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Home My WebLink About20191290.tiffCOLORADO Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 March 22, 2019 Dear Sir or Madam: RECEIVED APR 01 2019 WELD COUNTY COMMISSIONERS On March 28, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil It Gas, Inc. - Milkshake 31-W 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 John W. Hickenlooper, Governor ( Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer yib/(9 CG.PL(TP; kl1.(3T), AWSM'I£ ICH IGW) 4/►!tq 2019-1290 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Milkshake 31-W Production Facility - Weld County Notice Period Begins: March 28, 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 a Gas, Inc. Facility: Milkshake 31-W Production Facility Well Production Facility NWSW of Section 32, Township 6N, Range 67W Weld County The proposed project or activity is as follows: The operator is requesting permit coverage for eight (8) condensate storage vessels, two (2) produced water storage vessels, hydrocarbon loadout, natural gas venting from two (2) vapor recovery towers (VRTs) and natural gas venting from twenty-three (23) low pressure separators. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1087, 18WE1088, 18WE1089, 18WE1090 and 18WE1091 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.Qov/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: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 ORA0O Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: -HarrlsonSlaughtt 388856, Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: €xploration & Production Welt -Pad What industry segment? Olt -&Natural GasPraduction&Processing `. Is this facility located in a NAAQS non -attainment area? -Yes If yes, for what pollutant? Elt� Carbon Monoxide (CO) E l Particulate Matter (PM) €xiractioo Oil &.Gas Inc 9CE8 Milkshake 31-W Produ ion Facility NWSW quadrant of Section 32, Township 6N, Range 67W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range Ozone (NOx & VOC) WSW 32 6N 67 AIRS Point # Emissions Source Type Equipment Name Emissions Control? permit # Issuance # Self Cert Required? Action Engineering Remarks 010 Condensate Tank Condensate Tanks Yes 18 E1087 1 Yes issuance Section 03 - Description of Project Extraction Oil & Gas, inc. (Extraction) submitted an application requesting permit coverage for several new sources at an existing synthetic minor oil and gas well production facility located in the ozone non -attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon loadout, VRT venting, separator venting and natural gas fired RICE. The RICE are obtaining permit coverage under the GPO2. This preliminary analysis only addresses the condensate storage vessels, The condensate storage vessels are APEN required because uncontrolled requested VOC emissions are greater than 1 tpy (Colorado AQCC Regulation 3, Part A, Section IL8.3.a.). Additionally, the source is permit required because uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (Colorado AQCC Regulation 3, Part 8, Section ILD..2.aPublic c.), NOs emo ment is ons as a result of the prired for oject are greater han 25 tpy, andis source because new etic minor limits tthe change in CO emissions ones as eing established result�of in order tothe project avoid othgreater t anre50 t menu. Additionally, the change _ .,,,.- _.� t are greater than 50 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Regixestirig Synthetic Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? Plo 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) SO2 NOn CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2 Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx J CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory 002 Condensate Tank Facility AlRs ID: 3 , ri 0 010 = ,527 :?3fivil a 4':,.....,. lan...._„w_. -a. _ .- County Plant Paint Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Pimery Emissions - Storage Tank(s) Actual Condensate Throughput= 'Requested Permit Limit Throughput= Potential to Emit (PTE) Condensate Throughput= Secondary Emissions - Combustion Devices) Neat content of waste gas= it <os £Btu/scf Volume of waste gas emitted per BBL of liquids produced = ,9 1;%Y20iocf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Actual Condensate Throughput Whie Emissions Controls Operating = , 2,$l&,DUY Barrels (bbl) per Year Requested Monthly Throughput= 293119 Barrels (bbl) per month 10,070 MMBTU per year 12,084 MMBTU per year Potential to Emit(PTE) heat content of waste gas routed to combustion device= 12,084 MMBTU per year Section 04- Emissions Factors & Methodologies bbl/year Pollutant Nash Emission Rate (ib/hr) W&e Emission Rate (lb/hr) VOC :20.42250633 - 28.34797861 Benzene 0.04772 00420483 -. Toluene 0.0337314 0.0371338 Ethyibenzene :. 0.00379338 0.00397990 :. Xylene .:0,01129051 0.01314197 n -Hexane = 0.301171 0.41108 224TMP ::0.00230005 0.00301259:: Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) MIME= MIEMEM_ - MIIMMIMIIMMEIMMIESMMC ilrlffiTIMI=EMIM ®" Control Device Uncontrolled Uncontrolled Pollutant MIZZIZIMEMETIMMEmission Factor Source (waste heat (Condensete combusted) Throughput) i1f 00075 0.0000 9 IMEMBIIIM: ., 0.8075 0.0000 00680 0.0002 0.0011 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions uncontrolled Controlled (tans/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 NOS CO 213.61 178.01 8.90 213.61 10.68 1814 0.05 0.04 0.04 0.05 0.05 8 0.05 0.04 0.04 0.05 0.05 A 0.41 0.34 0.34 0.41 0.41 70 1.87 1.50 1.56 1.87 1.87 318 Harardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled fibs/year) llbs/year) Requested Permit Omits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n-Hecane 224 IMP 781.99 651.66 32.58 781.99 39,09952 665.02 554.18 27.73 665.02 33.25 68.09 56.75 2.84 68.09 3.40 214.03 178.36 8.92 214.03 10.70 6256.84 5214.03 260.70 6256.84 312,84 46.54 38.78 1.94 46.54 2.33 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, 8 Regulation 7, Section XII,C, D, E, F Regulation 7,5ection XII.G, C Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 NSPS 0000a Regulation 8, Part E, MACF Subpart HO (See regulatory applicability worksheet for detailed analysts) Source requires a permit Storage 04911 is subject to Regulation 7, Section XII.C-F Storage Tank is not subject to Regulation 7, Section Xil.0 Storage tank is subject to Regulation 7, Section XVII, 0, C.1 & C.3 Storage tank Is subject to Regulation 7, Section XVII.C.2 Storage Tank is not subject to NSPS Kb Storage Tank is not subject to MPS 0000 Storage Tank Is not subject to NSPS 0000a Storage Tank is not subject to MACF HO 2 of 5 K:\PA\2018\18WE1087.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling end Testing Requirements Does the company usethe 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 Memo05-01- 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. N/A - site specific emission factors were developed for this source. Does the company request a control device efficiency greater than 95% for a flare or combustion device? -. dyes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on mint and outlet concentration sampling L Based on the AP E7l000u,d'-d,tw nt)' hoe so 'Is produce trA4LoilltyFive &the existing wells that pond use **facility fractured and began product, nln Noveeiber =011. The lust enng welt wabfracillred in January 2017 and began productionin Feb ary2017 5eventee n new wellsdrilled andbr ughY onlfne in 2018.BaSed... C0G1Cdata, : these new wells -were fractured btureen March and MY 2013 and began moth:twn-q July 3018 Please reference the AMEN suomnedto r the source on 10/11/18 fc r Ist of the well names and AP. numbers. Th reo of the wells produce from the d Ilfo anadon, seventeen pm du cefrom thOtfolargra formation and tree produce a ingl d stream affluid from the @n II at,d Niobrara formations. IncTne sampleUsed tadevelop she specific emission factorcwas obtained horn the facility aft'er all tM wells began production. Since the wells have been pI Hre-fractured or the foot f d wen added) tne sampie is more tentatived act pt b le for establ1hing emission factors test{nateemfss gs r order tocon tnnthe ncyo, ynr,heam szion factors estabilshad �I_aunt+p Z. The to specific emissmn factorsd el p ct ough... p iedlq,d,ample uses braneSr 116°F respectvel7 3 TI N0x and CO enthsions =sere calthted l k the average hqutnecieret nct rnotel, fhe Pr M model :tuned 10 the follywing :ming, fAlFfash Ga Stream 708267MsO/ aY } H tf t nt 2455 928ta/scf. Using this.C ffreyutiort thee` Mscf/d Y 1+ 173E257Mto/duo)')2461,028to/ <fj,(1349 8TM cf/dnYll 2442- 4, The 20d wcalculated using the wastegas ow tatesindleat d follows G0R Iscf/bb€} = lIS,6142 M cf/day) +('7 88257 Mscfldey}i'I d65 oay/yea operator AIRS Point if hn,0mmd because the qp iroblent Immedlatelyc hecks oocurona daily. td RPEN radii et !evict Process SCC Code 010 01 Section 09- Inventory SCC Coding and Emissions factors p C Ina ntaltesl req nng,he operator ha ebtana news to spec csa ate irhedllrtir dcam sonobta d ti out t h l pre p for h i p ctic 314u2o Y4yntt /yfi/1/18Thepre..= and temparauue orthesample re SObas garid �e'ges(rpmYhe fl h® pv, k end thing t p do ed by Yh P Max )iuncP{r7�}r [y"�'teer ty 735[24'-:4 Btu/ BIW king d8 thng Ga S'r (}Gas Fiow. §t mis "deleuidb2d8$61t unn, doorage Hes o ten- ((56142 Mscf/day} )4344580 /scf)/1'349687 on with the f{IfOtlghpUE'iflssd Ite simulation, 3,451,245 27 bblgyear. The 000 ca xas (3,451, 243_92Hbl/y'o t('=1.423 s_t/bbl. v vbleem�ssi nsohservat ohs pebservedrohe 0&M PE n. 0theetho O' 'I 0nss onsare rvanon: Ifvisible emttsiops;.are othrougn the Method 2c, the op at r s e mothod Zta p rt ftp��self f�tao via unnecessary rpvfewad both documents assn xpresse4 they had no..pmmeor, Uncontrolled Emissions Pollutant Factor PM10 0,00 PM2.5 0,00 NOx 5.67E-03 VOC 2.047 CO 2.58E-02 Benzene 5.39E-03 Toluene 4,59E-03. Ethylbenzene 4.70E-04 Xylene 148E-03 n -Hexane 4.32E-02 224 TMP 3.21E-04 Control % Units O b/1,000 gallonscondensete throughput O b/1,000 gallons condensate throughput O 9/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput O b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 95 b/1,000 gallonscondensate throughput 95 b/1,000 gallons condensate throughput - 95 b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 3095 K:\PA\2018\18WE1087,CP1 Condensate Tank Regulatory Analysis Worksheet �Colorado Re uiatlon 3 Parts A and B-APEN and Permit Requirements Snury xs ir.li�e rJnr:.,;t4ainn:anP Ar.^a 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.a1? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPf, N0x greater than 10 TPY or CO emissions greater than 1OTPY (Regulation 3, Part B. Section 11.0.3)? You 6o"e indL'a:edthat source is in 46e Nes-Attt-ament Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than (TPY (Regulation3, PartA, Section 11.0.1.5)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greaterthan 2 TPY, NOR greater than 5 TPY or CO emissions greater than 10 TM' (Regulation 3, Part B, Section ll.0.2)? Istunto repo,. a Vrnn»t Colorado Regulation 7. Section XIle-F 1. Is this storage tank located In the B -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oll and gas exploration and production operations, natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? 'Storage tanks subiect tv iiegulahon 2, Section Xtl.C-P Section XII.C1 —General Requirements for Air Pollution Control Equipment— Prevention of leakage Section XII.C2— Emission Estimation Procedures Section %11.0— Emissions Control Requirements Section ME— Monitoring Section SUS—Recordkeeping and Reporting Colorado Regulation 7. Section 011.5 1. Is this storage tank located in the 5.hr ozone control area or any ozone nonattainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does thls 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? I:Rc,age Tank it m+4 subjoct.n Reo d:sion 7, Seetim:O11:5 Section XII.G.2 - Emissions Control Requirements Section XII:C1 —General Requirements for Alr Pollution Control Equipment— Prevention of Leakage Section XII.h.2—Emisslon Estimation Procedures Colorado Regulation S,Sedl6R XVII 1. Is this tank located eta transmission/storage facility? 2. Is this condensate storage tank]. located at an oil and gas exploration and production operation, well production fadlity', 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? Storagetankis sahjczt to Regulation 7, 9ectiondyil, 0,0.1 g: C.3 Section 04111.0 —General Provisions for Alr Pollution Control Equipment and Prevention of Emissions Section XVII.111-Emissions Control and Monitoring Provisions Section XVII.C.3-Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized"liquids? 'Storage tank 11 can o:I to ilogutrtion?, Y:sfio» X.01,1.2 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60. Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (ma) P.472 BI's)? 2. Does the storage vessel meet the following exemption In 60.111b(d((4)7 a. Does the vessel has a design capacity less than or equal to 1,589.874 ma ('"10,[X100001 toed for petroleum or condensate stored,processed, or treated prior to custody Venter es defined In 60.1110? 3. Was this condensate Stemge tank constructed, reconstructed, or modified (FMC definitions 40 CFR, 60.21 afterJuly 23,1984? 4. Does the tank meet the definition of "storage vessel'a In 00.1111? 5. Does the storage vessel store a"volatile organic liquid (V00)"aas 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 (to,110b(d)(2))7; or b. The design rapacity is greater than or equal to 151 ma ['950 BBL] and stores a liquid with a maximum flue vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' 1-472 BBL] but less than 151 ma ]'-9S0 BBL] and stores a liquid with a maximum true vapor pressure° less than 15.0 kPal60.110b(b)l? 'Storage Tank is not saint -1M NSPS Kb Subpart A, General Prdvisions 060.1126- Emissions Control Standards for VOC §66.1135 -Testing and Procedures §60.11Sb- Repotting and Recordkeeping Requirements §60.1161- Monitoring of Operations 40 CFR. Part 60. Subpart 0000. Standards of Performance for Crude OR and Natural Gas Production, TransmIsslon 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, oc modified (see definitions 40 CFR, 60.2] between August 23, 2011 and September 10, 2015? 3. Are potential VOC emlsslonsfrom 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 60.54307 5. Is the store gevessel sub]ect to and controlled In accordance with re uirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art RH? I5tcrageTans is out subject to 0503 LUDO Subpart A, General Provisions per 460.5425 Table 3 §60.5395 - Emissions Control Standards for VOL 060.5413 -Testing and Procedures 060.5395(g) -Notification, Reporting and Recordkeeping Requirements §60.5426151- Cover and Closed Vent System Monitoring Requirements §60.5417 -Control Device Monitoring Requirements [Note: N a smrageversel 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 SOPS 0000 per 60.5365(e)(2) even It potential VOC emissions drop below 6 tom Per Year] Yes Yes No 1W''""°' Pao rk-...flll#R''. )4te.7.1.0 agno Source Requires an APES. Go to the next question Co to next question Source Requires a permit Continue -You have Indicated the site attainmentstatus on the project summary sheet Continue - You have Indicated the facility type on the project summary sheet. Source is subject Continue -You have determined fadlity attainment status on the Project Summary sheet Storage Tank is not subject to Regulation 7, Section 011.0 -You have Indicated fadlity type on project summary sheet Continue -You have indicated the source category on the Project Summary sheet Go to the next question -YOU have Indltered facility type on project summary sheet. Go to the next question Source is subject to parts of Regulation 7, Sections XV11.90C. Go to the next question Storage Tank Is not subject NSPS Kb -The storage vessel capacity Is below the applicable threshold. Ys WPM NA Continue You have Indicated the source category on the Project Summary sheet Storage Tank Is not subject NSPS 0000 This tank was constructed outside of the applicability dates. an FR. Part 60. Subpart DODO%, Standards of Performance for Crude Oil atoll Natural Gas Facllkles for which Construction. Mrefleatbn, of Recorwtru sien Commenced Aker September 1g, 20]5 1. Was this condensate storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18,2015? 2. Does this condensate storage vessel meet the definition of "storage vessel"s per 60.5430a? 3. Is this ondensate storage vessel located at a faculty in the crude oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment Of the industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Is the storage vessel subject to and controlled in accordance with re uirements for store a vessels In 90 CFR Part 605ub art Kb or 40 CFR Part 63 Sub art HH? 'Storage bank is not subject to ?WS 00000 40 CFR, Part H. Subpart MAR Hit 011 and Gas Production Facilities 1. Is the storage tank located at an oli and natural gas production facility that meets either of the following Criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(0)12)); 0R b. Afacility thatprocesses, 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' 163.760(a)(3))? 2. Is the tank located at facility that is majors for HAPS? 3. Does the tank meet the definition of"storage vessely' In 63.761? 4. Does the tank meet the deletion of"storage vessel with the potential for flash emissbns"s per 63.761? 5. Is the tank subjecto control requirementsunder 40 CFR Part 60, Sub art Kb or Subpart 0000? vublect to A:Aci till Go to the nmh question Go to the next question Go to the next question Storage Tank is not subject NSP5 0000a. Inns IContinue- You have Indicated the source category on the Project Summary sheet. Subpart A, General provisions per §63.764(a)Table 2 §63.766 - Emissions Control Standards §63.773 -Monitoring 663.774 - Record kee ping §63.775 -Reporting MCI Review MCT review Is required if Regulation 7 does not apply AND if the tank Is in the non-attalnment area. If the tank meets both criteria, then review MGT requirements. Dlaplalmer This document assists operators with delemining applicability ofcertain requirements of the Clean AlrAd, its implementing regulations, and car Quality Control Commission regulations. This document is not a nrle or regulation, and the analysis it contains may not apply fo a particular situation based upon the Individual fads and circumstances. This document does not change or substitute for any law, regulation, /any other legally binding requirement and is not legally enhmeable. In the event of any conflict between tha language of this document and the language of the Clean Air Act„ its Implementing regulations, andNrQuality Control Commission regulations, the language of the statute or regulation will control, The use of non -mandatory language such as°recommend,"°may,""should," and "cen,.Is intended fo describe APCD Interpretations and recommendations. Mandatory tetrandogy such as "must' and "required"are intended to describe controlling requirements under the termed the Clean Ad Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and outsell Storage Tank is not subject MACT OH -There are no MAC? Hy requirements for tanks at area sources COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1087 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Milkshake 31-W Production Facility 123/9CEB NWSW SEC 32 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Tanks 010 Eight (8) 400 barrel fixed roof condensate storage vessels connected via liquid manifold. Enclosed Combustion Device(s) 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, Iy 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/pacific/cdphe/other-air-permitting-notices. 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 - Air Pollution Control Division Department r.4 3 aPin. Heatth o Ern-isarrvsnk Page 1 of 9 certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/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 Condensate Tanks " 010 --- --- 10.7 --- 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. 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.) COLORADO Air Pollution Control Division EDepat:M@!tt t 41.f$iX=: F?P.3lit2 `c F.":tircnrrunt.. Page 2 of 9 Facility Equipment ID AIRS Point Control Device Pollutants Controlled Condensate Tanks 010 Enclosed Combustion Device(s) 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, Section II.A.4.) Process Limits Facility Equipment ID AIRS point Process Parameter Annual Limit Condensate Tanks 010 Condensate Throughput 3,451,244 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 ail 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) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal 1COLORADO Air Pollution Control Division Department of x�a lie. Health e Environment Page 3 of 9 operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 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 I't MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 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, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: COLORADO Air Pollution Control Division Dq,,3rt.^ewtt.'? Vc En'vimn„ ent. Page 4 of 9 For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a 'restriction on hours of operation (Reference: Regulation Number 3, Part D, Section V.A.7.B). 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 COLORADO Air Pollution Control Division 1 oepartment ^i Nblt Health o E^.,5zar:3v nt. Page 5 of 9 operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and 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 (criminalpenalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Permit for condensate storage vessels at a synthetic minor oil and gas well production facility. COLORADO Air Pollution Control Division ..,,Inntrmit. sf Puhh -ea;t^ Page 6 of 9 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 (Ib/yr) 010 Benzene 71432 782 39 Toluene 108883 665 34 Ethylbenzene 100414 68 4 Xylenes 1330207 214 11 n -Hexane 110543 6,257 313 2,2,4- Trimethylpentane 540841 47 3 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 010: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 1.238x10-1 6.189x10"3 ProMax 71432 Benzene 2.266x10-4 1.13x10-5 108883 Toluene 1.927x104 9.63x10-6 COLORADO Air Pollution Control Division avartment rf nublMr •?e.a tFa & E,Mronrrtent. Page 7 of 9 CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 110543 n -Hexane 1.813x10-3 9.065x10"5 Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 95%. The site specific emission factors in the table above are based on a ProMax simulation. The ProMax simulation is based on site specific pressurized oil sample obtained from the outlet of the low pressure separator for the Milkshake 31W -20-6N well on 09/18/18. The sample temperature and pressure are 116°F and 50.6 psig respectively. 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 3O days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, n -Hexane, formaldehyde and Total HAPs NANSR Synthetic Minor Source of: VOC PSI) True Minor MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://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 COLORADO Air Pollution Control Division awartment rf Th bii;. Health a Fx,4rcn>nv;nt. Page 8 of 9 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 :COLORADO Air Pollution Control Division rx,prtrwrIt. rt yips;' Ntla3th `r Fntrtwn:"' nt. Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: HarrlxoixSlaughter Package #: :38Bs5s Received Date: 1/2018 Review Start Date: 3/5/2018 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploration & Pr aduct'on W What industry segment? all..& Natural Gas Production & Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? El Carbon Monoxide (CO) -Extraction Oil & Gas, Inc, 375 GCE13' ;Milkshake 31-W (Weld County duction Facilis NWSW quadrant of Section 32, Township 6N, Range 67W Section 02 - Emissions Units In Permit Application • ❑._ Particulate Matter (PM) ❑J Quadrant Ozone (NOx & VOC) Section Township Range WSW, 6N 67 AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 011 Produced"Water Tank Water Tanks Yes 18 E1088 1 yes' Pecan nittaI Issuance Section 03 - Description of Project Extraction Oil &Gas, Inc.(Extraction) submitted an application requesting permit coverage for several new sources at an existing syntheticninor oil and gas well production facility located in the ozone non -attainment area'. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon loadout, VRT venting, separator venting and natural gas fired RICE. The RICE are obtaining permit coverage under the GP02. This preliminary analysis only addresses the produced water storage vessels. The produced water stctrage vessels are AMEN required because uncontrolled requested VOC emissions are greater than 1 tpy (Cobrado AQCC Regulation 3, Part A, Section II.B.3.a.). Additionally, the source is permit required because uncontrolled VOC emissions from all AMEN required sources at the facilityare greater than 2 tpy (Colorado AQCCRegulation 3, Part 6, Public coma ment is required for this source beca• use new synthetic minor limits arebeing established in order to avoid other requirements, Additionally, the change in VOC and NOx emissions as a result of the projectare greater than 25 tpy, and the change in CO emissions as a result of the project are greater than 50 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Rdgtiesting 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) Is this stationary source a major source? If yes, explain what programs and which pollutants here 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) < Yes SO2 NOv CO VOC PM2.5 PM10 TSP HAPs CO VOC PM2.5 El El PM10 TSP HAPs ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory 005 Produced Water Tank Ifacillty AIRS ID: o my Section 02- Equipment Description Details 5010 Plant DetailedlEmisslons Unit TtwO..(2(4006ame1 Rxdd roof pi Description. Emlssloo Control Device Enclo J comfiustfon dwce(s) Descripion: Requested Overall VOC & HAP Control Efficiency Pe SectioiW3 - Processing Rate Information for Emissions Estimates 0' Actual Produced WaterThroughpct While Emissions Controls Operating= Requested Monthly Throughput = 75637 Barrels( (bbl) per month )Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water ThrouelrPut= Secondary Emissions- Combustion Devise(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced— 3t'v't 142 0f/bbl Actual heat content of waste gas routed to combustion device= Requested heat content of waste gas routed to combustion device = 'Barrels (bbl) per year Barrels (bbl) per year Btu/scf Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Ex= Q. MW'Xx/C Ex = emissions of pollutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas =SG of gas' MW of air Xx= mass fraction of x in gas C = molar volume of Ideal gas (370 scf/Ib-mol) at 60F and 1 atm MW GWR 3831 Hydrogen Sulfide COZ N2 methane ethane proean isobutane n -butane Isopenane n -pentane c/dopentane n -Hexane cydohexane Other hscanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes a Ib/Ib-cool scf/bbl Weight Percent 1511 0.00 28.60 8.01 12 142 5.29 /::13.3_.:,);'__. 049 j11 115191'3 3i„3..0.49 156 0.70 �, 1/1333 31 3 7 .0.46 a:00 165 111 '::'339.' ..0:00 0 D:1 00 103 Total VOC Wt % 10090 34.13 Will this storage tank emit flash emissions? 1,334 MMBTU per year 1,600 MMBTU per year 1,600 MMBTU per near Emission Factors Produced Water Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 4.38078E-02 2190E-03 .v. . _ 'T Benzene 208115E-03 1041E-04 Toluene 142599E-03 7.130E-05 - - Ethylbenzene 104892E-04 5.245E-06 / Xylene 4.38697E-04 2193E-05 n -Hexane L53066E-03 7.633E -OS 1' 224TMP 0.00000E+00 0000E+00 Control Device Uncontrolled Uncontrolled Pollutant (Ib/NfMHtu) (Ib/bbll Emission Factor Source (Produced (waste heat combusted) Water Throughput) PM10 0.0075 0.0000 1416XL�A��Jk ^7. Fs PM2.5 0.0075 h 0.0000 NOx - (Loam 0.0001 y y CO 03100 0.0006 eat Value Calculation Component LNV (btu/roc*! -HV {Btu/scil Water 0 0 0 102 0 02.6491 ❑ N2 0 9.9996 0 methane 9093 -2] 4701. "" 1010 ethane 1618.? 5.1300 1]09.7 propene 2314.3 21.926' -1516.0 isobutena 3003.4 0.851/ 3250 n -butane 3010.5 31317 3262.4 tentane 3690 0.0079 40019 pentane 3]06.9 0.6509 4008.7 119901091090 3512 9.2187 3763.6 Cychhexane 4179.' 0.1811 4431.0 H=xan� 19aa0940940 of 9-tiexa101 4403.0 0.6735 4756 hepianes 5101 0.2434 502.5 M,llV/ayclohexane 4863.? (1.9623 52'- 07159as9 5790 02706 Ptananas 6493.2 9.0516 =. °6.4 Depanas+ B 35905 O.Z210 1060 e. 4273.7 0.9193 4174.9 Ethyl, r_ne 4970.- 0 0268 9222 0910959:Al. ^n1.0. . 9:0901 4957.1 0.'x12 12 .7 nliaxane 4401.3 04831 -i 5,5 224-3OPiLHV/H1^Vo CWOVn=1 5:78.8 0 X51.6 924 539.8 0 637.1 Lower Healing Value of Gas Higher Heating Value of Gas 1168.840052 9:u/;cf 1274.470293 8¢o/scf 2 of 4 K:\PA\2013\ISWE1088.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors 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 (Ibs/month) VOC PM10 PM2.5 NOx CO 13.507 16.256 0.813 ]9.507 0.975 166 0.006 0.005 0.005 0.006 0.006 1 0.006 0.005 0.005 0.006 0.006 1 0.054 0.045 0.045 .0.0544 0.0544 9 0.248 0.207 0.207 0.248 0.248 42 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibe/Veer) Actual Emissions Uncontrolled Controlled (lbs/year) )lbs/year) Requested Pernik Limits Uncontrolled Controlled (Ibs/year) ((be/year) Bentene Toluene Ethylbenzene Xylene n-Hexene 224 TMP 18853.40 1544.50 77.23 1853.40 92.67 1269.94 1058.29 52.91 1269.94 63.50 93.41 77.84 3.89 93.41 4.67 390.69 325.58 16.28 390.69 19.53 136&50 1140.42 57.02 136650 68.43 0.00 0.00 0.00 0.00 0.00 Section 06 - Re latary Summary Analysb Regulation 3, Parts A. Regulation 7, Section XVII.0, Cl, C3 Regulation 7, Section XVII.C.2 Regulation 6, Part A. MPS Subpart 0000 NSPS Subpart 0000a (See regulatory applicability worksheet for detailed analysts) _ Source requires a permit Storage tank is subject to Regulation 2, Section XVII, El, C.1 & C3 Storage tank b subject to Regulation 7, Section XVII.C.2 Storage Tank is not subject to SOPS 0000 Storage Tank is not subjectta SOPS 0000e Section 07 - Initial and Porlodk Semolina and Testing Requirements Does the company uses site specific emissions factor to estimate emissions?if yes and If there ate flash emissions, em the emissions Sworn based one pressurized liquid water sample drawn at the fadliry 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 n 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? 'cn oZI 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 OFp i 3 Ri�Xoi9fied(gQt(IfFAPa[ eareb cad Ilashll IatiPRapalys E on tl 5P3'5' p S pr unzed t pl obi ed 09/lt/ltf th Milk b k 3100206N it Th itr f₹he eid� Spec 3 �,'Fleshgasaaga/T wn1 nSl l Art/bb Gash grs 1 ul ght t3478361ts/Ib Th N hlh t lys d t ph g t k do of 322 psIa flfl _ 1_�7xrr�33. sh Nbe red ip t greasons:(ml good nc o ft s pcs f f h [pro Is ri ssek Anes natp vdetl rarmatonan met nods[ gestmatmgwcrk ng a. ::1:11,'11:,,,mic OoEanegen develo in ties fcemtss ens fattnrs for ducedwaterthlAashs wgnld IiKRyh am madued [ [ ithemunsd I pod gip holds(e s75016/yearl.,sates4k,em ssmn farMa5 torihese HAP5 wit rtot be ncluded nthe permR.coq odT tl Od ly blob nl YI 1hon'hl eoseruea170500tee[od22, tetlsregtiredtommeproeh h R ns+ #y{as aka ed ,4r� 5d 2l t4 'A tkes k cart¢ uri. a£y t fUC�p[4�`3�P#3, r�dl�.l�P,'ci'),tYfIIrRBB'S05EYIeWpfigf�o comment The oPetatorrgv ewetl6othdocu entsand axP essed they had oocommeo6 AIRS Point # Presses# SCCCada 011 01 404-003-15 Freed Roof Tank, Produced Water, worldng+bmeththg+Rasping losses Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP unconrolled Emiulom Factor 3.19E-04 3.19E-04 291E-03 1,04E+00 133E-02 4.96E-02 3.40E-02 2.50E-03 1.04E-02 3.66E-02 0.00E+00 Control % 0 0 0 95 0 95 95 95 95 95 95 Untie b/1,00ogellons liquid throughput b/1,000ge11ons liquid throughput b/1,060 gallons liquid throughput b/1,000 gallons liquid throughput b/1,IXIOgellons liquid throughput b/1,000gellons liquid throughput b/1,500 gallons liquid throughput b/1,000 gallons liquid throughput b/1,000 gallons liquid throughput b/1,000 gallons liquid throughput b/1,000 gallons liquid throughput 3 of4 Kt\PA\2018\18WE1088.CP1 Produced Water Storage Tank Reguiatory Analysis Worksheet PW5. Data On NSPS Kb mlglrc be might but applbble f ,sled b tan. et wmarmnagem. t and INamanf.dlKlse. Ifthe tankr you an reviewing en Mon. of than flail. , please review LAMPS Kb. Colorado w ..env ru aA and Parma Prase am uaufrerta AITAININIENT 1. Art uncontrolled actual emlaam from any anesla polaema ham this Irdvidual&puma ...Han 2 TP1' IR.Ruladon G, Part A, seam II,D.IaR mama. iRecu .D.I.MI s. Ant �adlty nmmrtroleskdvaoCerrata= 0maw.. VV, NO,t venter.. O�lIXaam emaebmgreateertdan oarav lneauto ton a. Don e, sSenl nni1.D.3I0 1,00 lava a a.0000aFa. ueura a loves lmrxttataar+.nraa are uncontrolled emissions aom any afterle pollutants (rote Ws groaner than lila IReR 1.q7 2. Is the operalor.Iming Ica than I% avde oftand athannklmted Individual aronnmaraalhdIlryforp:oaaalagoe andeaa waste.. IR.g1Ietbn s, Pan,, Section 0.0,100 1. Ar...1 nlav uncontrolled v06 emas0am wages..RWV, NG.gM1n1[r.. STPV arm emissions greater lhanloire lnevulatbn R, Pan e, Section 11.0117 Worn. R•pulatlen 7, on 1. is thls tank located aLalnnam lfssim/storage fadl47 es010040m and production operation we3P 00000,00001,mtudga+mm0.....0+henanmW.Ill. promeb[ dam, 3. See Pnanacdw.tuwampetank.lmmroof000000 O 2. Are unroatm00ei actual emissions' ✓alsstamp tank equal mar greaterthan Stan& peryearV00 50,110n XV0.3 ns sir ur Pollution Control Equipment and P revenue of Emission Sentan .Ernfslan.0 Control and ®w=an,Rega,e-mem, dreg P,mnwm s. Deez the pnaduanel waterstarage tank cootatri ni^et fro, theaowing addmmwl eawle,aapph. ISaaraxctlengvll.at capture and MonyM¢(e;'stmnee Tanks!mai wnF Riree00udm mntmlEquipment 1, wS3 water Lei loaned 052 orm7delnmlosdefinl"532323FRR`0,l1en=aN:t'®zo:�a52pteembetle, ems: Ian.darm, e<wdthetnd,ady7 2. 2. Cant Rut 001ama ,gewasa' per60.sa wa pe• ryear? 100 as sauna ReauLa an APEN. Go 10 tn. nod question Latanat question Some Requires a per. ran... Yea lave e 11030 wmm2ryshed. theta.,type ryhe Project summary dad. Go to the nod vuestan source h s ublent m pa rt+of Regaatlon 7, seism aW.Rae Go to the seat eumeen [NO• ...Amass a 22ymloell pram. at Resularan 7,5eanl.2,22men ono 0ae subpart 3, General Pmalau per 060.52251041a 400.s5,5.eminlpm Catfal..anaawfaa ono 450.03011¢1- ,200 aad:am lei-tll„and Pr k.0,6. es w - Nadrwun, Reporting and Rdn:akeepl. R equirements geo.s2sNe1-Caer and rm d Vent WO. awnndna Rmaranam x0...,7 _mmrol oadnmpnnnln00 e: semen& Note: aemy 135 wbina Nex0000ehameml.wm•bou0 pa you gD6 Gnm.60,000600v dwamin5aen doh, le should rem+0auhj+0m MPS Goon am. 6um690E ) ew p w.ivocemlalon5dmpb5mw 6 tons paryeaal :<ad.rdeaf P5derm.ma far6rd.00mnd Nature C..Paalhle.arwmdrxnstrradon, 22nL2 on,e R0camtrmbnmmmanodafare5Pambav,2003 I. xis protium, wnovnw(& cal endrualed2msprctrvadl or.006.oee dd0nloen+ 40 aR,eo.21andsegtembn 1,20157 e1 veud medlhelePnnlnothtosego mael°r pe611sasun 3. D this produced rwwaateramnke vessel located m. fealty In the crude al and natural pa production segment, natural,.0r...1n/segment armtual entmmmh&kn and dm„esegmmtatfaiduary7 0. vOc ernIssfors' from the Individual 5. 0105 wch reau0:ernentaforatotn,ewsel.rin a aR nn 60 S. rt eb esdo 03113•363 Su n007 storage rvelar,era-aabaa fu,,Ora rut 5Aerra2Iewia 0.0011.02 Raa31.don7 de. not apply MDR tin mmak Int . nenawlnm.m5n5. II W torkmwuboth2dlurla,dunnvawwnneu 3.:5:3. 0lselalmas went asa.lagmmel= withMining024,3 eppltabd20arcMeinmquiwmnls al me Clean AlrActlls implementing repuhlions,endA0WeIIN Cmbol Cmdasbnmpulelions. This docurteni rs ma 0,0 end Me analysisRmntains may. not eippy too p502111laralluelun based upon Ins individual leafs end c 02157ences.Thu 020002 does nod chafgew subsdl✓la bony law regu.lbn, orany W Wise Welly binding requirement and. nal legaly enforces... In the eunl am, 5O212confliel 7 270 00 the language of lids dmumanl and Ilia 952 002 of the Clean kraal., its Impemenling rep✓lehona, and<trWekly GM. Commisson rapulelbna Ihe.0202p, of the stelule &mode. veiTconbd. The useolnamaMalay language such es • "sM302110end '210' is 1020 2 b describe A00 Intelpelel0vaa and recommendations. Mandalay lc•Mmbgy such e122022 end 7.M:ed. ere Intended to describe conWlling reequiems. unties the Imu 01 Ma Clean AV Act aMAH Quality CmVal Commission repu.lbns, but MIS daCumanl does nal asfablah bpeyDarling requvmenfs b ad olds.. 7.777 Cantinue•Voulavelfatcaterlat sown category on s Project summery shed. vc550,20k not au4ea 1.131,3 DD00-This tankwaaewtrumtd outside of Naapolmhuty data Go to .0 nett nuealon 5100235 (220 b rot 22450 Nsps 00002. COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 1 8WE 1088 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Extraction Oil Et Gas, Inc.` Milkshake 31-W Production Facility 123/9CEB NWSW SEC 32 T6N R67W Weld County Well Production Facility;'. Equipment or activity subject to this permit: Facility Equipment ID AIRS Equipment Description Point Description Emissions Control Water Tanks 011 Two (2) 400 barrel fixed roof produced water storage vessels connected via liquid manifold. Enclosed Combustion Device(s) 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, t y 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.Qov/pacific/cdphe/other-air-permitting-notices. 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 - COLORADO Air Pollution Control Division V.A. !rnent o1 Health o Environment.. Page 1 of 9 certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/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 Water Tanks 011 --- --- 1.0 --- 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.) COLORADO Air Pollution Control Division Page 2 of 9 Facility Equipment ID AIRS Point Control Device Pollutants Controlled Water Tanks 011 Enclosed Combustion Device(s) 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, Section II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Water Tanks 011 Produced Water Throughput 890,569 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.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion. device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. ;COLORADO IAir Pollution Control Division :'. Derrw?m.rt: 21 Public Neatth 6 Environment Page 3 of 9 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 a MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (O&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions 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, Section II.C.) Annually by April 30t follows: whenever a significant increase in emissions occurs as 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 COLORADO Air Pollution Control Division Department f Thablic Hea ti ' F.,Mmnmrnt. Page 4 of 9 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. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). 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 M.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 representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 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 !COLORADO Air Pollution Control Division Npartment :.1 ANir HeaR fr Environment. Page 5 of 9 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: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance 'COLORADO I Air Pollution Control Division ^era?'.mn;.,( PsYsi1r. Hrasthc F.:z,:ircr:rzt. Issued to Extraction Oil Et Gas, Inc. Permit for produced water storage vessels at a synthetic minor oil and gas well production facility. Page 6 of 9 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) 011 Benzene 71432 1,854 93 Toluene 108883 1,270 64 Ethylbenzene 100414 94 5 Xylenes 1330207 391 20 n -Hexane 110543 1,369 69 All ►vote: 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 011: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 4.38x10"2 2.19x10"3 Gas Analysis 71432 Benzene 2.08x10"3 1.04x1O4 108883 Toluene 1.426x103 7.13x1O5 1330207 Xylenes 4.387x1O4 2.19x105 110543 n -Hexane 1.537x10"3 7.68x105 ;COLORADO I Air Pollution Control Division D.: armen; f.MPublr Health 6 En,hrcnme nt Page 7 of 9 Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 95%. The site specific emissions factors in the table above are based on a flash liberation analysis conducted on a site specific pressurized water sample obtained on 09/18/18 from the Milkshake 31W -20-6N well. The results of the analysis provided a speciation of the flash gas, a gas to water ratio of 1.4 scf/bbl and a flash gas molecular weight of 34.7836 lb/lb-mol. The emission factors were determined using the results of the flash liberation analysis in conjunction with the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4- 3).The flash liberation analysis was evaluated at atmospheric storage tank conditions of 12.2 psia and 70°F. 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 NANSR PSD Synthetic Minor Source of: VOC, CO n -Hexane, Formaldehyde and Total HAPs Synthetic Minor Source of: VOC True Minor 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 COLORADO An Pollution Control Division Heath r E^:^:art*✓;rs. Page 8 of 9 MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX ;COLORADO Air Pollution Control Division } DerAftrnen; ci ,bit Ne a;tnn Er rcrrront. Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Harrison Slaug Package 6: 328656_ Received Date: 10/11/2018 Review Start Date: 3(6/2013 Section 01. - Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: NWSW quadrant of Section 32, Township 6N, Range 67W County: I Weld County Type of Facility: What industry segment?e a Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) E� f5gn Oil & Gas, Inc. Milkshake 31 -W -Production Facility 5' T '; i !ijl Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NWSW 32 6N 67 Particulate Matter (PM) E Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 012 - � � I,gaid 14 tii#ig / Liquid Loading Yes : 18WE108P 1 ,� Permit Initial O Issuance 13 -. 3377�773333 Section 03 - Description of Project Extraction Oil & Des,,,Inc. (Extraction)sabn the ozone non -attainment area. With this. venting, separator verzting and natural gat Y The h drocarboa doutsourcel PAN r 1 33;3 3 3 31.r„c the source pe is rte{it-required bPcau„„s£un, Public comment',: as a resultpfthei an 25 Spy, and the change?:. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? coverage forsevera l new sources at an existing .synthetic rrinor-e b and gas. well prodbn,„„ permit coverage for condensate storage: !essels, pthdOedd water storage vessels, hyflf'' ?itcoverage under the GP02 his preliminary analysisanly. addresses the hydrocarbon Loadautsa ions are greater than 1 tpy (Colors Lthe facility are greater Regulation 3, Part A, Section 11.8.3,a.). Adr loredoAQCC Regulation 3, Part B Sectii Lst3l7li'siYfl'in-order to avoid'le� [ , 'Additionally; the c5ange in VOC and ;a)tdithe project are gre- Section 05 -Ambient Air knpact Analysis Requirement: Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. 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) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? a If yes, explain what programs and which pollutants hert SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx J CO VOC PM2.5 ❑ ❑ PM10 TSP HAPs ❑ ❑ Hydrocarbon Loadout Emissions Inventory 005 Liquid Loading 121 Facility AIRS ID: Plant q3Z', Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: ,Loadout of condensate from storage tanks to tanktrudcs using submerged fill. Emission Control Device 6risfgstldr-Ck Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: 95.00 Requested Overall VOC & HAP Control Efficiency 36: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded = III .,g 3305& Barrels (bbl) per year IRegpested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = Actual Volume Loaded While Emissions Controls Operating = Requested Monthly Throughput= 13607 Barrels (bhl) per month 133,506 Barrels (bbl) per year Barrels (bbl) per year 47 Barrels (bbl) per year Secondary Emissions- Combustion Device(s) Heat content ofwaste gas= �ff)n: J 2454O8. Btu/scf Volume of waste gas emitted per year = 346,626.59 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? Hydrocarbon Loadout 712 MMBTU per year 854 MMBTU per year 854 MMBTU per year The state default emissions factors may be used to estimate emissions. Pollutant Pollutant Uncontrolled Controlled (Ib/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) 4.10E-04 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Uncontrolled Control Device Uncontrolled (Ib/MMBtu) (lb/bbl) (Volume Loaded) (waste heat combusted) �_ 0.0006 1 0.068a 3.14E-06 3.63E-04 Emission Factor Source Emission Factor Source 2of4 K:\PA\2018\18W E1089.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 (Ibs/month) PM10 PM2.5 5Ox Nog VOC CO 0.003 0.003 0.003 0.003 0.003 1 0.003 0.003 0.003 0.003 0.003 1 0.000 0.000 0.000 0.000 0.000 0 0.029 0.024 0.024 0.029 0.029 5 18.90 15.75 0.79 18.90 0.95 161 0.132 0.110 0.110 0.132 0,132 22 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 65.68 54.74 2.74 65.68 3.28 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 576.75 480.62 24.03 576.75 28.84 0.00 0.00 0.00 0.00 0.00 Section 06 - RegulatorySummary Analysis Regulation 3, Parts A, R Source requires a permit RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) The loadout must be operated with submerged fill to satisfy RACT. Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 1 Typtcal)y thevoiume ofwastegas emitted ouchmghydrocarbonloudest operations iscaiculated usrogthe following equation: Volume VOC(tan/year)]`l200016/ton]J[Molecnier Weight a (lb/lb iitol))°)379"cuff Ilt•mol), Whan the iSa€e default emission Faders far condensate loadout ate used So astimateprimary emirs Ions, the Inputvalue for molecular we%ght is 6S• lb/lb,,mol•. Usmg this information, the,yrr requestedvolumeafwaste gas omitted woUldbe Calculated at27p,454.69 ref/year. This volume of waste gas- along with a heat content of22558tu/acfand AP -42 Chapter13 '-- > (3,660lb/lyiMBtu and 09 llv/MMB£U respectiveFyy results In NOxand Cl) emissions of 03017 tpyand 0.077 tpv:'respea• lively. I3 Wtrhthtsapplicatian ihetsporataxchaseta estimate MOxand C11 missionsassoctatedwrththe, loadout operation using the GtXt(2,163617':ref/bbi)end tvastegas heat:content (2,464.08 Btu/suf}obtained from'. ,.. liquid loadfngv pons"stream in the PCPMaxsimalatrTt- his stream`i is ti aeda ip theProMaxaankloss stencilusing storage tankpropetties,lacation in format ion, carrrertowhicfi 448 is(aaded, nthod by which carfieris loaded Aajdnlaximum hatuiyloading iy,:,,eis streamisb ed on:amaximumhouriy.iaadingrateof 393, 9775 bb11hr(3,451,243.92 bbl/fear). ilswgtlo reformationi ,conjunction Withvapor ) volumetncfiow rate frnacfhe stream,20.458 Mscfjday,theGOR afthts stream was miculatedas fo(Inws:)20.458Mscf/day)*(2000scf'Mscf)*(365 day/year)jj3'n''' 451,24392 bbifyear)'=2:]. z3617scf/bbL Additionally, E ,,p o,t1x eatenlated a heatconCent o€ 2,454 08 Rtujscf,'''fhis I formation rs gsed'rn.the Combustion Device calculations in SectbrrA3 abo in, Both the heat content nd G0R used to catuutatncembu-;Li ermsslans : l fromthrs sfFearn ere maretonservatwec paredtoth v fue used fo the condensate storage vessels.5ince the to d •utopemt on only iecolves stabi)i;ed fluff 1,She_GOlf,assocr3ted wrath the cc ider ,eteytonage sselsis empectedtabe higher rn practice becauseit insiadesgas libe I dfin m the fluid as a result of a pressure drop Ouetot)%,the operator is typically allowed to. usathe GctRapd he at ontentassociated wtth. used on this" p .,. ... , the donder{satestoragGy"ssels to calcu' _ �sentaaon ofac the used to clalcufate loadbd'C om8us8nn.'kmissihe cor,kely eonseryei• '' u, q p ,_ g do met hod. TFieuse ofactual- dal nested wdh thinfacilityratherthana •�• a lete aombustidrramisswns associated witfr infarmatwn, thedata then er Addinonall then eratoF;s cafcnlarionresults In mi sipnstl7at aremorec n rvajivetfian theJalues caCColated user the default etimati� default esti atpon meth d is ferable asIt i &el cesuHo is a more acuora[ e ns. Based'ne this' nformation,the eperatepsaalcaiat on was d emediconsees live and acceptabin for. Ifpermitting roses pre y pig ntatfon ofaotualemissio 2 Accordingtathe application, thewast gas sociatedwith the loadout operation is captured usinga vaporcollectionsystensthat collecrsthe and routes thewasto gastodedicated enclosed combustiondevices. --' Thedisplaced vaporsfransthe truck arethou(Sept3separa₹e from Me tank battery Japer collection Bytom. The'perm,i will contain a condition thatregareesthrssystem too, operatede at alt times during loadout ., operations. Iii "14,',10",,,,,,,,,,,',.. = a:. 'r .. ,: .. 3 An initial .. , ..,r t method 9opao[yt st vaasnbf included in permit becausethe operator is required to conduct dadyvsdzte emiss'onsabservations per tfie.0&M plan. in £lice entwsibre emfssionsare observed,ffie op r t Ytrpsthaop�filan fo either repair-tAre prohlem immediatelyopperform a fnrhal method96bsarvation_Ifiisible endssions are observed through th'e„ Method 9,the raper tnr is required to rtnmediatelycorrec•t_ the problem Since•theseahecks occur on 8:._ .:44.,...,55"...„.!::,...•';':i; hasis It was determined none time method9 as parx ofzhe self certification--wasunneeessery. { a o, condens 4. Accord rag lathe applican ate is[ypicalty transported from the facility waptpefine us galea�autarriated custody transLmnsfer (iACT)unit.Ttudk loadout isonly utilized in the"event thepipebne is: unavailable,' p 3 � t - _ -- '- Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point 8 012 Process 0 SCC Code 01 4-06-001-32 Crude Oil, Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0,00 0 lb/1,000 gallons transferred 5Ox 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.619 95 lb/1,000 gallons transferred CO 0.04 0 lb/1,000 gallons transferred Benzene _ 9.76E-03 95 lb/1,000 gallons transferred Toluene 0.00E+00 95 lb/1,000 gallons transferred Ethylbenzene 0.00E+00 95 lb/1,000 gallons transferred Xylene 0.00E+00 95 lb/1,000 gallons transferred n -Hexane 8.57E-02 95 lb/1,000 gallons transferred 224 TMP 0.00E+00 95 lb/1,000 gallons transferred 3 of4 K,\PA\2018\18 W E1089.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B -APEN and Permit Requirements 'Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at en 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 Bats) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbis per year of condensate via splash fill? 5. Is the loadout operation loading less than 15,308 bbis per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, too greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)? 'You have indicated that source is in the Nor. -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than l TPY (Regulation 3, Party, Section li.D.1.a)? 2, is the loadout located at an exploration and production site (e.g., well pat) (Regulation 3, Part B,Section 11.0.1.1)? 3, Is the loadout operation loading less than 10,000 gallons (238 BBts) of crude oil per day on an annual average basis? 4, Is the loadout operator loading less than 6,750 bbis per year of condensate via splash fill? 5. Is the loadout operation boding less than 16,308 bbis per year of condensate via submerged 91l 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 8, Section 11.0.2)7 'Source requires a penult 7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section lll.0.2.al? 'The loadout mast be opal'atati with submerged fill to satisfy RACE. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Qualify Control Commission regulations. This document is not 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,"ls 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 end Air Quality Control Commission regulations, but this document does not establish legally binding requirements In and of itself. r No N No ' Yoe Go to next question, Go to the next question Go to next question Go to next question Go to next question The loadout requires a permit Ne. ,ri The loadout must be operated with submerged fill to satisfy RACT. COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE 1089 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Extraction Oil Et Gas, Inc. Milkshake 31-W Production Facility 123/9CEB NWSW SEC 32 T6N R67W Weld County Well Production Facility', Equipment or activity subject to this permit: Facility Equipment ID AIRS Equipment Description Point Description Emissions Control Liquid Loading 012 Loadout of condensate from storage vessels to tank trucks using submerged fill Enclosed Combustion Device(s) 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, bar 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/pacific/cdphe/other-air-permitting-notices. 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 COLORADO Air Pollution Control Division Department nr ?Win Heath b F.nvironmra Page 1 of 9 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/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 IIl.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. (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 Liquid Loading 012 --- --- 1.0 --- 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. 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 this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division 2ntrldb :. 7ieadi;z: En�,hrcn rw,nt. Page 2 of 9 Facility Equipment ID AIRS Point Control Device Pollutants Controlled Liquid Loading 012 Enclosed Combustion Device(s) VOC and HAP 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. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Liquid Loading 012 Condensate Loaded 160,207 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 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, Section III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Regulation 3, Part B, Section 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. (Regulation Number 3, Part B, Section III.E.) 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B, Section III.E.): COPHE .00 COLORADO Air Pollution Control Division Derartnent 2 Th t,l Hea≥th b Errrrcn?ntrv. Page 3 of 9 a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. Inspections of all compartment hatches at the facility (including thief hatches) shall occur at least monthly. Each inspection shall be ''documented in a log available to the Division on request. 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 seats 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 (Regulation Number 3, Part B, Section III.E.): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks and route the vapors to the control device listed in the Emission Limitations and Records section of this permit. 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. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING E MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OatM) 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. (Regulation Number 3, Part B, Section III.G.7.) d. COMPLIANCE TESTING AND SAMPLING COLORADO Air Pollution Control Division E�f. VT3r 'rent ^I "uhhr. 4':@.1111 `c Ern.rcn 3Vorf. Page 4 of 9 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, Section 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 nonattainrnent 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. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). GENERAL TERMS AND CONDITIONS COLORADO Air Pollution Control Division Department 3 Pt K. Hearn a Ens ronme 3 Page 5 of 9 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 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 bedeemed 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 tobe 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: COLORADO Air Pollution Control Division Dc,par ! wn: 44 ?h3fr is ?il;a G't n F,n'rircnrrw,n₹. • Page 6 of 9 Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Permit for condensate loadout at a synthetic minor oil and gas well production facility. COLORADO Air Pollution Control Division PuNis: Health `c C`.'SYiranment. Page 7 of 9 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 (lbtyr) Controlled Emissions (lb/yr) 012 Benzene 71432 66 4 n -Hexane 110543 577 29 ll Note: All non -criteria reportable pollutants in the table above with uncontroed 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 012• Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 2.36x10"1 4.1x10-4 1.18x10-2 2.05x10-5 CDPHE PS Memo 14- 02 Benzene 71432 n -Hexane 110543 3.6x10"3 1.8x10"4 Note: Controlled emission factors are based on the enclosed combustion device 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 - 'COLORADO Air Pollution Control Division ?tilt:. Health b Environment Page 8 of 9 year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, n -Hexane, formaldehyde and Total HAPs NANSR Synthetic Minor Source of: VOC PSD True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT MACT MACT 63.600-63.1199 63.1200-63.1439 63.1440-63.6175 Subpart AA Subpart DDD Subpart EEE - Subpart PPP Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO I Air Pollution Control Division DerAinment ci Fqg-AX' ^eattn & F.^.rzcrIrr nt. Page 9 of 9 Colorado Air Permitting Project County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploration & Production Well Pad What industry segment? Oil &NeturafGas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: Extraction Oil & Gas, I 123 Milkshake 31,•W Productio NWSW quadrant of Section 32, Township 6N, Range 67W Weld County Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) Quadrant Section Township Range El Ozone (NOx & VOC) N1NSW" 2! S AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert - Required? Action Engineering Remarks 013 Separator Venting VRT Gas Combustion Yes 8W E1090 - 1 Yes Initial lssuanee t Section 03 - Description of Project Extraction Oil & bas, Inc. (Extraction) submitted an application requesting permit coverage for several new sources at'an existing synthetic rotor oilanti gas well picduction facility located in the ozone non-attainmentarea. With this application, the operator is'requesting permit eoverage for condensate storage vessels, produced water storage vessels, hgdrocarbon loadeut, VRT 'venting, separator venting and natural gas fired RICE. The RICE are obtaining permit coverage under the GP02. This preliminary analysis nnly,addresses the VRT venting source. The VRT venting source is APEN required because uncontrolled requested VOC emissions are greater than 1 tpy (Colorado AQCC Regulation 3, Part A, Section: IL6.3.a.), Additionally, the source is permit required because uncontrolled VOC em issions from all APEN required sources : at the facility are greater than2 Spy (Colorado AQCC Regulation 3, Part 6, Section ILD:;2,a.). eq ' because new synthetic minor limits are being established in order Public commentisr urredfiortfiissnurceber rto;void other tequirements Additionally,thechangeinVOCandNOxemissions 3 as a result of the project are greater than 25 Spy, and the change in CO emissions as a result ofthe project are greater titan 50 tpy. - Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Regttessng Synthetic Minor Pe Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Nrr 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) Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs J J J CO VOC PM2.5 PM10 ❑ ❑ TSP HAPs ❑ ❑ Separator Venting Emissions Inventory 013 Separator Venting (Facility AIRS ID: Section 02 - Equipment DescriptIon Details Detailed Emissions Unit Description: County Plant �Q�fll Point Eecfased'H4 Emission Control Device Description:yq ( ii it Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Separator Actual Throughput,' MMscf per year Requested Permit Limit Throughput = tomappgigIaiMMscf per year Potential to Emit IPTE) Throughput= Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 6 MMscf per year Requested Monthly Throughput= MMscf per month 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 RAgifilog 4490 699) - 48.0OP51 b/Ib-mol Displacement Equation Ex =Q'MW •Xx/C MW Weight % Hydrogen Sulfide Oxygen/Argon COO N2 methane ethane propane isobutane n-bstane sppentane _ n pentane cyclopentane n -Hexane cycichco n Other hexanes 5ptanes megy(Nclohexane 224TMP Benzene Toluene Ethylbenzene xylemes CO. Heavies 0.00 0.06 0.60 0,21 97 0.30 33.03 7.71 24.70. s 7:45 0.49 2.32 0.76 0.24 0:00 0117 0.07 0:00 0;40 Total VOC Wt % 100.00 86.9946 cf/hbi from the outlet of the eeporrecove e EPA Eon )nvantoryImprovement Pro Pollutant Separator Venting Uncontrolled (lb/MMscf) Controlled (lb/MMscf) Emission Factor source '® ' ''' =EOM=MMINIEETM0DIEIM �' 00 4 ii Pollutant 0.0457 Primary Control Device Uncontrolled (Ib/MMBtul (Waste Heat Combusted) Uncontrolled lb/MMscf 00759 ))))41 0.:1 0.000E (Gas Throughput) Emission Factor Source Component 100{Stu/.r00 mole% HHV iEtu/ar.P Water 0 (";s.3:; : lig- 0 1202 0 b 6S5u,, 0 02 D 03365 0 methane 90'94 5/l40514 1010 ethane 1618.7 "'<:%I16:?AB:n. 1769.7 propane 2314.9 3IDD4381'' 2515,2 Isohutene 1000.4 51.315 .: 0252 n -butane 3010.8 2043561E 3707_4 is00en1cne 3099 4.22233-.`' 4000.9 n-pente0e 3706.9 4.9657$+ 4000.7 Cyclo0entene 3512 113340' 3763.5 Cyc.on xene 4179.7 $'3905 )) 4431.0 Hexanes Pheating 00140 of n) Hexortel 4404.8 q„5725 4759' ileptenno 5100 r.T::e9.3fi?t-- 502.5 Methy1uyolohexane 4063.7 ]�h':1ia16 e' 5215.9 09)999, 5796 154030 0 6243.9 Nonenes 6493.2 dt60948E'0: 5006.4 000000x:0 7109.0 5%T*Oijiiil, 7743 Benzene 0500.9 -B5D''° 07400 Toluene 4273.7 3.S'"- 4474.9 Eth)49anznne 4970.4 6l OI:W i 5222 Xyimes lAvq of o. in. 6- 090001 4057.1 R'^0 00640 t 5208.7 n -Hexane 4463.0 -6.0051' 4756 224-T.MP IL1V/HI-Vofisooctane) 5778.8 NjliggligVe 02316 1-20 - 586.8 i :00A e"' 607.1 99.9035 Lower Heating Value of Gas Higher Heating Vale of Gas 2487515858 0tu/scf 2700.593192 Btu/sct 2 of K:\PA\2018\18WE1090.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 Ohs/month) PM10 PM2.5 5Ox NO6 VOC CO 0.062 0.013 0.013 0.062 0.002 10 0.062 0.013 0.013 0.062 0.062 10 0.005 0.001 0.001 0.005 0.005 1 0.56 0.12 0.12 0.56 0.56 96 330.90 68.22 3.41 330.90 16.54 2810 2.57 0.53 0.53 2.57 2.57 436 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ns/year) Requested Pemllt Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene Ethylbenzana Xylene n -Hexane 224 TMP 1269.52 261.75 13.09 1269.52 63.48 560.57 115.57 5.70 560.57 28.03 27.70 5.71 0.29 27.70 1.38 107.09 22.08 1.10 107.09 5.35 1.2392.73 2554.97 127.75 12392.73 619.64 5.49 1.13 0.06 5.49 0.27 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (Sae regulatory applicability worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires apermit Source is subject. Regulation 7, Section XVII.8.2, G The control device for this separator Is not subject to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on agar 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. Ono, 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 V0C greater than or equal to 90 tons per year? tf 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 analysts 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 lino, the permit will contain a condition that requires the operator tocalculate 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 pennit 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 rented. The following qua Von s do 3 of 5 K:\PA\2018\18W E1090.CP1 Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes 1. Based on the application,. a flow rpeter,Svas Installed at this facility to measure the entirety of theVRTgas vented and routed to the enclosed eombustiondevice This flow meter is located downstream of the vapor recoveryunts (VW) at this facility amused to compress VRTgas and route itto the selespipel ne. Thistlow meter is thus used to measure total VRT gas that is routed to the enclosed combustion device (ECD) during VRU downtime, Banshee the flow meter location, the operator will not needto track VRU downtime in conjunction with flow meter data to demonstrate wmpliange with the permit limits_ The flow measured by the flow meter will be sufficient fordemonstating compliance with the permit limits. 2. theapplicetlon indicates the flow meters ere installed and operational at this facility. 3. Neither initial nor periodic method 22 opacity tests were included In the permit because the operator Is required to do deilyvisibleemlesionsehecku per the operating andmatetenanceplen. In the went visible emissionsare observed, the operator i srequied to '. either shut in the equipeeentimmedietely and conductrepaas or conduct a formal method22 opacity test. lathe event visible emissions are observed threughthe method 22, the operator Is required to immediately conduct repairsor shut in the equipment if wears cannot be conducted immediately,Sincethls is meretosust on -going compliencedemoestretion than aone timemethod 22, thioteital compliance: demonstration is not necessary-inthe permit. Additionally, thedatiy visible emission checks and subsequent requirements if WHIsle emissions are observed isesufficent orz-gotngcomptanee demonstration, so periodic method 22 opacity testing Is not required -inthe .permit 4. The heetmment used tecalculateNC&and CD emissions was obtained from the gas sample provided in the application. 5. Based onthe APEN provided forthe condensate storage vessels, twentyrhree wells produce to this facility: Fiveof the existing we Is that produce to thisfaalityweretractured and began production in November2013.The last existingwellwesfracturedis tnuery 2017 and beganpreductioe in February2017 Seventeen new wells were drilledand, brought online in: 2018. Based on COG COMM,: these new wells were fractured between Marchand May 2018 and began production In J*2018, Since newwelis Were.l added to and completedat the facility after0B/01/2014, the gascorn 'ng off the separation equipment Hsu*. to Regulation 7, Section XVII.G Conditions referencing these requlmments will be included in the permit 6. In this analysis, the standard equation to calculate emission factors I5 as follows: Emission fader (pollutant x) o (Weight% (pollutant x))/(?00)'(48 08991b/ti-mof /(379sofJlb mol)'(1,000,00(i5d/MMsef}.tisingthls equation, the followi0gensbslen factors were raleuletedi (II VOC e 110,383.29 Ib/MMtof, (II) BenzeneF 212,73 lb/MMeef, (lift Toluene o 93.91lb/MMscf, (tie) fthylbenzene = 4.57 lb!MMset,(v) Xylem,=17.8916/MMsct fell _n Hexane u 2,067.1191b/MMsehand olij 2247MP e 0.85 Ib/%1Mset-Theseemiissiuet factorsde not match exactly to the valuesprovided bythe operator. However, the different between the values calculated using thestandard equation and the veluescalculated hytheaiperater are eegiigible.Asa result, the operator calculated velueswereused for permitting purposes.The differences in the caiculationsare due to the epeept rusieg different molecularweights town vest from moles% to welight % and the use of a molar volume of`a799saf/lb-motretherthae 37P5ut/Itwmot. leorderto makethenalues match, themolar volume of as ideal gas was at§usted in the catul tions in. cells 070-876 T. The operator was provided with e draft permit and ADEN redline to review prior to public comment The operator renewed both-dot-umi AIRS Point 8 013 Process 4 SCC Code 01 3-I6-001-60 Flares section 09 - Inventory 5CC Coding and Emissions Factors pressed they had no comments. Pollutant Uncontrolled Emissions Factor Control % Units PM10 20.56 0 lb/MMSCF PM2.5 20.56 0 Ib/MMSCF 50x L62 0 lb/MMSCF NOx 187.65 0 Ib/MMSCF VOC 110298.42 95 lb/MMSCF CO 855.47 0 lb/MMSCF Benzene 211.59 95 Ib/MMSCF Toluene 93.43 95 lb/MMSCF Ethylbeneene 4.62 95 lb/MMSCF Xylene 17.85 95 tb/MM5CF n -Hexane 2065.46 95 ib/MMSCF 224TMP 0.95 95 lb/MMSCF 4 of 5 K:\PA\2018\18W E1090.CP1 Separator Venting Regulatory Analyse Werkshaat CAM a year Pore and G- OPEN and Pane Paaulreor leourro In the Nen-attalnmeft 1,103 I. Aro mmnndld aewd creseoot horn any ontera pollueim from OA IndlNdual song greater man 2 TPylRegdcdm3, Part A.55tlm Iln.>_ali 1. Pre tool fadlry uncontrolled VOL ernesiom greater...an ST, Non Seater tlan 10 Ter or CO emislan greater than lO TPY (Papuauon 3. Part S,saam llO3)T irlot enough Information PONATTAINMINT Ne uncontrolled onftanany crew, polwnatran thhbtlMdual source greater thin STPY (Regular m3. Part A Section 20.12)22 Are total wmtss lPate unsorted. cerore from ma®m a greater 3TPY,HoagreeNan 5EPv CO emission oeiten than 10 WV (Predation 3, Parte.don 202)2 'Source rpules a Ronne 4brodo Potuirreor,Sartion KYII I. Was rho well newly rmstreaai,M1Wmtdleally hectored. rommdatd on m afterAuggt 220142 ISonne Ismhadto Roguartan T,Scebn%h[&E, G Scion Emere Pmuldons for AP Pollution Control Eaulomenfod Prevention of Emissions SdbnW %.G Pmissam Contra Ahem.", Embalm. Control laptlmsl sad2nt a Is therooara toramtdled tryback-upo alternatemmhustlon device e.e., not the primary coned ded®)Oat h tot endured, IT hlett mn,,Pea. xn!S2.0 Satwn%v11.62e—Alternative emission control esdp em Diana mar Thisdclanedf assists cperetas win aYenmirvrg applicability circa.(n taatLeneres de` e gleenarAce es implementing raged.... Illsand Nl2t OYaxs not Mager stbstitufe kry law, regulation a any ou-legally binding regulamed arkn not legally enforceable reemerge, elegy conflictW&weet Me larguagear Ws document and the lergtege al the t000, 0Acf„ eslmplamerng regulations, and Air Qualify Corbel Commission regulefbns. tlelacgtapecAthestatute a mpualian willambd. The u3see Ode rdataylagter,etch as"recommen—may;''shw0.'0Mtat is Wended la c.c.,.tControl Dintorprelaean ravnmendatins..Atardataytamindotyetch as'musY ard-regukee are Wended tor.scribe controlling requirements under,. fermiolMe Glase krActand Air Duality CONu commission regulations, bag. Leaned.. not establish legally Wedge regurerneRsinaMCRmb. tttss 'IIS sSapnresan APENECm Marenyuectlon 5'e.E.n;.�:< t ta¢Pryit¢apCmt The control devirr b the Cpamto Is not reflect to Regulation T- tartlet 1MI.e.ie COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE 1090 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Extraction Oil Et Gas, Inc. Milkshake 31-W Production Facility 123/9CEB NWSW SEC 32 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit; Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT Gas Combustion ` 013 Low pressure ' natural gas venting from two (2) vapor recovery towers (VRT). Low pressure gas is routed to and controlled by an enclosed combustion device (ECD) during vapor recovery unit (VRU) downtime. 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, 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/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control COLORADO 3 Air Pollution Control Division Page 1 of 9 Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/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 Tons per Year Emission Type Point PM2.5 NO,t VOC CO VRT Gas Combustion 013 --- --- 16.6 2.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate Limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit COLORADO Air Pollution Control Division Page 2 of 9 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT Gas Combustion 013 Emissions from the VRTs are routed to an enclosed combustion device (ECD) during vapor recovery (VRU) downtime. 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, Section II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT Gas Combustion 013 Natural Gas Venting 6.0 MMSCF 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. 9. The owner or operator shalt continuously monitor and record the volumetric flow rate of natural gas vented from the vapor recovery towers (VRTs) and routed to the enclosed combustion device using a continuous operational 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 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal COLORADO Air Pollution ConirolDivision Y2eparr ent nP Fubi c Health F Envtrcnrvra 3 of 9 operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. 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 & MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (O8M) 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 IIl.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, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a COLORADO Air Pollution Control Division My ar:nen::A F ubl+.;. F..^,:pro nen;. Page 4 of 9 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. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). 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 .,not 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 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. 1COLORADO Air Pollution Control rx,partment of er. Hea3;h g En:4rcn�:v:rt. Page 5 of 9 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 shalt 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 theregulations 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: Harrison Slaughter Permit Engineer Permit History Issuance Date Description This Issuance Issued to Extraction Oil Et Gas, Inc. Permit for natural gas venting from two (2) vapor recovery towers at a synthetic minor oil and gas well production facility. ;COLORADO Air Pollution Control Division t Public 4ealth c F;nrircr.:-tent. Page 6 of 9 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 Gas Combustion Benzene 71432 1,270 64 013 Toluene 108883 561 28. Ethylbenzene 100414 28 2 Xylenes 1330207 107 6 n -Hexane 110543 12,393 620 2,2,4- Trimethylpentane 540841 6 1 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 013: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source CO 855.47 855.47 AP -42 Chapter 13.5 COLORADO Air Pollution Control Division Department rt ?uWzc Heatiab F.^srara≥urt. Page 7 of 9 CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source VOC 110,298.42 5,514.92 Gas Analysis 71432 Benzene 211.59 10.58 Gas Analysis 108883 Toluene 93.43 4.67 Gas Analysis 110543 n -Hexane 2,065.46 103.27 Gas Analysis Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The VOC and HAP emission factors listed" above are based on a site specific vapor recovery tower gas sample obtained ' on 09/18/2018. The sample temperature and pressure are 105° F and 5 psig respectively. The VOC and HAP emission factors were determined using the weight % values and gas molecular weight (48.0895 lb/lb-mol) from the gas sample analysis in conjunction with the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4- 3). The AP -42 Chapter 13.5 CO emission factor (0.31 lb/MMBtu) was converted to units of lb/MMscf using a heat content of 2,759.'59 Btu/scf. 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 Operating Permit NANSR Status Synthetic Minor Source of: VOC, CO, n -Hexane, Formaldehyde and Total HAPs Synthetic Minor Source of: VOC PSD True Minor 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 COLORADO Air Pollution Control Division £`>r�rar',man' ri �tiri<;: Heatt^� e r";»:rar:??'✓:r Page 8 of 9 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 COLORADO Air Pollution Control Division E .Partnent v3 Pubk .?ea;t.'₹ c enl^rmlmn2 Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Harrison Slaughter Package #: 388856 Received Date: 10/11/2018 Review Start Date: 5/?/2013 Section 01- Facility Information Company Name: Extraction Oil & Gas Inc County AIRS ID: 123 Plant AIRS ID: 5CE6 Facility Name: Milkshake 31-. .....__......._ .................. Physical Address/Location: County: Type of Facility: What industry segment? Oil & Netural-Gas Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ carbon Monoxide (co) NWSW quadrant of Section 32, Township 6N, Range 67W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range Particulate Matter (PM) Ozone (NOx & VOC) NWS\ 32 6 AIRs Point # Emissions Source Type Equipment Name Emissions Control? permit # Issuance # Self Cent Required? Action Engineering Remarks 014 . '-'Sepatag Gas Combustion Yes= 18WE1091 1 Ye - Permit)niaiel _ issuance Section 03 - Description of Project ExtractionOil & Gas, Inc- (Extraction) submitted an application requesting permit coverage for several newsources at an existing synthetic minor oil and gas well production facility located in the ozone non-attainwentarea. With this application, the operatoris requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbonloadaut,VRT -` venting, separator venting and natural gas fired RICE. TI e -RICE are obtaining permit coverage . under the GPb2. This preliminary analysis only addresses the low pressure separator venting source..:_ The low pressure separamr venting source is APEN required because uncontrolled requested VOC emissions are greater than Ito/ (Colorado AQCC Regulation 3, Part A, Section ll,8.3;a- Additionally, the source is permit required because uncontrolled VOCemissions from all APEN required sources at the-facilityare greater than 2 tpy (Colorado AQCC Regulation 3, Part B, Public comment is required for this source because new synthetic rninarlimits are being established in order to avoid otherrequirernents. Additionally, the change in VOC and hlOx emissions as a result ofthe project are greater than 25 tpy, and the change in CO emissions as a result of the project are greater than 50 tpy. - - Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic -Minor Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Iko 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 (Poo) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants hero SO2 NOx Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs J CO VOc PM2.5 O CI PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory 014 Separator Venting IFacility AIRs ID: County Section 02 -Equipment Description Details Detailed Emissions Unit Description: [ow pressure ra.� Enclosed Cmnhusbon Device(Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency % Limited Process Parameter Gas meter Section 03- Processing Rate Infomration for Emissions Estimates 9CEH ,& , a 'fa3.. € Plant Point Primary Emissions - Separator Actual Throughput = F,9"'MMscf per year Requested Permit Limit Throughput 2130;:'. MMscf per year Requested Monthly Throughput= 2 MMscf per month Potential to Emit (PTE) Throughput = Zl MMscf per year Process Control (Recycling) Equipped with a 490: Is VRU process equipment 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 �'avanhFtigtaa` enty.i location Agussai:il e PI lysfsln coniiii Ih/Ib-moI Displacement Equation Ex=Q"MW"Xx/C iMW H - drogen Sulfide Oxygen/Argon CO2 N2 methane ethane isabutane n -butane Is..0 ntane n-• - mane c do.entane n -Hexane c dishexone Other hexanes he -nes meth Icyclohexane 224-TMP Beraene Toluene Ethelbenzene X lanes C8+31eavles Uncontrolled Weight % ,.: 2.10 1.24 0.54 000 11.05 0;26 0.04. 0.22 239 .00 5_.5655 Btu/scf scf/hbl Pollutant Controlled (Ib/MMsof) (Ib/MMscf) Emission Factor Source MTiMMIMMIIMMEIMSEIMi h® 203.7030 Pollutant Primary Control Device Uncontrolled (Ib/MMBtu( (Waste Haat Combusted) Uncontrolled lb/MMscf Moon (Gas Throughput) a Emission Factor Source low pressure gecis r10 e4ei Heat Value Calculation Component OHS (Btu/se.) HHV (HIu scf) Wale: 0 0 0 CO2 U 18081 ° 0 112 0 0.2250. 0 methane 909.4 34.494 10110 ethane 1.615.7 23.7154 :'' 1769.7 propane 2314.9 22.425 2516.2 5obutane 000'0.4 2.5887 : 3252 c-butoue 3010.0 7.8100 >:: 3262.4 iseoentane 3699 ---1.543. 4000.9 n -pentane - 3706.9 19642 4005.7 Cyol05entane 3512 `-. 0.1597'" 3763.6 Cttlotleoene 4179.7 '0.1512'....: 4461.6 Hexanes fneatarg value of n -Hexane) 4401.E '='108589 r:':.:: 4756 heptanes 5100 04376:. 5502.5 MethylCy—olehexene 4963.7 0.1922 5215.9 001-806%, 5796 0.3184 '.' 6248.9 Plor.3rtes 6u-'--.- 0.0685 . 6996.4 • Decane + _ - 0 2652 ::: 7743 Benzene _ :...: 0 0922.-. 3741.9 Toluene 42/3.7 C.0993 4474.9 Ehylberzene 497-0.4 0.0146 5222 Xylem., (AV,' 070, in, p rylane) _ 4957.1 00726 5205.7 0 -Hexane •400.0 0.0424 4756 224-TSSH (1.9016136 of in^.cta00) 5770.0 0.0003 5230.6 , H2S 586.d•- 0; ,,. 637.1 99.9548 Lower Heating Value of Gas Higher Heating Value of Gas 1021.052347 am/scf 1966.5061 Btu/act 2 of K:\PA\2018\18WE1091.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 _ Sax 500 VOC CO 0.157 0.058 0.058 0.157 0.157 27 0.157 0.058 - 0.058 0.157 0.157 27 0.012 0.005 0.005 0.012 0.012 2 143 0.53 0.53 1.43 L43 244 600.33 222.44 11.12 600.33 30.02 5099 6.54 2.42 2.42 6.54 6.54 1111 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) fibs/year) Requested Permit Limits Uncontrolled Controlled fibs/year) fibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 3556.18 1317.65 65.88 3556.18 177.81 5089.09 '- 1885.63 94.28 5089.09 254.45 856.06 317.19 15.86 856.06 42.80 4277.76 1585.01 79.25 4277.76 213.89 25880.61 9589.38 479.47 25880.61 1294.03 21.66 8.03 0.40 21.66 1.08 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.8, Regulation 7, Section XVII.B.2.e (See regulatory eppllcabillty worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Camplianca Source requires a permit Source is subject to Regulation 7, Section XVII.5.2, G . The control device for this separator is not subject to Regulation 7, Section 0911.B.2.0 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 10, and should have been collected within one year of the application received date. However, lithe facility has not been modified (e.g., no new wells brought on-Ilne(, 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 theemission factors are less than or equal to the emissions factors established with this application. Am 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. WEl 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/bbi) value In section 03. Does the company requests control device efficiency greater than 95% fora 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. 3 of 5 K:\PA\2018\18WE1091.CP1 Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes L Bated on th applicators, a Haan[ fenilily that'ere used to comprencio' Meter m eatipn, the eperatorwilt not Peed -rot treok VHtl dayert m811tt 2: Theepplfiatlon lhdicatesthe flow meters are ihstalled=axe operation[ atiiil 3. Neither Initial nor periodic method- 22 opacity tests were included in the permit because the operator Is required to do dailyvisinieemissions checks per the operating' 5{ either shut in the equi prnenttmrnediately andconduct repairs or conduct a formal method 22'opacity testy In the event visible emissions are absented through the method 22 the pester is:r gwred dd tmmediatelyceedoce epairdd repairs cannot bnducted immedately. Since this is a more robuson-going compliance demonstration than a onetime method22, this inideI compliance demonstrationrsnot necessary In the permit Additionally, the daily vis'hlae requirements if visible emssons are observed is a sufficient n going compliance demonstration, so periodic method 22 opacity tesingis not required in the permit. -- - --- 4-:The heatcontent used to calculate Nba and CO emissions was obteinedffom the gas sample provided in thapplication. 5. Based on- the -AFEN provided for the condensate storage Vassals, twenty-three wells produce to this facilty.Fve of the existing wells that produce to thafeolity were fractured and began production in November 203. The la, feting was freot,u January 2017 and began production n: February 2017. Seventeen new wells were drilled. and. brought online in 2012,:. Based on COG. CG data, these new wells were fractured between March and May 2013 and began production in July 2038. Since new well added to and completed at the facility after OS/01/2014, the gas coming off the separation equipment is subject to Regulation 7, Section XVIfG Conditions .referencing these requirementswillbe included in the permit, 6. In the analyse, the standard equation to calculate emission factors a as fol lows. Emission factor (pollutant x) A (Weight% (poll utant x))/(100)`(35.2239 lb/lb-molt/079 evfjlbmol)*(1,000'000 scl7MMscft_Being this equation, the following entire on factors were ..._ calculated: (1)VCG'57,?18.481b/MMgcP, (Ill Benzene _69.`..21hZM Ms<t, (Ili) Toluene =242571bjMMsd, [iv) tJiylbenzehe=40B bjMMscF,(y)XYJepe=203.931h(MMsef,(vil n-HMayne=},233:7AI6JM Nisef, and (vii)27MliMP=1.4'76/MMsef. These emission factorsdo not match exactly -to the gables provided by Inc our ton However, the difference between the values ca I culated using tt este ride rd equation and the values calculated by the operator are negligible_ 4s e result, the operator calculated values were used.. for permittingpurposes. The differences the tionoa2 due. To the operator using different molecufarweights to convertfrom mole %to weight% and the use of a molar volume of 379.3 sof/Ib-mot rather than 979scf/Ib-mot In orde r to makathe!slues t h th mnolar volume of an ideUgas was adjusted vibe- elaYlora cell 875-876 t rwa ftpconit rid gy 10 review prior to public comment The operator reviewed bottsdocumentsand ex AIRS Paint 0 Process # SCC Code 014 01 3-10-001-60 Flares Section 09 - Inventory SCC Coding and Emissions Fetters Pollutant Uncontrolled Emissions Factor PM10 14.97 PM2.5 14.97 506 110 NOx 136.59 VOC 57174.31 CO 622.70 Benzene 169.34 Toluene 242.34 Ethylbenzene 40.76 Xylene 203.70 n -Hexane 1232,41 224 TMP 1.03 Control % Units O 6/MMSCF O 6/MMSCF O h/MMSCF O 6/MMSCF 95 b/MMSCF O h/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 4055 K:\PA\2016\16WE1091.CP1 Separator Ventlog Regulatory Analysis Worksheet yS.urw Y I n. o Non -Attainment PENN .nA arm; Pwmnm.nb dPo ATTAINMENT y Are unconnAtied actual nn tore tislnalwtival nouns greeter than 2 TPY(Pegulanon3,Pan 2. Are total hdll, ummntmlltllWe a t missbe greater...than p I, NOT greater n lO TRY or COeurer then la TAT (Regulation 3 on 3. Parts, 5.Nonlln3)i IrTer nneralairounurreen iIONATTAINMANN from arty ul[ede pcgutants frau tilts individual source greeter than 1 TAT (Pagulatlen3, Part A, ...AD..), 2. Are tool facilityonmnedled VOX emissions from the greater than 2PPY, NOT Neatertlsn STPYorm embalms greater non IOTA!(reptlauen3, Part IT,Secdunll.p.l), bum. nrquirn a pun. ion le PetulrtbnJ.Seebe %RR 1 Wes well neMycondaueaf. hydraJWlltiFacnvai, or remmpittei on or aherAugmt 1,2a1<, 1Sauro is TANN. Regulation I, Seelpn%V14g.ZG Ss.° %VIERZ-Genenl PmeIsNnufw Air...In Cmod EpuIpment and Pmmtim dEmissloa s.ebn%IRG Emlmenscmba Alterneiva Emissions canoed lOmbnol Sevin( a. Isthiaepemmr controlled by a bacFw or altermre combustion dew®Ae,mtme prima, rove device)Matis net enclosed, MTh. ns Reg.i. n,,Ead,a,.NTS2o Section % ERL.-Altemen a emisdom nano. equipment to MEd:dmer The...ream assistscpeato's with determining applicablliry of certain re...ow °'Medusa AlrAcf, Rs anakm gregulations, and Air Cha'i(y Control Commisslm regulations. Tills decumere;seat aare e,dNeiatim, ere thaeg000sncmtues may net apply. a210Inie siwa5m based upon am in.,. al reds anddmansba%as Res eccune[tleeseeUlayao siestioon Tor claw, regulation, wary aFerbgelly Unsling mo spmon'And is mflegaib a9meeule In the event ceany correctefween the language o'Wseccament and the lagu age o ',wager, NrAot„ Its lmplemaiarg regulations. anc AiSOSet Cont. Commission regulations, the languager&Ma smart or regulationuers ye The use ormTaadno ay bo,A,A vnh as'raanme loetntY..shauOfthe Green is WaNdto describe APCD ins eprelasf regulations, are recamm ,dalbns. nonc.ry terminology such as 'must. and'eroeere SO Inlercmn')etr cebecommlllrg reluremeRs Msbr the terms or Ma Cleen Ale MI and Air Ouslny are. Canmeslon regulations, ball. document etas n2testablish legally Uv%Lg raturemarls i, are ',ea tl- Source .• Source Pgepdru ePAPEN. Gorr the next merlon COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE 1091 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Extraction Oil Et Gas, Inc Milkshake 31-W Production Facility 123/9CEB NWSW SEC 32 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Description Emissions Control Low pressure gas is routed to and LP Gas Low pressure natural gas venting from " controlled by an Combustion ' O14 twenty-three (23) tow pressure separators. enclosed combustion device (ECD) during vapor recovery unit (VRU) downtime. 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, k 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/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control COLORADO Air Pollution Control Division erar!mnnt o1 Public Hea;h c Entirormt nl. Page 1 of 9 Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/ pacific/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 NO, VOC CO LP Gas Combustion 014 --- 1.5 30.1 6.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit COLORADO Air Pollution Control Division Page 2 of 9 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LP Gas Combustion 014 Emissions from the low pressure separators are routed to an enclosed combustion device (ECD) during vapor recovery (VRU) downtime. 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, Section II.A.4.) ) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LP Gas Combustion 014 Natural Gas Venting 21.0 MMSCF The owner or operator shalt 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. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the low pressure separators and routed to the enclosed combustion device using a continuous operational 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 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply COLORADO Air Pollution Control Division ti b Envimnrte a Page 3 of 9 with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. 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 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) 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, Section 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 COLORADO Air Pollution Control Division €`wartment 2i Ptit r. Ht,afth En,•&-onment. Page 4 of 9 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. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the ; capacity of the source or modification to otherwiseemit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). 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 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. COLORADO Air Pollution Control Division De:par:men: of AiNtc Heaths b Em.lronment. Page 5 of 9 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: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. Permit for natural gas venting from twenty- three (23) low pressure separators at a synthetic minor oil and gas well production facility. COLORADO Air Pollution Control Division ^enar vine 9171,,N1r. Hea72n o En9r9r, nert:Y Page 6 of 9 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) LP Gas Combustion 014 Benzene 71432 3,557 178 Toluene 108883 5,089 255 Ethylbenzene 100414 856 43 Xylenes 1330207 4,278 214 n -Hexane 110543 25,881 1,294 2,2,4- Trimethylpentane 540841 22 1 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 014: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 136.59 136.59 AP -42 Chapter 13.5 COLORADO 3 Air Pollution Control Division Dtpa}tment of Public Health b ErAimnmmnt. Page 7 of 9 CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source CO 622.7 622.7 AP -42 Chapter 13.5 VOC 57,174.31 2,858.72 Gas Analysis 71432 Benzene 169.34 8.47 Gas Analysis 108883 Toluene 242.34 12.12 Gas Analysis 100414 Ethylbenzene 40.76 2.04 Gas Analysis 1330207 Xylenes 203.7 10.19 Gas Analysis 110543 n -Hexane 1,232.41 61.12 Gas Analysis Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The V0C and HAP emission factors listed above are based on a site specific low pressure separator gas sample obtained on 09/18/2018. The sample temperature and pressure are 117°F and 50 psig respectively. The V0C and HAP emission factors were determined using the weight % values and gas molecular weight (35.2239 lb/lb-mol) from the gas sample analysis in conjunction with the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4- 3). The AP -42 Chapter 13.5 N0x and CO emission factor (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) were converted to units of lb/MMscf using a heat content of 2,008.7056 Btu/scf. 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 Operating Permit NANSR Synthetic Minor Source of: VOC, CO, n -Hexane, Formaldehyde and Total HAPs Synthetic Minor Source of: VOC PSD True Minor 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 COLORADO Air Pollution Control Division S'ep,artmertt Nen≥th v iewir rmen . Page 8 of 9 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 COLORADO Pollution Control Division i?t=t�iEc sfealt! Ert;4r.rmert. Page 9 of 9 Milkshake 31-W Condensate Tank APEN 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 tahks 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: l FL/VC/087 AIRS ID Number: 123 / 9CEBOI D [Leave blank unless APCD has already assigned a permit # and AIRS ID} Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Milkshake 31-W Production Facility Site Location: NWSW Sec 32 T6N R67W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@extractionog.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 38884C Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1 catoa..au Milkshake 31-W Condensate Tank APEN Permit Number: Atke t0Y - AIRS ID Number: 123 / 9CEB/ pl p [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 ❑ 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 ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Please issue individual permit for Condensate Tanks. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Storage of Condensate at E&P Facility. Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 07/16/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration Et Production (E&P) site ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 19 Yes ■ No Are Flash Emissions anticipated from these storage tanks? • Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? I51 Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0,ca0LS m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)GI 805 series rules? If so, submit Form APCD-105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 2 tOLoaAua Milkshake 31-W Condensate Tank APEN 0 Upward ❑ Horizontal Permit Number: 1 1Oc1- AIRS ID Number: 123 / 9CEB t loft [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information 1110411, re eque Condensate Throughp 2,876,036.60 3,451,243.92 From what year is the actual annual amount? Average API gravity of sales oil: Projected 44.59 degrees ❑ Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 10.57 ❑ External floating roof ara - i ltrs F � illamfldoae� i a ra8e a -, .._.. � © ,rte � u of ra 71'!� ' installation Da#e a — Recent Story �� tora¢e Tan :,9 fi%ear Date of Fit -s, Production N/A 8 x 400 bbls 3200 7/2018 7/2018 _- g eoe • B e on - - See Attached ■ - - ■ - - ■ ■ - ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The ER.P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information 40.44058, -104.925725 k 9. 'Cry 1, fa .� zf. Ilea? e e7� ,_, 3i � v4=.. ,e .mev '.i? � Y `h r£ � N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑ Downward LI Other (describe): Indicate the stack opening and size: (check one) O Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Unknown Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 Permit Number: Milkshake 31-W Condensate Tank APEN `StAD ei low} AIRS ID Number: 123 i9CEBi O\O [Leave blank unless APCD has already assigned a permit it 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 95% % 98% % Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: �Z�ls3 Btu/scf MMBtu/hr hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP separator, Vapor Recovery Tower Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 I toLoR.;aa Milkshake 31-W Condensate Tank APEN Permit Number: AIRS ID Number: 123 / 9CEB / I ol0 [Leave blank unless APCD has already assigned a permit 11 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): escTn 6 e C nt ® f e ,' �,. , ,. _ ,. _ , a __ OveralLRequested Control a$ , fficiency� . Tee action in emissions VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected 0.1238 • lb/bbl 178.013 8.901 213.615 . 10.681 • VOC oll'.il: EtriS.. Site Specific Sampling NOx CO 0.31 • Ib/MMBtu AP -42 Chapter 13,5 1.561 • 1.561 . 1.873 . 1.873 • 0.000227. lb/bbl 651.659 ' 32.583 • Benzene 71432 x AP Site Specific Sampling Toluene 108883 0.000193 • lb/bbl Site Specific Sampling 554.181 • 27.709 • Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.00181 • lb/bbl Site. Specific Sampling 5,214.040 260.702 • 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. {a-teRA.at? Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 I Milkshake 31-W Condensate Tank APEN Permit Number: G lOc)7` AIRS ID Number: 123 / 9CEB / c'71 O [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. Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance J Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 61 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Extraction Oil & Gas, Inc. Source Name: Milkshake 31-W Condensate Tanks Emissions Source AIRS ID': 123 I 9CEB / 010 <72 C51 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123- 37703 PAVISTMA SOUTH 01 ❑ 05- 123- 36652 PAVISTMA SOUTH 02 ❑ 05- 123 - 36650 PAVISTMA SOUTH 03 ❑ 05- 123 - 34945 PAVISTMA SOUTH 04 ❑ 05- 123 - 34959 PAVISTMA SOUTH 05 ❑ 05- 123 - 43250 MILKSHAKE 23C ❑ 05- 123 - 46054 MILKSHAKE 31W -20-01N /1 05- 123 - ,-(cobSS MILKSHAKE 31W -20-02N ►1 05- 123 - 45820 MILKSHAKE 31W -20-03N /1 05- 123 - 45817 MILKSHAKE 31W -20-04C /1 05- 123 - 45828 MILKSHAKE 31W -20-05N ►1 05- 123 - 45827 MILKSHAKE 31W -20-06N /1 05- 123 - 45822 MILKSHAKE 31W -20-07N ►1 05- 123 - 45816 MILKSHAKE 31W -20-08C /1 05- 123 - 45819 MILKSHAKE 31W -20-09N -.- 05- 123 - 45823 MILKSHAKE 31W -20-10N /1 05- 123 - 45825 MILKSHAKE 31W -20-11N ►1 05- 123 - 45821 MILKSHAKE 31W -20-12C /1 05- 123 - 45826 MILKSHAKE 31W -20-13N ►1 05- 123 - 45824 MILKSHAKE 31W -20-14N L 05- 123 - 45818 MILKSHAKE 31W -20-15N ►1 05- 123 - 46053 MILKSHAKE 31W -20-16N ►/ 05- 123 - 46056 MILKSHAKE 31W -20-17N ►1 Footnotes: ' Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 0 4 Condensate Tank Addendum Milkshake 31-W Produced Water Tank APEN 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.goy/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: fg J&foss AIRS ID Number: 123 / 9CEB f' bI f [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Extraction Oil & Gas, Inc. Site Name: Milkshake 31-W Production Facility Site Location: NWSW Sec 32 T6N R67W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@extractionog.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 38880'' - cotaRAoa o..r.er.e...r Milkshake 31-W Produced Water Tank APEN Permit Number: lsZtat✓ 10 �g AIRS ID Number: 123 / 9CEB / (O1 1 [Leave blank unless APCD has already assigned a permit # and AIRS,ID] Section 2 - Requested Action ▪ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: Please Issue individual permit for produced water tanks. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Storage of Produced Water at E&P Facility. Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 7/16/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year El Exploration & Production (E&P) site ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ./ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes ❑ No / Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 2 I IkpoWTolotrdile Milkshake 31-W Produced Water Tank APEN Permit Number: AIRS ID Number: 123 / 9CEB / ( O I l [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information cctua iiaa uce 742,141 890,569 From what year is the actual annual amount? Tank design: 0 Fixed roof Projected ❑ Internal floating roof ❑ External floating roof N l k 1)G ui® a s g' a�i� fl e s�� .� insYadlat�oafe .: �s @ateEo�r eeent Story tn'� o - u o N/A 2 x 400 bbls 800 7/2018 7/2018 See Attached 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information 40.44058, -104.925725 N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) Upward Horizontal ❑ Downward 0 Other (describe): ❑ Upward with obstructing raincap F Indicate the stack opening and size: (check one) ElCircular Interior stack diameter (inches): Unknown Square/rectangle Interior stack width (inches): Interior stack depth (inches): 0 Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3 thalstm tAbt7i Milkshake 31-W Produced Water Tank APEN Permit Number: AIRS ID Number: 123 / 9CEB / Olt [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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ✓❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr h r Type: ECD Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 95% 98% % % Waste Gas Heat Content: Constant Pilot Light: ❑/ Yes ❑ No Pilot Burner Rating: IVSS Btu/scf MMBtu/hr 3- &r- ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP separator COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4 Milkshake 31-W Produced Water Tank APEN Permit Number: c?,,LL 1Dg� AIRS ID Number: 1 23 / 9CEB / OI [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 form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): �� a1# '�T �h\�� escti to o owl e od{s) ,__r_ -„„ nese '`- t'a1.R&ontro ,e, �- , * ue ranal&er ss1nns VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected 1 e- lb.w -6-833 0.S i 19.003 1%5 •4-ee6 o. vOC 0.04 52 lb/bbl Site Specific Sampling NOx CO ca� �? c i \ ` cootrolce= a ma y` . _ c.,�.@` e _... Benzene 71432 0.002081 ` lb/bbl SiteSpecificSampling 1,544.462• 77.223 • Toluene 108883 0.001426 ' lb/bbl Site SpeclficSampling 1,058.255 • 52.913 • Ethylbenzene 100414 Xylene 1330207 0.000439 ' Ib/bbl Site Specific Sampling 325.606 • 16.280 • n -Hexane 110543 0.001537 - lb/bbl Site Specific Sampling 1,140.408' 57.020 • 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. ' j,,v,,c5 Y` ockc . cw�Q I F11.S oloco/ 'GI Form APCD-207 - Produced Water Storage Tank(s) APEN -Revision 7/2018 5 I Milkshake 31-W Produced Water Tank APEN Permit Number: AIRS ID Number: 123 / 9CEB / Qi [Leave blank unless APCD has already assigned a permit 11 and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) 10 (11 ITO \S Date Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance Q✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 6 I cat0RAod Liparlormt 'Mae �.----- E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil & Gas, Inc. Source Name: Milkshake 31-W Produced Water Tanks Emissions Source AIRS ID2: 123 / 9CEB / a( et Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123- 37703 PAVISTMA SOUTH 01 ❑ 05- 123- 36652 PAVISTMA SOUTH 02 ❑ 05- 123 - 36650 PAVISTMA SOUTH 03 ❑ 05-123 - 34945 PAVISTMA SOUTH 04 ❑ 05- 123 - 34959 PAVISTMA SOUTH 05 ❑ 05- 123 - 43250 MILKSHAKE 23C ❑ 05- 123 - 46054 MILKSHAKE 31W -20-01N a 05- 123 - ,t- osS MILKSHAKE 31W -20-02N 1/ 05- 123 - 45820 MILKSHAKE 31W -20-03N /1 05- 123 - 45817 MILKSHAKE 31W -20-04C LI 05- 123 - 45828 MILKSHAKE 31W -20-05N r 05- 123 - 45827 MILKSHAKE 31W -20-06N // 05- 123 - 45822 MILKSHAKE 31W -20-07N LI 05- 123 - 45816 MILKSHAKE 31W -20-08C /1 05- 123 - 45819 MILKSHAKE 31W -20-09N 1 05- 123 - 45823 MILKSHAKE 31W -20-10N a 05- 123 - 45825 MILKSHAKE 31W -20-11N ►1 05- 123 - 45821 MILKSHAKE 31W -20-12C /1 05- 123 - 45826 MILKSHAKE 31W -20-13N L1 05- 123 - 45824 MILKSHAKE 31W -20-14N a 05- 123 - 45818 MILKSHAKE 31W -20-15N // 05- 123 - 46053 MILKSHAKE 31W -20-16N iI 05- 123 - 46056 MILKSHAKE 31W -20-17N /1 Footnotes: ' Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 Water Tank Addendum Milkshake 31-W Liquid Loading APEN ti Hydrocarbon Liquid Loading AP; 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: I SAVE/0g9 AIRS ID Number: 123 / 9CEB / O/Z [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Extraction Oil & Gas, Inc. Site Name: Milkshake 31-W Production Facility Site Location: NWSW Sec 32 T6N R67W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: 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. 388848 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 cc4.0ItA o pdArntr.rr Milkshake 31-W Liquid Loading APEN Permit Number: I44c9t:. t OS, AIRS ID Number: 123 / 9CEB / 0) 7_ [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 2 - Requested Action 0 NEW permit OR newly -reported emission source Request coverage under construction permit 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 ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' 0 Other (describe below) - OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info E Notes: Please issue permit for hydrocarbon liquid loading. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Loading of condensate liquid onto tanker trucks for transport. Liquid is routed to pipeline during normal operation, permit serves as backup in case truck loading is necessary. Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 7/16/2018 Will this equipment be operated in any NAAQS nonattainment area? O Yes • No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No • O Is this source located at an oil and gas exploration and production site? Yes No NI ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • p Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ p Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2 I AIN Dtrwh c T eve. Milkshake 31-W Liquid Loading APEN Permit Number: \%Log"1o' 1 AIRS ID Number: 123 / 9CEB / UI z [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 160,207 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: Tank Trucks 133,506 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: N/A Average temperature of bulk liquid loading: N/A °F True Vapor Pressure: N/A Psia ® 60 °F Molecular weight of displaced vapors: N/A lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year Product Density: N/A lb/ft3 Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I GLORA°Oi D•pdriTart, tinkle Milkshake 31-W Liquid Loading APEN Permit Number: tc t& E tO\ [Leave biank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 123 / 9CEB / oi7 Section 5 - Stack Information 40.44058, -104.925725 ' a -- a s a , - - e N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ✓❑ Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 0 Other (describe): 0 Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOC, HAPs Rating: Type: ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% % Minimum Temperature: `F Waste Gas Heat Content: 7 oko-N, Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: MMBtu/hr 0 Other: Pollutants Controlled: Description: Requested Control Efficiency: 0 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 CQLOitADel Milkshake 31-W Liquid Loading APEN Permit Number: t +v O9p, AIRS ID Number: 123 I 9CEB / CO2_. [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 rot efficiency (% reduction): De g y o ci t0 e�BL� ,, 4 71 �� I�CIL� _ 4S__ U %® e _OP G . PM SOx NOx CO VOC ECD 95% HAPs ECD 95% Other: ❑✓ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑✓ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected PM SOx NOx CO VOC 0.236 lb/bbl PS Memo 14-02 15.754 0.788 18.904 . 0.945 ' Benzene 71432 Toluene 108883 Ethylbenzene Xylene n -Hexane 100414 1330207 110543 0.0036 lb/bbl PS Memo 14-02 480.622 24.031 . 2,2,4- Trimethylpentane Other: 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCO-208 - Hydrocarbon Liquid Loading APEN f - Revision 7/2018 5 I e.oit A.i?d Irirmsmaaaaci Milkshake 31-W Liquid Loading APEN Permit Number: to, \ AIRS ID Number: 123 / 9CEB / O12_ [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. (i):12\9 �rn bl?41113 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: Ei Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 or visit the APCD website at: https: / /www.colorado. gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6I 'COLORADO Milkshake 31-W VRT Gas Venting APEC4tI4 Gas Venting APEN - Form APCD-211\2_ 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: l gwE/P90 AIRS ID Number: 123 / 9CEB / D/3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: Extraction Oil & Gas, Inc. Milkshake 31-W Production Facility NWSW Sec 32 T6N R67W (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: cnelson@extractionog.com Catie Nelson 720-354-4579 I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388849 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 C4181tA0& Milkshake 31-W VRT Gas Venting APEN Permit Number: lc1uDE t O p AIRS ID Number: 123 I9CEB/ csi3 [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: Please issue individual permit for VRT Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of VRT Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 7/16/2018 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year Yes Yes Yes Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I No No No C*tORAD01 Milkshake 31-W VI3T Gas Venting APEN Permit Number: 1ct-bG t O1O AIRS ID Number: 123 / 9CEB / Or [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: 2759.589 BTU/SCF Requested: 6.000 - MMSCF/year Actual: 1.237 - MMSCF/year -OR- Requested: N/A bbl/year Actual: N/A bbl/year Molecular Weight: 48.090 VOC (Weight %) 86.995. Benzene (Weight %) 0.1669 - Toluene (Weight %) 0.0737' Ethylbenzene (Weight %) 0.0036 • Xylene (Weight %) 0.0141. n -Hexane (Weight %) 1.6291- 2,2,4-Trimethylpentane (Weight %) 0.0001- Additional Required Information: •..%" t4OS o i0 jt9 ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 Qi4RADd ftwAr J enwc Milkshake 31-W VRT Gas Venting APEN Permit Number: vcrSt-c6 icon AIRS ID Number: 123 / 9CEB /10) [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information 3eogr•aphica1 Coo_rdi (LatitudelLongitude or 40.44058, -104.925725 S e . Q.o. �- c N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) �✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature: Waste Gas Heat Content: t 5°l .b Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: ;C6t6kAU[ri Form APCD-211 - Gas Venting APEN - Revision 7/2018 4 I Milkshake 31-W VRT Gas Venting APEN Permit Number: lerwpEtcRO AIRS ID Number: 123 / 9CEB I dl3 [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): lib d m- �� , esc Xo -of b try t o s 76—!--i- ll RteRueste 3Cant Q #CIe PM SOX NOx CO VOC ECD 95% HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected PM > 0.529 • 0.529 • 2.566 • 2.566 ' SOX NOx CO 0.310 • Ib/MMBtu AP -42 Chapter 13.5 VOC 110,298.417 . Ib/MMscf Site Specific Sampling 68.220 ' 3.411 ' 330.895 • 16.545 - 211.586 - Ib/MMscf 261.732' 13.087 • CO ttT e Benzene 71432 Site Specific Sampling Toluene 108883 93.428 • Ib/MMscf Site Specific Sampling 115.570 • 5.779 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,065.455 - Ib/MMscf Site Specific Sampling 2,554.967 . 127.748 • 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 `Denting APEN - Revision 7/2018 51 Milkshake 31-W VRT Gas Venting APEN Permit Number: tQLOE tOcIO AIRS ID Number: 1 23 / 9CEB / O/ [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. 14(11 joi Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ID Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website a1, https: / /www.colorado.Rov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6I ca�oa�na MO.ArkiehMie Milkshake 31-W LP Gas Venting APEN Gas Venting APEN - Form APCD-21I 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: 1 g 1A1 E1091 [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 123 /9CEB/ ©/Lf Section 1 - Administrative Information Company Name1: Site Name: Site Location: Mailing Address: Extraction Oil & Gas, Inc. Milkshake 31-W Production Facility NWSW Sec 32 T6N R67W (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388850 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I cataexoa IkpmftritorIVISe Milkshake 31-W LP Gas Venting APEN Permit Number: llu3tkoct` AIRS ID Number: 123 /9CEB/ [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 - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Please issue individual permit for LP Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of LP Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 7/16/2018 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year Q Yes ❑ Yes Q Yes ❑ No • No ❑ No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I COLORADO Milkshake 31-W LP Gas Venting APEN Permit Number: VILt5E10ck‘ AIRS ID Number: 123 / 9CEB / D)� [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Process Equipment Information ❑ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # 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 Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 2008.706 BTU/SCF Requested: 21.000 MMSCF/year Actual: 7,781 MMSCF/year -OR- Requested: N/A bbl/year Actual: NhA bbl/year Molecular Weight: 35.224 ' VOC (Weight %) 61.566 - Benzene (Weight %) 0.1824' Toluene (Weight %) 0.2610 • Ethylbenzene (Weight %) 0.0439 • Xylene (Weight %) 0.2194 . n -Hexane (Weight %) 1.3271 ' 2,2,4-Trimethylpentane (Weight %) 0 803 0.ckk 9a5 Sa►k . Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Ft n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I COLORADO Milkshake 31-W LP Gas Venting APEN Permit Number: V2-( E\Oct\ AIRS ID Number: 123 / 9CEB / 01,_k [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 5 - Stack Information Leo i�ca cc LongJtth mate e or UTls 40.44058, -104.925725 may N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑✓ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature: Waste Gas Heat Content: ,L®CF?2.1 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 41 Milkshake 31-W LP Gas Venting APEN Permit Number: l,?,2E tO`\ ` AIRS ID Number: 123 / 9CEB / Olc{ [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): , Pa1l yes a etio Ito = e Ovall2.e nested onaroi Ef iciency PM Sox NO. CO VOC ECD 95% HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected a IS 0 PM 551 . ton • SOx -.NOX 0.068 • lb/MMBtu AP -42 Chapter 13.5 0.531, 0.531 1.434- 1.434 • CO 0.310 • Ib/MMBtu AP -42 Chapter 13.5 2.423 - 2.423 • 6.538 - 6.538 - VOC 57,174.313 lb/MMscf Site Specific Sampling 222.429 • 11.121' 600.330 - 30.017 • 169.340 • lb/MMscf 1,317.592 ' 65.880 . Benzene 71432 Site Specific Sampling Toluene 108883 242.338 • lb/MMscf Site Specific Sampling 1,885.565 94.278. Ethylbenzene 100414 40.765 • lb/MMscf Site Specific Sampling 317.181. 15.859' Xylene 1330207 203.703 lb/MMscf Site Specific Sampling 1,584.958 • 79.248- n -Hexane 110543 1,232.410 - lb/MMscf Site Specific Sampling 9,589.063. 479.453 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit [imitations. 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 Si i- t Milkshake 31-W LP Gas Venting APEN Permit Number: `,LOe l ` AIRS ID Number: 123 / 9CEB [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. 1a r\ 20It Si ure-of Legal y Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance ❑� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 61 COLORADO Hello