant of Section 7, Township 4N, Range 68WW Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? n Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank TKs 001-008 Y� 13WE0039 Yes Permit Initial Issuance 002 Produced Water Tank PW 001-002 Yes 19WE0040 1 Y., Permit Initial Issuance (13 Separator Venting LP Yes 19WE0041 1 Yes Permit Initial Issuance LP separator C'"4 Separator Venting VRT 19WE0042 1 Yes Permit Initial Issuance [CE Liquid Loading LOAD ''r° 19WE0043 Yes Permit Initial Issuance Section 03 - Description of Project New synthetic minor E&P facility in the NAA Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? 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) S92 frjissf No Yes NOx CO VOC PM2.5 PM10 TSP -iAPs Colorado Air Permitting Project Is this stationary source a major source? If yes, explain what programs and which pollutants herE SO2 No Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs I • Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 County A01C Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Eight (8) 400 bbl fixed roof condensate storage tanks Description: Emission Control Device Enclosed Combustion Device Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 1,062,572 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 1,062,572 Barrels (bbl) per year Requested Permit Limit Throughput = 1,275,087 Barrels (bbl) per year Requested Monthly Throughput = 108295 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput Secondary Emissions- Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 1,275,087 Barrels (bbl) per year 2394 Btu/scf scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? 4,600 MMBTU per year 5,520 MMBTU per year 5,520 MMBTU per year Emission Factors Condensate Tank Pollutant Uncontrolled Controlled Emission Factor Source (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 0.154500 0.007725 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 0.000307 0.000015 Toluene 0.000237 0.000012 Ethylbenzene 0.000031 0.000002 Xylene 0.000075 0.000004 n -Hexane 0.002100 0.000105 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) 224 TMP 0.000017 0.000001 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 0.0000 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM1O/PM.2.5) PM2.5 0.0075 0.0000 AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) NOx 0.0680 0.0000 CO 0.3100 0.0000 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 PM10 PM2.5 NOx CO 98.5 82.1 4.1 98.50 4.93 837 0.0 0.0 0.0 0.02 0.02 3 0.0 0.0 0.0 0.02 0.02 3 0.2 0.2 0.2 0.19 0.19 32 0.9 0.7 0.7 0.86 0.86 145 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 391 326 16 391 20 302 252 13 302 15 40 33 2 40 2 Xylene 96 80 4 96 5 n -Hexane 2678 2231 112 2678 134 224TMP 21 18 21 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 MACT HH (See regulatory applicability worksheet for detailed analysis) 3 of 20 K:\PA\2019\19W E0039.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should 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. e 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 Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # 01 SCC Code Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.01 3.7 0.03 0.01 0.01 0.00 0.00 0.05 0.00 Control % 0 0 0 95 0 95 95 95 95 95 95 Units Ib/1,000 gallons Ib/1,000 gallons lb/1,000 gallons lb/1,000 gallons Ib/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons Ib/1,000 gallons condensate condensate condensate condensate condensate condensate condensate condensate condensate condensate condensate throughput throughput throughput throughput throughput throughput throughput throughput throughput throughput throughput 4 of 20 K:\PA\2019\19WE0039.CP1 Condensate Tank Regulatory Analysis Worksheet I Re ulation 3 Pa 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 Il.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 OS -01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, 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 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 Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of leakage Section XI1.C2 — 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? Yes Yes Yes Yes Yes No Storage Tank is not subject to Regulation 7, Section XII.G Section XII.G2 - Emissions Control Requirements Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C2 — 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, 8, C.1 8 C.3 No Yes Yes Section XVII.8 — 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 condensate storage tank contain only "stabilized" liquids? Yes No Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60. Subvert 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 m' (-10,000 88L) used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.11lb? 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 60.111b? S. 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 (^950 881] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' ['472 881] but less than 151 m3 ("950 8814 and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? r No Source Rec Go to next Source Rec Continue - Continue - Source is st Continue - - Storage Tar Continue -' Go to the n Go to then Source is st Source is st Storage Tar Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60113b - Testing and Procedures §60115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR. Part 60. Subvert 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 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 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(ex2) 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))? 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"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? 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 Yes No Yes 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 binckng 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 Continue -' Storage Tar Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 County AO1C Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Two (2) 400 bbl fixed roof produced water storage tanks Emission Control Device Endosed combustion device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 600,552.0 Barrels (bbl) per year 95 ♦ Iiuested Permit Limit Throughput = 720,663.0 Barrels (bbl) per yeas Requested Monthly Throughput = 61207 MMscf per month Potential to Emit (PTE) Throughput = 720,663 Barrels (bbl) 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 Flash Liberation Analysis 1569 0.5 MW 31.43 Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Weight % Helium 0.00 C02 6.41 N2 8.72 methane 18.81 ethane 18.97 propane 26.43 isobutane 3.03 n -butane 10.21 isopentane 1.78 n -pentane 2.00 cyclopentane 0.24 n -Hexane 0.39 cyclohexane 0.51 Other hexanes 0.24 heptanes 1.08 methylcyclohexane 0.30 224 -TM P 0.17 Benzene 0.22 Toluene 0.12 Ethylbenzene 0.01 Xylenes 0.03 C8+ Heavies 0.32 Total 99.99 VOC Wt % 47.08 Btu/scf scf/bbl Emission Factors Separator Venting Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Liquid Throughput) (Liquid Throughput) VOC 0.01952 0.00098 Flash Liberation Site Specific Emission Factors Benzene 0.0001 0.0001 Flash Liberation Site Specific Emission Factors Toluene 0.0000 0.0000 Flash Liberation Site Specific Emission Factors Ethylbenzene 0.0000 0.0000 Flash Liberation Site Specific Emission Factors Xylene 0.0000 0.0000 Flash Liberation Site Specific Emission Factors n -Hexane 0.0002 0.0002 Flash Liberation Site Specific Emission Factors 224 TMP 0.0001 0.0001 Flash Liberation Site Specific Emission Factors Primary Control Device Uncontrolled Uncontrolled Emission Factor Source Pollutant (lb/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 0.0000 AP-42Tsbie;14-at MIO/PM.2S) PM2.5 0.0075 0.0000 AP-42141)1e14-2(PM10/PM.2.5). NOx 0.0680 0.0001 AP -42 Chapter 13.5 Industrial Flares (NOn) CO 0.3100 _ 0.0002 AP -42 Chapter 13s lndustrIal Flares (CO) . - Section 05 - Emissions Inventory Criteria Pollutants I Potential to Emit Uncontrolled I Actual Emissions Uncontrolled Controlled Requested Permit Limits Uncontrolled Controlled Requested Monthly Limits Controlled 6 of 20 K:\PA\2019\19WE0039.CP1 Produced Water Storage Tank(s) Emissions Inventory (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM 10 0.00 0.00 0.00 0.00 0.00 0 PM 2.5 0.00 0.00 0.00 0.00 0.00 0 NOx 0.02 0.02 0.02 0.02 0.02 3 VOC 7.03 5.86 0.29 7.03 0.35 60 CO 0.09 0.07 0.07 0.09 0.09 15 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 66 55 55 66 66 Toluene 36 30 30 36 36 Ethylbenzene 3 2 2 3 3 Xylene 9 7 7 9 9 n -Hexane 117 97 97 117 117 224 TMP 51 42 42 51 51 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is 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) 7 0& 20 K:\PA\2019\19WE0039.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. 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 :.y.. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # 5CC 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 Uncontrolled Emissions Factor #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REFI #REFI #REF! #REF! Control % 0 0 0 #REF! 0 #REF! #REF! #REF! #REF! #REF! #REF! Units lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons Ib/1,000 gallons Ib/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput 8 of 20 K:\PA\2019\19WE0039.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 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 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 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 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)? Yes 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 facility2, natural gas compressor station' 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? No 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 t, Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Record keeping 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 emissions2 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"1 per 60.5430? Yes No Storage Tank is not subject to NSPS OOOO Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC 560.5413 - 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 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 Go to next Source Req Continue -' Continue -' Go to the n Source is st Source is st Continue -' Storage Tar Separator Venting Emissions Inventory 003 Separator Venting Facility AIRs ID: 123 County A01C Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Low pressure separator venting emissions enclosed combustion device Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 21.13 MMscf per year 95 Requested Permit Limit Throughput = 25.36 MMscf per year Requested Monthly Throughput = 2 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 25.36 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description Sample analysis of LP gas 2060 Btu/scf MW 36.38 Weight % Helium 0.00 CO2 1.76 N2 0.94 methane 14.48 ethane 15.96 propane 29.94 isobutane 4.72 n -butane 15.65 isopentane 3.92 n -pentane 5.18 cyclopentane 0.49 n -Hexane 1.49 cyclohexane 0.36 Other hexanes 2.60 heptanes 0.86 methylcyclohexane 0.30 224-TMP 0.00 Benzene 0.19 Toluene 0.12 Ethylbenzene 0.01 Xylenes 0.04 C8+ Heavies 0.75 Total 99.76 VOC Wt % 66.63 scf/bbl Ib/Ib-m of Displacement Equation Ex = Q * MW * Xx / C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) Emission Factor Source (Gas Throughput) (Gas Throughput) VOC 63956.04 3197.80 Extended gas analysis Benzene 185.16 9.26 Extended gas analysis Toluene 114.61 5.73 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Ethylbenzene 12.00 0.60 Xylene 36.48 1.82 n -Hexane 1426.31 71.32 224 IMP 0.48 - 7 2 Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 15.349 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 (5Ox) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 15.349 SOx 0.0006 1.212 NOx 0.0680 140.080 CO 0.3100 638.600 10 of 20 K:\PA\2019\19W E0039.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 0.19 0.16 0.16 0.19 0.19 33 PM2.5 0.19 0.16 0.16 0.19 0.19 33 SOx 0.02 0.01 0.01 0.02 0.02 3 NOx 1.78 1.48 1.48 1.78 1.78 302 VOC 810.96 675.70 33.78 810.96 40.55 6888 CO 8.10 6.75 6.75 8.10 8.10 1375 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 4696 3913 196 4696 235 Toluene 2907 2422 121 2907 145 Ethylbenzene 304 254 13 304 15 Xylene 925 771 39 925 46 n -Hexane 36171 30138 1507 36171 1809 224 TMP 12 10 1 12 1 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. rITUtit -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. i 11 of 20 K:\PA\2019\19WE0039.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 15.35 0 lb/MMSCF PM2.5 15.35 0 Ib/MMSCF SOx 1.21 0 lb/MMSCF NOx 140.08 0 lb/MMSCF VOC 63956.04 95 lb/MMSCF CO 633.60 0 Ib/MMSCF Benzene 185.16 95 Ib/MMSCF Toluene 114.61 95 lb/MMSCF Ethylbenzene 12.00 95 Ib/MMSCF Xylene 36.48 95 Ib/MMSCF n -Hexane 1426.31 95 Ib/MMSCF 224 TMP 0.48 95 lb/MMSCF 12 of 20 K:\PA\2019\19WE0039.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, Par, 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.0.3)? 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 thar 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 si The contro Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123 County A01C Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Vapor Recovery Tower Enclosed Combustion Device Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 4.76 MMscf per year 95 Requested Permit Limit Throughput = 5.72 MMscf per year Requested Monthly Throughput = 0.486 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 5.72 MMscf per year Yes Yes Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies 2691 Description Sample analysis of VRT Gas MW 46.921 Weight % Helium 0.0000 CO2 0.5980 N2 0.3037 methane 2.1276 ethane 9.9590 propane 37.9375 isobutane 7.6636 n -butane 25.2777 isopentane 5.5378 n -pentane 6.3166 cyclopentane 0.4205 n -Hexane 0.9824 cyclohexane 0.1735 Other hexanes 1.9226 heptanes 0.3313 methylcyclohexane 0.0940 224-TMP 0.0003 Benzene 0.0937 Toluene 0.0256 Ethylbenzene 0.0009 Xylenes 0.0021 C8+ Heavies 0.1382 Total 99.9061 VOC Wt % 86.9183 Btu/scf scf/bbl Ib/lb• m of Displacement Equation Ex = Q * MW * Xx / C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) Emission Factor Source (Gas Throughput) (Gas Throughput) VOC 107607 5380.33 Extended gas analysis Benzene 116 5.80 Extended gas analysis Toluene 32 1.58 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Ethylbenzene 1 0.06 Xylene 3 0.13 n -Hexane 1216 60.81 224 TMP 0 0.02 Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 20.051 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 20.051 SOx 0.0006 1.583 NOx 0.0680 182.988 CO 0.3100 834.210 14 of 20 K:\PA\2019\19WE0039.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 0.06 0.05 0.05 0.06 I 0.06 10 0.06 0.05 0.05 0.06 0.06 10 0.00 0.00 0.00 0.00 0.00 1 0.52 0.44 0.44 0.52 0.52 89 307.76 256.10 12.81 307.76 15.39 2614 CO 2.39 1.99 1.99 2.39 2.39 405 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 664 552 28 664 33 Toluene 181 151 8 181 9 Ethylbenzene 6 5 0 6 0 Xylene 15 12 1 15 1 n -Hexane 6957 5789 289 6957 348 224 TM P 2 2 0 2 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 You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 15 of 20 K:\PA\2019\19WE0039.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes 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 20.05 0 Ib/MMSCF PM2.5 20.05 0 Ib/MMSCF SOx 1.58 0 Ib/MMSCF NOx 182.99 0 Ib/MMSCF VOC 1076C6.69 95 lb/MMSCF CO 834.21 0 lb/MMSCF Benzene 116.00 95 Ib/MMSCF Toluene 31.59 95 lb/MMSCF Ethylbenzene 1.11 95 lb/MMSCF Xylene 2.60 95 lb/MMSCF n -Hexane 1216.23 95 Ib/MNISCF 224 TMP 0.37 95 Ib/MMSCF 16 of 20 K:\PA\2019\19WE0039.CP1 Separator Venting Regulatory Analysis Worksheet 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. 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 11.0.2)? Source requires a permit Yes Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes 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 i.idividual 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," "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 ro Source Req Source Req Source is st The contro Hydrocarbon Loadout Emissions Inventory 005 Liquid Loading Facility AIRs ID: 123 County AO1C Plant 005 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Condensate loading into tanker trucks Enclosed Combustion Device Yes 100.0 95 Requested Overall VOC & HAP Control Efficiency %: 95.00 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 106,257 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 106,257 Barrels (bbl) per year Requested Permit Limit Throughput = 127,509 Barrels (bbl) per year Requested Monthly Throughput = 10830 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 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 = 127,509 Barrels (bbl) per year 2394 Btu/scf 151739 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46*S*P*M/T 303 MMBTU per year 363 MMBTU per year 363 MMBTU per year NO - A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor. Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 Chapter 5.2 Table 5.2-1 Submerged Loading: Dedicated Norma! Service (S=0.6) P True Vapor Pressure 5.2 psia M Molecular Weight of Vapors 66 Ib/Ib-mol T Liquid Temperature 520 Rankine L Loading Losses 4.93416 lb/1000 gallons 0.20723472 lb/bbl Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 0.2071 0.0104 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific- AP -42: Chapter 5.2, Equation 2 Site Specific - AP -42: Chapter 5.2, Equation 3 Site Specific- AP -42: Chapter 5.2, Equation 4 Site Specific - AP -42: Chapter 5.2, Equation 5 Site Specific - AP -42: Chapter 5.2, Equation 6 Site Specific - AP -42: Chapter 5.2, Equation 7 Benzene 0.0004 0.0000 Toluene 0.0003 0.0000 Ethylbenzene 0.0000 0.0000 Xylene 0.0001 0.0000 n -Hexane 0.0030 0.0002 224 IMP 0.0000 0.0000 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 2.12E-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 2.12E-05 SOx _ 0.0006 1.68E-06 NOx 0.0680 1.94E-04 CO 0.3100 8.83E-04 18 of 20 K:\PA\2019\19 W E0039.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 0.00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 S0x N0x V0C 0.00 0.00 0.00 0.00 0.00 0 0.01 0.01 0.01 0.01 0.01 2 13.21 11.01 0.55 13.21 0.66 112 CO 0.06 0.05 0.05 0.06 0.06 10 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 53 44 2 53 3 41 34 2 41 2 5 4 0 5 0 13 11 1 13 1 383 319 16 383 19 224 TMP 3 2 0 _ 3 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must be operated with submerged fill to satisfy RAG. (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 Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process # 01 SCC Code 4-06-00142 Crude Oil: Submerged Loading Normal Service (S=0.6) Pollutant PM10 PM2.5 S0x N0x VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.00 0.00 4.9 0.02 0.01 0.01 0.00 0.00 0.07 0.00 Control % 0 0 0 0 95 0 95 95 95 95 95 95 Units lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons Ib/1,000 gallons lb/1,000 gallons transferred transferred transferred transferred transferred transferred transferred transferred transferred transferred transferred transferred 19 of 20 K:\PA\2019\19WE0039.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.I)? 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 11.0.2)? Yes Yes No No No Yes Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.ai? 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 Ad, 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 "car," 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 'COLORADO Air Pollution Control Division Department of P1.41.1C. Health £ Fnv-ironn,er.- Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0039 Issuance: 1 Extraction Oil a Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Trott Production Facility 123/A01 C NESE SEC 7 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TKs 001-008 001 Eight (8) 400 bbl fixed roof condensate storage tanks Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit 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 8 COLORADO Air Pollution Control Division Deoarinert. of P«sic Health & Fnvironmen: 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.) 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: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TKs 001-008 001 --- --- 5.0 --- 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 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 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 8 ;COLORADO Air Pollution Control Division eoart cent of PteO3rc }-;e,-a_th t Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled TKs 001-008 001 Enclosed Combustion Device 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 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit TKs 001-008 001 Condensate throughput 1,275,087 barrels The owner or operator shall monitor 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. 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) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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 • 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) Page 3 of 8 CDPHE i :COLORADO Air Pollution Control Division Department of Put.)Health & Environ*neni Dedicated to protecting and improving the health and environment of the people of Colorado 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 shalt 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. 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 £t 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 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. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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.) Page 4 of 8 COLORADO Air Pollution Control Division Deoarhrent or P1}bvc !-Iecai h t F:mirotmtent Dedicated to protecting and improving the health and environment of the people of Colorado • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 19. 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. 20. 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. 21. 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 Page 5 of 8 CDPHE s !COLORADO Air Pollution Control Division DaparLhent. Ci Pubi:c Health t [nvironnien Dedicated to protecting and improving the health and environment of the people of Colorado 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. 22. 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. 23. 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 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. 24. 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. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 6 of 8 CDPHE i 'COLORADO Air Pollution Control Division I Department of Pub'sc Health b Fnvironrnent 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 391 20 Toluene 108883 302 15 n -Hexane 110543 2,678 134 Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.154500 0.007725 Pressurized Liquid sample, HYSYS, TANKS 4.0.9d 71432 Benzene 0.000307 0.000015 108883 Toluene 0.000237 0.000012 100414 Ethylbenzene 0.000031 0.000002 1330207 Xylene 0.000075 0.000004 110543 n -Hexane 0.002100 0.000105 540841 2'2'4-0.000017 Trimethylpentane 0.000001 Page 7 of 8 !COLORADO Air Pollution Control Division Department of Pubic. Hei=.h ty Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 and HAP NANSR Synthetic Minor Source of: VOC 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 6O: 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 MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 COLORADO Air Pollution Control Division I Department of Pubttr 1dertt h b F.nvironmen: Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0040 Issuance: 1 Extraction Oil Et Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Trott Production Facility 123/A01 C NESE SEC 7 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description PW 001-002 002 Two (2) 400 bbl fixed roof produced water storage tanks Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit 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 8 COPHE 4 `COLORADO Air Pollution Control Division Deoarnneot of Pub:c 11eaith & rnororunero 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: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO PW 001-002 002 --- --- 0.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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 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 8 CDPHE COLORADO Air Pollution Control Division IDe>nirhnent cf Pubitc Hea4;h & EnvI on-mment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled PW 001-002 002 Enclosed combustion device 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 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit PW 001-002 002 Produced Water throughput 720,663 barrels The owner or operator shall monitor 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. 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) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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; Page 3 of 8 CDPHE s COLORADO Air Pollution Control Division Department rf Pub c Health t Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 12. 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. 13. 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 14. 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 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 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. 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 Page 4 of 8 CDPHE C COLORADO Air Pollution Control Division Department of Pubt:c Health G Frei oninent Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 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 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 shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be Page 5 of 8 CDPHE i ;COLORADO Air Pollution Control Division Department- cart*nen of Public .-iea th. E., Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 in writing 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 6 of 8 COLORADO Air Pollution Control Division Department of Pubic 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 emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.01952 0.00098 Source Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 5) 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. 6) 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. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC and HAP NANSR Synthetic Minor Source of: VOC Page 7 of 8 COPHE s COLORADO Air Pollution Control Division Department. of Pub c Fleolth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 CDPHE COLORADO Air Pollution Control Division Department of Pl.Jilc Heoith & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0041 Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil &t Gas, Inc. Trott Production Facility 123/A01 C NESE SEC 7 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP 003 Twenty (20) High -Low Pressure Separators Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (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 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 9 ;COLORADO Air Pollution Control Division Department of Pubik: Heeith & 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.) 4. Upon issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas routed to the enclosed combustion device from each separator covered by this permit. 5. 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.) 6. 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 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO LP 003 --- 1.8 40.6 8.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. Page 2 of 9 ;COLORADO Air Pollution Control Division • f.',enartmert Fubtac Health & h'nMronmenr, Dedicated to protecting and improving the health and environment of the people of Colorado 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LP 003 Emissions from the Separator are routed to an Enclosed Combustion Device during Vapor Recovery Unit (VRU) downtime 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit LP 003 Natural Gas Venting 25.36 MMSCF 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. 10. Upon issuance of this permit, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas route to the enclosed combustion device from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall 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 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 9 COLORADO Air Pollution Control Division Department of Pu69rc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator 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. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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 (NOx) 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 Page 4 of 9 CDPHE q COLORADO Air Pollution Control Division ( 'Department cf Ptibizc Ntai h & Ezwironanent Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall 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 shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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. Page 5 of 9 COLORADO Air Pollution Control Division Department' of Pub[lc E-ieak1E) Cnvironnient Dedicated to protecting and improving the health and environment of the people of Colorado 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 regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil 8 Gas, Inc. Page 6 of 9 ;COLORADO Air Pollution Control Division De>;artment of Pubitc Hea6th b Fr vironment 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-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP 003 Benzene 71432 4,688 234 Toluene 108883 2,900 145 Ethylbenzene 100414 305 15 Xylenes 1330207 922 46 n -Hexane 110543 36,102 1,805 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 7 of 9 ;COLORADO Air Pollution Control Division Department- of Pub tc 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/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP 42 CO 0.31 lb/MMBtu 0.31 lb/MMBtu VOC 63,837 3,191.9 Gas Sample Analysis 71432 Benzene 185 9.3 108883 Toluene 114 5.7 100414 Ethylbenzene 12 0.6 1330207 Xylene 36 1.8 110543 n -Hexane 1,424 71.2 Note: The controlled emissions factors for this point are based on the flare 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC and HAP 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://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 Page 8 of 9 !COLORADO Air Pollution Control Division Department. of Pub;fc Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 COLORADO Air Pollution Control Division L,spaim nr v F i,iJ'ic HE,atth £, Eru-r^.nrrie.n Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0042 Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil Et Gas, Inc. Trott Production Facility 123/A01 C NESE SEC 7 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT 004 Two (2) Vapor Recover Towers (VRT) Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit 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 9 COLORADO Air Pollution Control Division Dpnaltnc of i-�.:iy':c He,alit) t: i-.n/rnnm.,,ic 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.) F.4. ) 4. Upon issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas routed to the enclosed combustion device from each VRT covered by this permit. 5. 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.) 6. 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 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO VRT 004 --- --- 15.4 2.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. Page 2 of 9 COLORADO Air Pollution Control Division Denann-rtn[ Haa1th f, bw 7)nrro t Dedicated to protecting and improving the health and environment of the people of Colorado 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT 004 Emissions from the VRTs are routed to an Enclosed Combustion Device during Vapor Recovery Unit (VRU) downtime 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT 004 Natural Gas Venting 5.72 MMSCF 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. 10. Upon issuance of this permit, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas route to the enclosed combustion device from the VRTs using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall 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 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 9 COLORADO Air Pollution Control Division Don ri -. of i'r 3t'ic Health Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator 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&tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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 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 Page 4 of 9 COLORADO Air Pollution Control Division �;artrn-nt of Fr iblc }{ea1tb Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall 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 shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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. Page 5 of 9 COLORADO Air Pollution Control Division of of rut,"c HOatth f, Frtinm,,n. Dedicated to protecting and improving the health and environment of the people of Colorado 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 regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a. Gas, Inc. Page 6 of 9 COLORADO Air Pollution Control Division Den r tinni of Fra.)' C Honfh a fr, -,anrxr-_nt 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. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) VRT 004 Benzene 71432 663 33 n -Hexane 110543 6,944 347 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 7 of 9 COLORADO Air Pollution Control Division Eii,nalmTnr of rcb c Honittl 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/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP 42 CO 0.31 lb/MMBtu 0.31 lb/MMBtu VOC 107,470 5373.5 Gas Sample Analysis 71432 Benzene 116 5.8 110543 n -Hexane 1,215 60.8 Note: The controlled emissions factors for this point are based on the flare 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC and HAP 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://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 Page 8 of 9 COLORADO Air Pollution Control Division Denaiinenc of Pi.Ch.c Hcaith z: Env�r::;nrr,,,nt Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 ;COLORADO Air Pollution Control Division Department of Pub=.ic Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 1 9WE0043 Issuance: 1 Extraction Oil &t Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Trott Production Facility 123/A01 C NESE SEC 7 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LOAD 005 Truck loadout of condensate by submerged fill Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit 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 8 COLORADO Air Pollution Control Division i Department of Pubhc Ffeahh & 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.) 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: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOx VOC CO LOAD 005 --- --- 0.7 --- 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. 6. 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 th's permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LOAD 005 Enclosed Combustion Device VOC and HAP Page 2 of 8 CDPHE i :.COLORADO I Air Pollution Control Division sa�artrnent of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 7. 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD 005 Condensate Loaded 127,509 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 8. 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.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. 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 combustor. (Reference: Regulation 3, Part B, III.D.2) 11. 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. 12. 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): 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. Page 3 of 8 ;COLORADO i Air Pollution Control Division Department of Pubic Health 5 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 13. For this controlled loading operation, 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): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 14. 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 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 8 ;COLORADO 1 Air Pollution Control Division Department of Public Health & En•vironn2ert Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 17. 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 NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 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 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 Page 5 of 8 CDPHE i ;COLORADO Air Pollution Control Division Deb artmcnt of Pubitc Health o 6wironrnent Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 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 in writing 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 6 of 8 COLORADO Air Pollution Control Division Department of Puaac Health b Fnvirormzent 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) 005 n -Hexane 110543 361 18 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl VOC 0.2072 0.0104 n -Hexane 110543 0.0030 0.00015 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.2 psia M (vapor molecular weight) = 66 lb/lb-mol Page 7 of 8 CDPHE q ;COLORADO Air Pollution Control Division De, arhnent of Pub;Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado T (temperature of liquid loaded) = 520 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of 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 and HAP 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: //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 MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 /ACC / 0O I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Extraction Oil & Gas, Inc. Site Name: Trott Production Facility Site Location: NESE Section 7 T4N R68W Mailing (Include Address: p Code370 17th Street, Zip Code) Suite 5300 Denver, Colorado 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. 391675 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 :COLORADO 1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name3 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 - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Eight (8) - 400 bbl Condensate Storage Vessels Company equipment Identification No. (optional): TKs 001-008 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 10/05/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 0 Exploration & Production (EEtP) site days/week 52 weeks/year O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? O Yes • No Are Flash Emissions anticipated from these storage tanks? O Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? O Yes • No If "yes", identify the stock tank gas -to -oil ratio: 0.000108 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No 0 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 AviveotoRADo 2 I e 111 r::_. sc:�:_:.•.�Y Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl /year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 1,062,572 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 42.22 degrees ❑ Internal floating roof Tank design: 0 Fixed roof 1,275,087 RVP of sales oil: 10.01 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK 001-008 8 3200 09/2018 09/2018 Wells Serviced by this Storage Tank or Tank Battery6 (MP Sites Only) API Number Name of Well Newly Reported Well SEE ATTACHED FORM APCD - 212 ■ - ■ ■ ■ - ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EELP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.324431, -105.040427 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECDs —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle El Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): TBD Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 AVIV:COLORADO 3 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECDs MMBtu/hr Make/Model: TBD B Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2,394 TBD Btu/scf scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig Describe the separation process between the well and the storage tanks: HLP Separator, VRT, Condensate Storage Tanks Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 ler COLORADO 4ittiV Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions8 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 0.155 lb/bbl Promax/Tanks409d 82.09 4.10 98.51 4.93 , N0x 0.068 Ib/MMBtu AP -42 0.05 0.06 CO 0.31 lb/MMBtu AP -42 0.24 0.29 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor7 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions8 (Pounds/year) Benzene 71432 0.0003 lb/bbl Promax/Tanks409d 326 — 16 -- Toluene 108883 0.0002 lb/bbl Promax/Tanks409d 251 - 13 - Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.002 lb/bbl Promax/Tanks409d 2,239 ` 112 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 COLORADO 5 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. „- 1M ' Lure of Legally Authorized Person (not a vendor or consultant) Catie Nelson t / 24 ) Doke Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: El 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-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.coiorado.govicduhe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6I 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. 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: 16, LAI 64651/-0 AIRS ID Number: )7-3 /1401C/602. - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Trott Production Facility Site Location: NESE Section 7 T4N R68W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: Catie Nelson (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 wilt be issued by the APCD via e-mail to the address provided. 391676 C0i®R AB® Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 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 O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-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: Company equipment Identification No. (optional): For existing sources, operation began on: Two (2) - 400 bbl Produced Water Storage Vessels PW 001-002 For new or reconstructed sources, the projected start-up date is: 10/05/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 0 Exploration Et Production (EEtP) site weeks/year ❑ Midstream or Downstream (non EaP) 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 ✓ mitreoLoRADo Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Produced Water Throughput: 600,552 720,663 From what year is the actual annual amount? Tank design: ['Fixed roof 2018 ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Pw 001-002 2 800 09/2018 09/2018 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only) API Number Name of Well Newly Reported Well SEE ATTACHED FORM APCD-212 ❑ - ❑ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.324431, -105.040427 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECDs —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Horizontal ❑ Downward ❑Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/rectangle ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Interior stack width (inches): Interior stack depth (inches): ,COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑✓ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECDs MMBtu/hr Make/Model: TBD B Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Waste Gas Heat Content: Minimum Temperature: TBD Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 1,569 TBD Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -42 psig Describe the separation process between the well and the storage tanks: HLP Separator, Produced Vk/ater Storage Tanks Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4 I �°7..F=' "'===, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP -42, .Mfg., etc.) Emissions (tons/year) Emissions8 (tons/year) Emissions (tons/year) Emissions (tonslyear) VOC 0.019 ' lb/bbl Analysis 5.85 0.29 7.03 ' 0.35 NOx 0.068 ' lb/MMBtu AP -42 0.01 0.02 CO 0.31 ' Ib/MMBtu AP -42 0.07 0.08 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor7 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, etc.) ) Uncontrolled Emissions (pounds/year) (pounds/ ear ) Controlled Emissions8 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 5 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit it 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. 0 ON ciri Signature f of Legally Authorized Perso (not a vendor or consultant) i Da e ' Catie Nelson Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: ID 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: httos://www.colorado.Rov/cdohe/apsd Form APCD-211 Gas Venting APEN - Revision 712018 6 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Formt Company Name: Extraction Oil & Gas, Inc. Source Name: Trott Production Facility Emissions Source AIRS ID2: TBD Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-45898 Berthoud Farms # 8E -10-1N ■ 05-123-45899 Berthoud Farms # 8E -10-3C ■ 05-123-45720 Berthoud Farms # 8E -10-5N ■ 05-123-45719 Berthoud Farms # 8E -10-7N ■ 05-123-45732 Berthoud Farms # 8E -10-9N ■ 05-123-45724 Berthoud Farms # 8E -10-11C ■ 05-123-45721 Trott # 7W -10-2C ■ 05-123-45725 Trott # 7W -10-4N ■ 05-123-45733 Trott # 7W -10-8N ■ 05-123-45710 Trott # 7W -10-10C ■ 05-123-45702 Trott # 7W -10-12N ■ 05-123-45705 Trott # 7W -20-16N ■ 05-123-45716 Trott # 8E -10-1N ■ 05-123-45709 Trott # 8E -10-3N ■ 05-123-45714 Trott # 8E -10-5N ■ 05-123-45731 Trott # 8E -10-7C ■ 05-123-45723 Trott # 8E -10-9N ■ 05-123-45712 Trott # 8E -10-11N ■ 05-123-45728 Trott # 8E -10-17N ■ 05-123-45718 Trott # 17E -20-19N ■ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter NA Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 JA's m 3 , 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: /9 (,tfE I. f / AIRS ID Number: 12? /A0 (c- / 6,03 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Extraction Oil & Gas, Inc. Trott Production Facility NESE Section 7 T4N R68W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: 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. 391677 COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Emissions Low Pressure ("LP") Separator Venting Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 10/05/2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD days/week TBD weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? ❑✓ Yes ❑ No ❑ Yes ❑✓ No ❑✓ Yes ❑ No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I AV ,COLORADO 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 #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameterss: Vented Gas Properties: ❑ No Vent Gas 2 06O BTU/SCF Heating Value: , Requested: 25.36 MMSCF/year Actual: 21.13 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 36.36 VOC (Weight %) 66.59 Benzene (Weight %) 0.19 Toluene (Weight %) 0.12 Ethylbenzene (Weight on 0.01 Xylene (Weight %) 0.04 n -Hexane (Weight %) 1.49 2,2,4-Trimethylpentane (Weight %) 0 00 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX a 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 Vir COLORA@O 3 I AV ._ Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.324431, -105.040427 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: TBD MMBtu/hr Make/Model: TBD 95 >99 % % Waste Gas Heat Content: 2,060 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/ hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 4 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC Enclosed Combustion Device 95 HAPs Enclosed Combustion Device 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NO. 0.068 Ib/MMBtu AP -42 4,34-1.c 4-G4-4 `.�' CO 0.31 Ib/MMBtu AP -42 6.12- 6,'6 7-34-i $,I VOC 63.837 lb/Mscf Eng. Est. 674.50 33.73 809.40 - 40.47 — Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service (CAS) Number Basis Units (AP -42, Mfg., etc.) Emissions (pounds/year) Emissions6 (pounds/year) Benzene 71432 0.185 lb/Mscf Eng. Est. 3,906 ' 195 Toluene 108883 0.114 lb/Mscf Eng. Est. 2,416 ";" 121 - Ethylbenzene 100414 0.012 lb/Mscf Eng. Est. 254 — 13 - Xylene 1330207 0.036 lb/Mscf Eng. Est. 769 - 38 n -Hexane 110543 1.424 lb/Mscf Eng. Est. 30,085 -- 1,504 — 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 .Coi'9RADO 5j Ikaff 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. 7I'1'1 Signiure of Legally Authorized Flerson (not a vendor or consultant) Catie Nelson (27(76 Date Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 43OO 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/cdphepcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 61 remoramera. roe. COLON A0O 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: q W 0042. AIRS ID Number: rz3 lA J G / t bl)• [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Trott Production Facility Site Location: NESE Section 7 T4N R68W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: 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. Form APCD-211 - Gas Venting APEN - Revision 7/2018 391678 lisr. COLORADO 1 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) OR O 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: 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: Vapor Recovery Tower ("VRT") Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 10/05/2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD days/week TBD weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 ❑✓ Yes ❑ Yes ❑✓ Yes ❑ No ❑✓ No ❑ No COLORADO 2 �„ Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ Yes ❑ No Vent Gas Heating Value: 2,691 BTU/SCF Requested: 5.72 MMSCF/year Actual: 4.76 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 46.92 VOC (Weight %) 86.90 Benzene (Weight %) 0.09 Toluene (Weight %) 0.03 Ethylbenzene (Weight 0.00 Xylene (Weight %) 0.00 n -Hexane (Weight %) O.98 2,2,4-Trimethylpentane (Weight %) . 000 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and pressure) E 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 loggveoLoRAD0 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UT/A) 40.324431, -105.040427 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (F) Flow Rate (ACFM) Velocity (ft/sec) ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) p Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD ECD MMBtu/hr Make/Model: TBD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 2,691 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 i9L�at Ali 6� 4 I Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the ined control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC Enclosed Combustion Device 95 HAPs Enclosed Combustion Device 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limits) Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NO. 0.068 Ib/MMBtu AP -42 9.39-0,y 014F UT CO 0.31 Ib/MMBtu AP -42 1_7-9-i LC) 2.15- 2•`1 VOC 107.47 Ib/Mscf Eng. Est. 256.0 12.80 307.20 15.36 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions e (pounds/year) Benzene 71432 0.116 Ib/Mscf Eng. Est. 552 28 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 1.215 lb/Mscf Eng. Est. 5,787 289 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. C, Vscalcsr -11\1-\ I `� Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 5 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. � . /L/ 11 7/I ?Ur\ 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: O Draft permit prior to issuance ▪ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: httos://v/ w.colorado.gov/cdphe/aGxd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 6I AYcosoaAoo I. "-f" 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: ! 4�� O�.3 AIRS ID Number: j 23 /,4 i GiDDr [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Trott Production Facility Site Location: NESE Section 7 T4N R68W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: 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. 391681 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 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 O 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 O Change company name3 ❑ 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 a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate loading into tanker trucks Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 10/05/2018 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 ■ BI Is this source located at an oil and gas exploration and production site? Yes No p ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • SI 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 AVIV:COLORADO 2 I Ce y^Vi:ci l�;C:F Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 0 Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 127,509 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") 106,257 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 60 V ° F True Vapor Pressure: 5.2 Psia @ 60 °F Molecular weight of displaced vapors: 66 lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. ANIFIN COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit g and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.324431, -105.040427 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) ECD -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) ✓❑ Circular ❑ Other (describe): O Upward with obstructing raincap Interior stack diameter (inches): TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOC/HAPs Rating: TBD Type: ECD MMBtu/hr Make/Model: TBD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 % Minimum Temperature: TBD °F Waste Gas Heat Content: 2,394 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 eOioaA®o 4 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the rail (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO, NO, CO VOC ECDs 95 HAPs ECDs 95 Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane O 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? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM 5Ox NO, 0.068 Ib/MMBtu AP -42 0.02 0.03 CO 0.31 lb/MMBtu AP -42 0.10 0.11 VOC 0.207 lb/bbl AP -42 11.02 0.55 13.22 -` 0.66 ..- Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0041 lb/bbl AP -42 301 — 15 - 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5I Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit 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. (\ Si L. �4atur�e Le all Authorized Person erson�( of 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 El 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: httos://www.colorado.Rovicdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6 1 ., Hello