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Home My WebLink About20191292.tiff1P- ub\i c Pieii►e i4/8/t4 COLORADO 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 0 St PO Box 758 Greeley, CO 80632 March 27, 2019 Dear Sir or Madam: RECEIVED APR 01 2019 WELD COUNTY COMMISSIONERS On April 4, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - C Street Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CC: Pt_ C TP), ktcrT), pwc-xm/eR/cICR) 14/1114,1 2019-1292 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - C Street Production Facility - Weld County Notice Period Begins: April 4, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Extraction Oil Et Gas, Inc. Facility: C Street Production Facility Well Production Facility SWSE of Section 36, Township 6N, Range 66W 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, condensate loadout, natural gas venting from two (2) vapor recovery towers (VRT) and natural gas venting from twenty (20) low pressure separators at a synthetic minor oil and gas well production facility located in the ozone non -attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): the 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 15WE0812, 18WE1143, 18WE1144, 18WE1145 Et 18WE1146 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- pu blic- 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 1 i , Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: SWSE quadrant of Section 36, Township 6N, Range 66W County: Weld County Type of Facility: What industry segment?; Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Quadrant Particulate Matter (PM) E Ozone (NOx & VOC) Section Township Range E,. AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit a issuance # Self Required? Cart Action Engineering Remarks y�( d"1»o��ng � GI €rod jaas�� ' q g , ��h �5t3U��8'��'` � "' n�',A3jj a3 3fi ,3 3 ��ul` f3 ` �` �' a od�i�'if� E� 333 3. )) ;6 /,'!5///�iL. „ ,,., ;;; .,., :.,: 3.1� ui,�i'fA v#'a r .., G Section 03 - Description of Project Extraction Oil fcuSSas Inc; (Extraction); submitted an application requesting permitcovrerage'forseveral sources at an existing synthetic eninoroilandgas`wellproduction facilityiocated inth ozone non -attainment area. With this application; the operator is requesting permit coverag€-farcornden_sate storage vessels„ produced water storage vessels, hydrocarbon-loadout VRT` venting, end separator venting. This preliminary analysis only addresses the hydrocarbon ut loadosource- - - - With this application the operator la requesting to decrease the permitted throughrpt for the-loacleutsource from 675000 barrels/year to 126(260 barrels/yeah Willie More wells w drilled atthis facility, the liquid from the storage tanks is;routed to a' pipeline d"of7lg"normal operation. This" permit.serees to covertrucil".l'oading operratiensduring times when the pipel"ii unavailable. Additionally, the operator is requesting to'estimatteemissions usingthwstate: denaulternisstonfactors'forconthnsateloadoutThestateemissionfactorsareMareconserya than the previously calculated emission factors using Ap-Q2 Cl peter 5. Self=certification was submitted forthe first issuance",of this peifeit on 02/05/2016. This-self-certifiication was approved and a final approval lettei'was issued, en. 08/O1/2O16. The modifications requested in this permit service do not warm nt sending the permit hook through the self -certification process. As a result, the permit will iberssued as final approva Public commentisrequired for this source because new synthetic minor limit"s are being established atthefacilityin orderta avoid other requirements. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? ecrgSjrakhe: i, Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? Nat 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 Eery NOx Is this stationary source a major source? �' l If yes, explain what programs and which pollutants here SO2 NOOn Prevention of Significant Deterioration (P5D) _ { Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) - CO VOC Co J Voc PM2.5 PM10 TSP HAPs R -❑ PM2.5 PM10 TSP HAPs ❑ ❑ Hydrocarbon Loadout Emissions Inventory 002 Liquid Loading 'Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit lumina ,ofcom)ensa Description: :"'- """"" " " Emission Control Device ;,,,,lased €rhnbesdo00 Description "; .,., Is this loadout controlled? Collection Efficiency: Control Efficiency: Requested Overall VOC & HAP Control Efficiency %: 95.00 Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput = Potential to Emit (PTE) Volume Loaded = "' '105,249: Barrels'(bbl) per year Actual Volume Loaded While Emissions Controls Operating = Requested Monthly Throughput = 120,299• Barrels (bbl) per year 10727 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas= r> Barrels (bbl) per year Btu/scf Volume of waste gas emitted per year = 286,222.58 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? Emission Factors Hydrocarbon Loadout 518 MMBTU per year 742 MMBTU per year 742 MMBTU per year The state default emissions factors maybe used to estimate emissions. Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) 1.18E-02 2.05E-05 Emission Factor Source VOC 2.36E-01 4.10E-04 0.00E+00 0.00E+00 0.00E+00 3.60E-03 0.00E+00 Benzene Toluene • 0.00E+00 Ethylbenzene 0.00E+00 0.00E+00 1.80E-04 0.00E+00 Xylene n -Hexane 224TMP Emission Factor Source Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) 4.38E-05 4,38E-05 3.45E-05 3.99E-04 1.82E-03 PM10 PM2.5 SOx NOx CO „,4.0(916; Barrels (bbl) per year 2 of 4 K:\PA\2015\15 W E0812.CP2 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants ' Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 0.003 - 0.002 0.002 0.003 0.003 0 PM2.5 0.003 0.002 0.002 0.003 0.003 0 Sox 0.000 0.000 0.000 0.000 0.000 0 NOx 0.025 0.021 0.021 0,025 0.025 4 VOC - 14.90 12.42 0.62 14.90 0.75 127 CO 0.115 0.096 0.096 0.115 0,115 , 20 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ins/year) - (lbs/year) (lbs/year) (lbs/year) Benzene 51.78 43.15 2.16 51.78 2.59 Toluene 0.00 0.00 0.00 0.00 0.00 Ethylhenzene 0.00 0.00 0.00 0.00 0.00 Xylene 0.00 0.00 0.00 0.00 0.00 n -Hexane 454.68 378.90 18.94 454.68 22.73- 224 TMP 0.00 0.00 0.00 0.00 0.00 Section 06 - Reeulatore Summary Analysis Regulation 3, Parts A, B Source respires a permit RACT- Regulation 3, Part B, Section III.D.2.a (See reguintery applicability worksheet for detailed analysis) The readout 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 Typicaily";. the volume of waste gas emitted during hydrocarhonleudauE operatians`isealgyrli ¢� ,netltef Ilawmg equgt�dn Volume (scf/year)=[Uncontrolled V0 (Ib/lb mol}jt'[370 scff -mol(. Whenthe state default emfssiqu factors_fnrsond nsaieloadaut r'tdseiY estimate pnamaryemissfens, the input value liar moleanlatw requested volume of Waste gas emlttedW uld becatodatedat 173,795-2 scf/year. Ths vawith afloat content of 2,255 Stu/scfand AP -42 Chapter (0.068 f€s1tylMBtu and 0.9116[MMStu espeh ly)resultslnNOkand €0 emissichs'of 0.013 ipVaiii" v✓stnthis apolicatton, the operator those tq esemat Non and CO emissions associated with. thetoadoutonerolla itf khda26623scf/bbl( and waste gas heat content )2,591.24 Bta/s "liquid loading vapors" stream in the ProMax simulation. This stream is calculated in the Pre Mastsnkloss shod€usin s£grag.,,,o pi parties, location inform atien;sarcierte which liquid is loaded; Method h: which carrier Is loaded, and maximum hourly loading rat, this stream is based or a maximamr'hourhi laas6 gs'9te of 28603225,6&l/hr (2,593,234.2 b11/yearbUsng tin`s information in coniunetion with vappr:,3 volumetricflew rate from the stream, 15101 Mscf/ laY, the GOR cfthis stream was calculated as fallows-4;1.:f M of/day) ' IXIOscf/Msdr065 day/year)/(2,593:234.2 biNyear)=2 26623scf/bla Addr -. ProMax:calculatedo heat content at 2,591.24-Btu/set This information=is used hi the 6am6tlsfion Device ealdt*nns In Sect%n:U3ebove, Both the heat content and 0.00 used to eaiculateaam,6ustian ermssl i from this stream are more conservative compared to the values used for condensate storage vessels-Sinsethefoadoutbr',erationonly involves stabilized fluid. the GORassociated with the condensat storag. vesselsis xpeeYed to be higher in practice because it includes gas liberated 4om the fluid as a result of a peessora drop Duc.',3toth�'t6e operator is typically ulago vedto use the GO R and heat content associated -w .,the cend'ensate storage vessels to calculate combustion etnFssiens assoceted with the loadout. Eased on¢htsinfartnatitin,.theda0dhe operator used to calcte•laadout combustion emissiansis likely'conse,l'vats Additionally the pe atots calculation results in emissionsihatarefnore COnSeiyativethan the values calculated usmg the default estimation Method, The use'nfactual data associated with this facRrty. ather`than defaultSiOfinWgiiinaticinmet.hii.oferable as Klikely results;in;a.mAresceurate[ej5resentation of octi al viol vie -is. Based en€hisinformafion,the operatdp's talc latrgn as deemed conservative and acceptable 2. Acencdiogtotho apnea The diplated vapoesfiom: operations. Section 09 - Inventory SCC Coding and Emissions Factors ar))*[2000 lb/tae)/[Molecular i Ve ght 6S lb/Sequel. Using tiesinformatinn,.the, .ladyy loin factorsfor?'NOxand Co -gasassociated with the)oadou£ operation is captured using a vapor rollectionsystemthat collects the and.routesthe waste gas to dedicated enclosed combustion devices. hus,kept sepaiate.frbm the_ enk barteryvapor collection system. The permit will contain a condition that requires this systemto be operational' stall times during l oadout et included in thgset.hecause the operator us'required to conduct weekly visible em issrons obserraitons per t phe O&M. plan- In the event visible -emissions areobserved,; gpiionteither repair thiprob,rani-ufirnediatelyor performafa ,i method 9 observation. if visible mrssronsare'ohse ed;throughth Method9 the operator isrequiredm immediately I. k these'ahockssoccur oft aweekly basis, It wasdetermined.a one time method'Sral part of the;eifwertlfiootion woo uanecessary, rding td the applic AIRS Point # 002 Process # 01 :pT the facility via pipeline using lease automated c dytra„r)sfar (i11CTJ unit :frock foadnut is only utilized r febliccomment,Tieoperator reviewed SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 1.04E-03 0 lb/1,000 gallons transferred PM2.5 1.04E-03 0 lb/1,000 gallons transferred 50x 8.22E-05 0 lb/1,000 gallons transferred NOx 9.51E-03 0 lb/1,000 gallons transformed VOC 5.619 95 lb/1,000 gallons transferred CO 4.33E-02 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 IMP - 0.00E+00 95 lb/1,000 gallons transferred 3 of 4 K:\PA\2015\154VE0812.CP2 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re: ulation 3 Parts A and El- APEN and Permit Requirements Source it in the Nnn-Atteinm'enc Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10.000 gallons (238 Bets) of crude oil per day on an annual average basis? 4, Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? S. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than OOTPY (Regulation 3, Part B, Section II 3)7 You hove indicated that sou se is itr alto Atere-Atnrinmenl Area _ NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)7 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day an an annual average bases? 4. Is the loadout operation loading less than 6,750 obis per year of condensate via splash fill? 5, is the loadout operation loading less than 16,308 hbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 2TPY, NOR greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2(7 JSaurce requires a permit 7. RACT Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section iil:D.2:a)? 'The Marked stout be operated with :submerged fill fo satisfy PACT - Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is note rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,"'may,"'should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. No Nd Go to next question. Go to the next question Go to next question Go to next question 6o to next question The loadout regulate a permit Paget:; JThe loadout must be operated with submerged fill to satisfy RACT. COLORADO Air Pollution Control Division Department of Public Health k Enviroranerrt Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 15WE0812 Issuance: 2 Extraction Oil & Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: General . . Description: Well Production Facility C Street Production Facility 123/9DD4 SWSE SEC 36 T6N R66W Weld County Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description • Emissions Control Description Liquid Loading 002 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO Liquid Loading 002 --- --- 0.8 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 3. 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 Liquid Loading 002 Enclosed Combustion Device(s) V0C and HAP PROCESS LIMITATIONS AND RECORDS 4. 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 002 Condensate Loaded 126,299 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 Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health & Ervirorime it Dedicated to protecting and improving the health and environment of the people of Colorado keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 5. 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.) 6. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 7. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Regulation Number 3, Part B, Section III.D.2) 8. All hydrocarbon liquid loadingoperations, 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.) 9. 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. 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. 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 seals and PRD with an indication of status, a description of any problems found, and their resolution. 10. 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.): Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health & Erviron rnent Dedicated to protecting and improving the health and environment of the people of Colorado 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. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING a MAINTENANCE REQUIREMENTS 11. 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 your 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 12. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 13. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 14. All previous versions of this permit are cancelled upon issuance of this permit. 15. 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 change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or Page 4 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For 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. 16. 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 VI.B.4/V.A.7.B). GENERAL TERMS AND CONDITIONS 17. 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. 18. 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. 19. 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. 20. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health 8 Environment. Dedicated to protecting and improving the health and environment of the people of Colorado 21. 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. 22. 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. 23. 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: Permit Histo Harrison' Slaughter Permit Engineer Issuance Date Description Issuance 1 February 1, 2016 Issued to Extraction Oil a Gas, LLC Issuance 2 This Issuance Issued to Extraction Oil a Gas, Inc. Decrease permitted throughput from 675,000 barrels/year to 126,299 barrels/year. Use state default emission factors to estimate emissions. Issue as final approval. Page 6 of 8 COLORADO Air Pollution Control Division Department of Public Health E Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 52 3 002 n -Hexane 110543 455 23 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 002: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 2.36x10"1 1.18x10-2 CDPHE PS Memo 14- 02 Benzene 71432 4.1x10"4 2.05x10"5 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%. Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health E; Er vir« rrn erci Dedicated to protecting and improving the health and environment of the people of Colorado 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane Et Total HAPs PSD and NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed'. below: h ttp: / / ecf r. g poaccess. 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 MALT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: Extraction @SII &!Gas County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: SWSE quadrant of Section 36, Township 6N, Range 66W County: [Weld County Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SWSE RN..-- Paritulate Matter (PM) E Ozone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance tt Self Cert Required? Action Engineering Remarks 0tlIii 131 i1 ��>- ensateTaplc y Condensate Tanks 18WE1143 7 �� P ermatan '. lssuare ; I^ Section 03 - Description of Project • • Extraction Oil & Gas, Inc. (Extraction submitted an application requesting Synthetic ) pp q g permit coverage for several 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 requestir:gpermit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon loadout, VRi venting, and separator venting. This preliminary analysis only addresses the condensate storage vessels The condensate storage vessels arc: APE' required because uncontrolled requested: VOC emissions are, greater than 1 tpy (Colorado AQCC Regulation 3, Part A, Section Additionally, the source is permit required because uncontrolledVOC emissions from ail ADEN required sources atthe facility are greater than 2 tpy (Colorado AQCC Regulation 3, Part B, Section' [r.0 2 a.): The condensate storage vessels were previously covered under the CIRRI.- The GPO1 wit be cancelled upon issuance aft r pe�t7 it. rent is required for this source because new synthetic minor limits are being established in order to avoid other requirements. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? RequestingSyn Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. 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 (PM) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 N05 CO VOC PM2.5 PM10 TSP HAPs 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) PM10 TSP HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRS ID: 121 9004 001 Plant Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput= (Requested Permit Limit Throughput= _ Potential to Emit (PTE) Condensate Throughput= q fif0 O.4 Barrels (bbl) per year T i59%23H1 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating= 12;`4)) Barrels (bbl) per year Requested Monthly Throughput= 220247 Barrels (bbl) per month I Secondary Emissions - Combustion Device(s) Heat content of was. gas= g �,'.;25R100 Btu/sof Volume of waste gas emitted per BBL of liquids produced = 1 1,1994 scf/bbl Actual heat content of waste gas muted to combustion device = Requested heat content of waste gas routed to combustion device = 3 Barrels )bbl) per year 6,683 MMBTU per year 8,019 MMBTU per year Potential to Emit )PTE) heat content of waste gas routed to combustion device= 8,019 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions] Pollutant Flash Emission Rate (lb/hr) W&B Emission Rate (lb/hr) VOC 5.00856627 28.9973021S Benzene 0011910-0 O tl425348..:. Toluene 00152871 0.0574956 Ethylbenzene 0.000383665 000156797.: Xylene `' 0.004933435 00229156 n -Hexane 0.122188 0,656164 224TMP 6.000592414 ;. 0.06an0x25 Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (Ib/bbl) )ib/bbl) (Condensate Throughput) 1.1487E-01 1.8392E-04 2.4586E-04 6.59266E-06 ' 9.4075E-05 2.6293E-03 1.2499E-05 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat (Condensate combusted) Throughput) (Condensate Throughput) VOC Benzene Toluene 5.744E-03 9.196E-06 1,229E-05 3.296E-07 4.704E-06 1.315E-04 6.250E-07 Ethylbenzene Xylene n -Hexane 224 IMP Pollutant PM10 PM2.5 NOx CO 0.0000 0.0000 0.0002 0.0010 B O07S ,--:::_ :I?. 00100 < -F. Section OS - Emission Inventory Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 148.95 124.12 6.21 148.95 7.95 1265 0.030 0.025 0.025 0.030 0.030 5 0.030 0.025 0.029 0.030 0.030 5 0.273 0.227 0.227 0.273 0.273 46 1.243 1.036 1.036 1.243 1.243 211 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled )Ibs/year( (Ibs/year) Requested Permit Limits Uncontrolled Controlled (its/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 476.94 397.45 19.87 476.94 23.85 637.98 531.31 26.57 637.58 31.88 17.10 14.25 0.71 17.0963 0.85 243.96 203,30 10.16 243.96 12.20 6818.37 568197 284.10 6818.37 340.92 32.41 27.01 1.35 32.41 1.62 Section 06- Regulatory Summary Analysis Regulaten 3, Parts A, B Regulator 7, Section XII.C, D, E, F Regulation 7, Section XII,G, C Regulation 7, Section 01/11.0, al, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NIPS Subpart Kb Regulation 6, Part A, NIPS Subpart 0000 NSPS 0000a Regulation 8, Part E, MACT Subpart HH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Storage tank is subject to Regulation 7, Section XII.C-F Storage Tank is not subject to Regulation 7, 500600 XII.G Storage tank is subject to Regulation 7, Section XVII, 0, C.1 & C.3 Storage tank Is subjectto Regulation 7, Section XVII.C.2 Storage Tank is not subjec[to NSPS Kb Storage Tank is not subject to N5P5 0000 Storage Tank is not subject to NIPS 0000a Storage Tank is not subject to MACT HH 2 of K:\PA\2018\18WE1143,CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Tasting Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to e0 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines In PS Memo 05-0 Does the company use a site spedfic 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 amf collected within one year of the application received date. However, lithe 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 fatter based on guidelines in PS Memo 05-01. N/A - site specific emission factors were developed for thbs source. Ones the company request a control device efficiency greater than 95% for a flare or combustion device? lifts, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of tie combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes i. easedorttho APES provided,OVoentywails pro duce to this facility, The threes l tng wetl 'tfslsfacfitywece t ttue produce from the Nichrnroftrmo4 rSeventea wwels' were di-5[mi and brought¢nlme In 2008 Resedun_COOCO, .,-product A g t2610.Thfrteenofthese welts mbrinen'frontthe Niobrara form t,onaodlth'eretn niag Wellspl',dd4P thlssourcz-o,n10/30/18{Ora.1intofthewell names endAPlnumbers.The sample: usedtodcvelop kespeeiic enf(s5l' di the wells Have Matbeen' recompleted, re-frectured orotheow, 0nnod41ed [f.'e:'new weals added}: th sample isreprefepfx forward The permltwll1 notcontaIn a,I nit'aiteon, quu,ngithe.operetortin obtain a wsltespeclhcs mple nordettt 12.Tho sitespeptflp am15slon Pao -bars weveloped through the Vaebt ProMaxand a site atecif2 pressurzeclIfggjdspr( prgsr gedd) ,I P`mmple was obta,nedfromtheootlet ofdse to pressure sepa-atorforthe C5.5coG 01-112 well on / ere I Indusingthe a g:h t t t dtl( model The PAVMax mddeCresglted in the folldwmgva(q (A)Fia l(6a 5t _(!)bas Blsd 725089 PAscf%day (I}H Neat Content; `Z59124 Btu/ d U ing M t the ge15e� d tgpa�ggF.fon Mscf/dayl)+((725089 Mucf/deyj to/sttl/(649Z-0 2587.005 BYuf T 4 The5ORw s Ioulated uses ggs fbw les ntlcold ommer83above.n onto et wth tie Yh ughput basis dth Ibl l hop foil ws COR (scf/bbl) (112416M"9gi/t j(725PBSM cf/d 3)) (365 daV/Y t) 11000 cf/1M nct)/i2503,734.2 bnVY r)-11355, 5 3 2 455 cF/bbl. 8 An initial Method22 ss opacity nattn (ixded imtJt ,q rrmtb theop t req -d orMuc€tve kIy bl bs bon pertheOtB'iMij observed,theoperator has the option to elHlart¢parctiley(tiblem monad atnip or performafotmal method 020bs Nab¢n ify Bible emiss,op3 ar@nbserVddllttUlli required to immediately con ci,eProblem. Since These Checks occur on a weekly basis, it wasdeterm nod aoneime methad22 as par!¢f thasset-cerdficadomw: 014 6. Theo eratorwas idedw,th adrafY nutandAPESredlinehareview prior to pubic earnm tTh rat r dh the t and p Ash yh d ' p prove per p p _ Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point g . 001 Process It 01 SCC Coda Uncontrolled Emissis Pollutant FactorControl% PM10 0.00 PM2.5 0.00 NOx 5.01E-03 VOC 2.735 5 CO 2.28E-02 Benzene 4.38E-03 5 Toluene 5.85E-03 5 Ethylbenzene 1.57E-04 5 Xylene 2.24E-03 5 n -Hexane 6.26E-02 5 224 TMP 2.98E-04 5 Units b/1,D00 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gall end condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput b/1,000 gallons condensate throughput 3 of 5 KI\PA\2023\18W E1143.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Re• Motion 3 Parts A and R-APEN and Permit Requirements 16n:.r.r. is to 0:o.50: -Attainment Anna ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.5.a)? 2 Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo OS -01 Definitions 1.12 andl.14 and Section for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than lO TPY or CO emissions greater than 1OTPY (Regulation 3, Part B,Sectlon 11.0.3)? 'You hays- indicated shut smrcn is in No; Non -At te:nn:ant Assn NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Pan A, Section II.D.1.a(? 2. Is the constrbction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total faclllry uncontrolled VOL emissions greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than SD TPY (Regulation 3, Part D, Section 0.02(? ISourcet'oeulms a permit Colorado Regulation 7. Section XII.C-F - • 1. Is this storage tank located In the a -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operations, natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? (Storage tank i5 nthiect to Regulation', See.ien Section %II.C.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section Xll.C.2—Emission Estimation Procedures Section Xtl.D—Emissions Control Requirements Section RILE —Monitoring Section RILE— Recordkeeptng and Reporting Colorado Reguta510e 7, Section PILO 1. Is this storage tank located in the 8. -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tankexhibt"Flash" (e.g storngnonstableed liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? 'Storage Tank is not subject to Regulation 7. 00,110: X11.13 Section XII.G.2- Emissions Control Requirements Section %II.CI —General Requirements far Alr Pollution Control Equipment —Prevention of Leakage Section %II.C2—Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located ate transmission/storage fealty? 2. Is this condensate storage tank` located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this 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 VOCI (Storage tank is sub oct to Rayvleroa 7, Section 0111, R, C.I. & C.3 Section %VIM, -General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section %VII.C.1 - Emissions Control and Monitoring Provisions Section %VII.C3-Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilzed"liquids? (Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII. C,2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60. Subpart Kb. Standards of Performance for Volatile Organic liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meson (m5) P.472 631s17 2. Does the storage vessel meet the following exemption in 6o.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m' 7'10,000 BBL] used for petroleum or condensate stored,processed, or treated priorto custody transfers as defined in 601110 3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2] after July 23, 19g4? 4. Does the tank meet the definition of "storage vessel' In 60.111b? 5. Does the storage vessel store a"volatile organic liquid (VOL?' as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 toe (-29.7 psi? and without emissions to the atmosphere f60.110b(d)(2))7; or b. The design capacity is greaterthan or equal to 151 me (^950 BBL) and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (6o.11ob(b))?; or o, The design opacity is greater than or equal to 75 M' [^472 BBL] but less than 151 m' 1-950 BBL] and stares a liquid with a maximum true vapor pressure` less than 15.0 kPa(60.110b(b))7 (.Storage TOtk it 0A suitiect to MPS rib Subpart A, General Provisions 46o.112b-Emissions Control Standards for VOC §60,113b -Testing and Procedures 460.115b- Reporting and Recordkeeping Requirements 050,S56b- Monitoring of Operations 90 CFR, Part 60, Subpart 0000. Standards of Performance /or Crude Oil and Natural Gas Production. Transmission and Distribution 1. Is this condensate storage vessel located at a fadlity in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed,reconstructed, or modified (see definitions. 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the lndmdual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vsel meet the definition of"storage vessel"z per 60.5430? • 5. Is the storage vessel subject to and controlled In accordance with re uirements for store a vessels In 40 CFR Part 60 Subpart Kb or 90 CFR Part 63 Sub art HH? ISdera '1un3' Is not subtext to oiP5 D000 Subpart A, General Provisions per 460.5425 Table 3 §60.5395- Emissions Control Standards for VOL §60.5913 -Testing and Procedures §60.5395(8) -Notification, Reporting and Recordkeeping Requirements §60.5916(c) - Cover and dosed Vent System Monitoring Requirements §60.5412 -Control Device Monitoring Requirements [Note: It a storage vessel is previously determined tobe subject to NIPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NIPS 0000 per 60.5365(¢)[2] even If potential VOC emissions drop below 6 tons per year) 1�E4 ..... iiMEM Yes Yes No Source Requires an APEN. Go to the next question Go to next question Source Requires a permit Continue -You have indicated the site attainment status on the project summary sheet Continue -You have Indicated the facility type on the project summary sheet. Source is subject Continue - You have determined facility attainment status on the Project Summary sheet. Storage Tank is not subject to Regulation 7, Section XII.0-You have indicated facility type on project summary sheet. Continue -You have indicated the source category on the Project Summary sheet. Go to the next question -You have indicated facility type on project summary sheet Go to the next question Source Is subject to parts of Regulation 7, SenlonsXVII.B&C. Go to the next question ad Source is subject to all provisions of Regulation?, Seaton XVII, Subsections B & C Storage Tank is not subject NIPS Kb -The storage vessel rapacityIs below the applicable threshold. waS NA §i\ 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, 40 CFR, Part 64 Subpart 0000s. Standards of performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification. or Reconstruction Commenced After September 15, 2015 1. Was this condensate storage vessel constructed, reconstructed, or modified Nee definitions 40 CFR, 60.2) after September 10, 2D15? 2. Does this condensate storage vessel meet the definition of "storage vessel.. per 60.54305? 3. Is this condensate storage vessel located at a facility 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 tons per year? 5. la the Sterge vessel subject to and controlled In accordance with re uirements for store e Vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part63 Sub art HH? 15Corage Tanku not suhlaci 00 NSPS 0000, 40 CFR, Part 63. Subpart MACHH. Olt and Gas Production Facilities 1. Is the storage tank located at an all and natural gas production facilitythat meets either of the following criteria: a. Afacility thatprocesses, upgrades or stores hydrocarbon liquids. (63.760(a)(2)); OR b. Afadliry 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 users 163.760)a)(3))? 2. Is the tank located at a facility that is major. for HAP.? 3. Does the tank meet the definition of "storage vessel.. in 63.7613 4. Does the tank meet the definition of"starage vessel with the potential for flash emissions s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60 Subpart Kb or Sub art0000? [Storage 'tank (s oat ambient no MACY fill Subpart A, General provisions per 463.764 (a) Table 2 §63.]66- Emissions Control Standards 353.723 -Monitoring §63,]/4. Recordkeeping 6e3.775 -Reporting RAC Review RAC review Is required H Regulation 'does not apply AND ifthe tank Is in the non -attainment area. Hthe tank meets both criteria, then review RAC] requirements. Disclaimer This document assists operators with defamining applicability of certain requirements of the Clean Air As( Its implementing regulations, and Air Quality Control Commission regulations. This document Is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the Inr5vidual 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. la the event of any conflict between the language of this document and the language ofthe Clean Air Act„ its Implementing regulations, and Air Quality Control Commission regulations, the language oldie statute or regulation will control. The use ofnon-mandatory language such as "recommend,' 'may; "should,' and-can,"is Intended to describe APCD Interpretations and recommendations. Mandatory tenidnology such as 'must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and All' Quality Control Commission regulations, but this document does not establish legally binding requirementsln and ofgse/! Yes Na Go to the nest question Go to the neat question Go to the nest question Storage Tank is not subject NIPS 0000a. [Yes 'Continue- You have indicated the source category on the Project Summary sheet. wow Storage Tank is not subject MAR HH -There are no MAC HH requirements for tanks at area sources COLORADO Air Pollution Control Division Department of Pubic Health flEovirtrarnent Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1143 Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil a Gas, Inc. C Street Production Facility 123/9DD4 SWSE SEC 36 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point' Equipment ' Description Emissions Control Description Condensate Tanks 001 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, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result Page 1 of 10 COLORADO Air Pollution Control Division Department of Public. Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado in revocation of the permit. A self certification form and guidance on how to self -certify • compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2. ) 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, YOC CO Condensate Tanks 001 .. --- 7.5 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled Condensate Tanks 001 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 001 Condensate Throughput 2,593,235 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) Page 3 of 10 COLORADO Air Pollution Control Division Department o₹ Ribitc Hea€th & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it 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 storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator shall'' follow the most recent operating and maintenance (OiM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health a.Ervirarnnent Dedicated to protecting and improving the health and environment of the people of Colorado Existing Permit Number Existing Emission Point New Emission Point GP01 123/9DD4/001 123/9DD4/001 19. 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; . or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation 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 VI.B.4/V.A.7.B). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 5 of 10 COLORADO Air Pollution Control Division Departmentof Public Health & Envirosument Dedicated to protecting and improving the health and environment of the people of Colorado 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied (lb 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 owneror operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health 8 Ervironmerf. Dedicated to protecting and improving the health and environment of the people of Colorado Permit Histo Issuance Date Description Issuance 1 This issuance Issued to Extraction Oil 8 Gas, Inc. Permit for condensate storage vessels at a synthetic minor oil and gas well production facility. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public_ Health & Erviroorneut Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 477 24 001 Toluene 108883 638 32 Ethylbenzene 100414 17 1 Xylenes 1330207 244 13 n -Hexane 110543 6,819 341 2,2,4- Trimethylpentane 540841 33 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 1.149x10"1 5.74x10"3 ProMax 71432 Benzene 1.839x10-4 9.196x10"6 Page 8 of 10 'COLORADO Air Pollution Control Division Department'of Public:: Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 108883 Toluene 2.459x10-4 1.229x10-5 110543 n -Hexane 2.629x10"3 1.315x10"4 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 CS Scott 01-1-12 well on 09/18/18. The sample temperature and pressure are 110°F and 49.5 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 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 folio Status Applicable Requirement Operating Permit Synthetic Minor Source of: VOC, n -Hexane &t Total HAPs PSD and NANSR Synthetic Minor Source of: VOC 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 Page 9 of 10 COLORADO Air Pollution Control Division Pepartment of Public Health & Er+n or;rriera Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical - Address/Location:. SWSE quadrant of Section 36, Township 6N, Range 66W County: Weld County Type of Facility: � What industry segment? Is this facility located in_a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) :C.Street Prod Section 02 - Emissions Units In Permit Application Quadrant Section Township Range 36 66 Particulate Matter (PM) E Ozone (NOx & vOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cart Required? Action Engineering Remarks 11133 rr g 13 y v ij 111 erTank Water Tanks :.- Yes 15WE1144 �� €°13rf aki � 3 I Section 03 - Description of Project Extraetron Au & Gas, Inc. (Et xraction) submitted an application re uestl rg permit:coverage for several sources at an existing synthetic minoroil and gas well production facility located in to uantmn a dttd3 a tarventi with Thishis applicatfbrt't{ e"ope(atoPis`""req"17eatng permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon loadout Vl i r g, preliminary analysis only addresses the produced water storage vessels. ' 3 i .. tl��..', llli The prod uced water storage vessels are ADEN -required because uncontrolled requested IOC emissionsaregreater han lfpti (Cobrado AQCC Regulation 3, Part A, Section If.8.3.a)i Additionally, the source is permit required because uncontrolled VOC emissionsfrom all APEN required sources at the facilitya re greater than 2tpy (Colorado AQCC Regulation 3, Part Br Section I1.0.2.a.). The produced water storage vessels were previously covered under the GP05. The GPO will be cancelled upai issuance of this permit Public comment is required for this source because new synthetic minor limits are being esta Wished is order to avoid other requirements, Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? fietfuesting SynthJtie tinor Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. 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) N .Yes 502 NOx CO VOC PM2.5 PM10 TSP HAPs 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) ❑ ❑ PM10 TSP HAPs Produced Water Storage Tank(s) Emissions Inventory 003 Produced Water Tank Fatality Allis ID: County 9004 Plant Point Section 02- Equipment Description Details Detailed Emissions Unit -;(21•Ailobeteol Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Informatton for Emissions Estimates Primary Emissions • Storage Tank(s) Actual Produced Water Throughput = 'Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = Drags vessels conneetedvie llgoid teagifntd,: '[EP261;7;5: Barrels (bbl)per year Actual Produced Water Throughput While Emissions Comrok Operating = Barrels (bbl) per year Barreb (bbl) per year Secondary Emissions- Combustion oavke(s) Heat content of waste gas= ii:i:.3204 Mu/sof Volmna of waste gas emitted per BBL of liquids produced = €`�22 sef/bbl Actal 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- EmW kris Factors & Methodologies Ex= O*MW*Xx/C Ex = emissions of pollutant x O- Volumetric flow rate/volume of gas processed MW = Molecularwelght of gas =SG of gas * MW of air 00= mass fraction of x in gas C = molar volume of Ideal gas (379 set/Ib-mot) at ODE and 1 atm MW GWR Hydrogen suiRde CO2 N2 methane ethane 32.3692 Ib/Ib-mot 241 scf/bbl Weight Percent 1% 0.O0 11.33 17.90 14.24 Isobutane n -butane .12 19 cydopentane n-Hetene cydohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes 206 9 FI oloo :t.:WRA iii=llii .::133911/d td C10 Total you Wt % 100.00 Will this storage tank emk flash emissions? Requested Monthly Throughput= 50959 Barrels (bbl) per month 665 MMBTU per year 1,527 MMBTU per year 1,527 MMBTU per year Emission Factor Source Pollutant (ib/bbl) (@/bbl) (Produced Water Throughput) (Produced Water Throughput) ®' 5.63007E-02.MIME < .Pfr .. < . 's i.SW 1/44 EIMMINIMIEMMEM 1l®: s1 = "®' '®" 0.06000E+00 0.000E+00 Pollutant Control Device Factor Source unaEmission (waste heat ombuuted) (Produced Water Throughput) :/71- 0.0075 0•0075.=MIMI 0.0680 _MM. 0 :' 03100 ' -.MEM. Heat Value Calculation Component _HV%Btu/scit oleo HHVIBtu/soil Water 0 r 3 ilf ll 1,i 0 CO2 p - :s h...2r ..,3'105 w;(l:3fi+3-,h.f-xv 0 92 n ".... 177202' .'/S"i i?V 0 rrelhane 503.4 294194 ii55 1010 ethane 1513.77 19.2342.....510433- 1700.7 u u.9 a 3 10.4625 2900. isohutene 2.333.1 W3 1.0337 -2_._ Y 30`_0.8 28500 3252.4 is eentene 3500 5 0,5321 4000.0 n -Pentane 37069 0.'>9J3 4003.1 Cucodevione 35'_2 0.0784 r : 3753.0 Cdcbhexene 4173.7 0.1082 13 4401.6 H-vottae (heat.; value Alnuexene) 4403.0 0.6726 4756 n ausnes s 5109 0.0921 5302.5 M,ahykVdnisexene 4003.7 y 0.0634 111/' 52_95.9 Octanes. 5796 - 0.0079 0248.9 konanes 6493.2 0.0156 - 5496.4 Oecanea. 7189.5 7:C;ly, 0.0707 7743 Bar -zone 3590.9 1 k4,131,:0.-0916 3741.9 13,:a13,:ane 4273.7 d 0.3163 4474.9 E11Vl5-nzen0 4570.4 91//41o101151/ 0.0083 ,B7=2=t52==rt 5222 Xoknesthvo of 00 0mil-=net - 4557.1 _y � ill .,.a . 0.0939 - - 5208.7 n-Hstane 4403.8 ,1,.11.1 . ..,e..,: :5>: 0 S32 'ii; it""Fm' 4756 23A -MAP 119'3,3/orIs, aic-a,nal 5770.8 0 3313];3° l P. 62'.31.5 325 535.8 :l .;f 0' l ii0l Ei3iga 537.0 100.032 Lower Heating Value of Gas Hrgher Heating Value of Gas 1103.653042 Btu/Sct 3205.230496 Stu/scf O 2 of 4 K:\PA\2018\18W E2144.CP3 Produced Water Storage Tark(s) Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tans/year) (tons/year) (cans/year) (Ibs/month) VOC 16,890 7.368 0.368 16.890. 0.845 143 PM10 0.006 0.002 0.002 - 0.006 0.006 PM25 0.006 0.002 0.002 0.006 0.006 1 ' NOx - 0.052 0.023 0,023 0.0519 0.0519 9 CO 0.237 0.103 0.103 0.237 0.237 40 Potential to Emit Actual Emissions Requested Penton Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 1016.12 443.27 22.16 1016.12 50.81 Toluene 96824 422.39 21.12 968.24 48.41 Ethylbaeeene 29.05_ 12.67 0.63 29.05 145 Xylene 295.99 129.12 6.46 295.99 14.80 e -Hexane 2924.46 1014.03 50.70 2324,46 116.22 224 TMP 0.00 0.00 0.00 0.00 0.00 Section O6- ReeulatonvSummary Analyst Regulation 3; Parts A, B Regulation 7, Section X011.0, Cl, C3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS lubpart0000 NSPS Subpart 0000a (See regulatory applicability worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements Source requires a permit 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 5575 0000 Storage Tank is not subject to SOPS 0000a • Does the company use a site specific embslons factor to estimate emissions? ft if yes and If there are flash emissions, em the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected wkhin one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then k may be appropriate to use an older site -specific sample. If no, the permk will contain an "Initial Compliance" testing requirement to develop a site spent emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company requests 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 concent etf0n sampling Section 08- - hnleal Section 09 - inventory SCC Coding and Emissions Factors y7 AIRS Point4 003 is sly rce-are fit'iof scf econde t t mge plhe niostrecent hus acceptabfefof estah�isi pfactors from this timates theflash.portionofemissmns fromThe stpra o ever rtwas det i edth tt eveloptngslte spedficfactors fpygssehdoe, not provide Informaq oduced water storage vessels and not ha imfsai{Ian;Fhoverall emission factor or nmissl sslonsbelow reportingthresholds Ii <250 lb/year) As aresult, on factors for these HA permit because the opener is requ. ed to conduct teesly ible an ssin, c lv its perthe0&M I atlo 021ta,(e ai Method Yb t roinb sons are ohs rvad .hrough .ne Method ope[aE ethod 22 ai part O. -the self ce011110atio w ssaon laed directly from the fldsh gas analysis pr.1&..d ul the ap{ilratnn The In ro itemca' CUIaYIn sh gas. ... _ lineto review pr or to pub) c comment The R r41gs£evi wed bothdocn e Process N SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, wsrldngebreathing+fashing losses alt's s expressed they had no common ply..serves to de Pollutant Uncontrolled Emissions Factor Control% Unlb PM10 4.52E-04 0 6/3,000 gallons liquid throughput PM2.5 4.52E-04 _ 0 b/1000 gallons liquid throughput NOx 4.126.03 0 b/1,000 gallons Squid throughput VOC 1.346t00 95 b/1,000ga1(oro liquid throughput CO 1.88E-02 0 b/1,000 gallons liquid throughput Benzene 4.03E-02 95 b/1,000 gallons liquid throughput Toluene 3.04E-02 95 b/1,000 galore liquid throughput Ethyibenzene 5.15E-03 95 b/I,000 gallons liquid throughput Xylene 1.17E-02 es 6/1,000 gallons liquid throughput n -Hexane 9.22E-02 95 b/1,090 gallons liquid throughput 224TMP 0.00E+00 95 6/1,000 gallons liquid throughput 3 of Ki\PA\2018\18WE1144.CP1 1 Produced Water Storage Tank eegulatoryfwlycls Worksheet palm nob that NSPS Nb myht b• nyht b• •ppllobYbrnrtah tanks at werarmnaap.m.aAnd InNdbn bdtba. If Alm tan. You An nvbwbg are at ono. tb..edifies, puce. rANAw NSAS Kb. [Alarm.,A nulmbn3Pub A and II -ADEN end NAAR wyuhrernevra ATIAINIAMT a. Are unrontrolled actual nisdns from any.1Aru pol:ae:. from NIs1:Mlvld:ul source nreobrtnen xtty IRagulatlan3, Pan A,sedIenll.D.1A1? a. Is Ilmoperator clAlmlne Oran". roll And b tnetanblocated a•wn.ommerdal iadllry for p:ocessA¢ All snag,, waarmuaierl (reguleian3, Part Asdtonll,o.1.M1 3. Are total .wmmrolled weembstom areateA urn 5 TPr, Mar greatertnan 10 'WY arm embafon greater tksn.AA(Regular., 3 Pert e,ssslmu.oali 1. nlledemisslom rma, any att.n..pollutants ',A.A b adlvidnlan:ngmeterthan 1 'MY Ixegul•rin 3, Pan A Seruon ILD.1.al? NT 2. Are meCreatormlmin.aIh•n 1wodd.dl and stk rang lowed a e nnmmmeo l fadlitvfarprongingoa and gam wastewater? Iteg boon3, Part fl, smtann.D.1.m1 3. A:etal fadlbw r u, dudV mbs elom greater Py than2T, Now wearerth:an STpv or m emkdnscreaterthrr1nm Areguam tion 3, Parto.Swnn.D.x1? s:on an..,e. q.:nrt Colorado Regulation 7,.....1111 mlrIWaoraperm.? - 2. aWRprodaedw. nnend production grr•t n,welI prodminbeat,A,n g mp anar•nan r,wmnlg.a p:aea mg qnt? 3. A Orb produced waterstarape lank a located rAoagetankt�P r Poll lAAD nshim Ewrome'rn d pmnamfn d Drab. mnr Control ad Monuonng Provisions r anpm Peoulremems Ole S. Doc produced wweerdo.ei e antoxah Anb stalAbd'DodNa, IlnAtl.bllowlreaddna:r.Iprould,n.wN. source Aecrurrea An . GobWenod aaann Source RequIres a permit Continue -.Aiwa ...red the mrorm u,evraae rr.,yeh. continue - You have std the faeinvvpeoonthe Prelett summary shad. A0 Ale uirstlari Spam b sblm top era of freawuan?, Sedlana xM I.gge as b the nor wavon ENa--- �Sourns subim ro liwAvmm:s of Regulation?, Sect Ion snl,sutrmtma a aC sadbnWM. ..ream!Monb,dn orsm:a,rin. nted.rnAlr Ponatlom mntrw Equipment 90 [m, part 60, S bq,t o000, sudar. of A do anon f or Crud• Dil and xa,r•I o•. Reaction, Tr•remmmn Ad 0bd bud,n 1. u rhb produced w•tersrwage nem, looted at leaky to the ors.. Aid wranl gas productWm-al.'s prmesdngarrmem ornatw•ly„m etr•bsad. n aeragesegmentatleldutryi 1. Was n M1b pbmd wevrstonge vosdraw:utd,:eronauwtd, art,.. lseeddmk.e 40 CFP,60aW 1 warrlAueuat13,2o11ad.pembr16,a01s? Ara *Antral Vac emissbn'frn: We Idddual stAAAAvmetl Amatr Wan or equal to s tent peryear? DoesWla endured waerstar•gevasel AAAthedeknnln Af'Mon veuesseYpereo.5n3o? Is subp.rtADe,enlprovk.0 pr460slasiable3 460.5533- ErnAsIon Control Standards for We 460.5913•TedingandPmedulm 460.53a51a1- Not lnouon, Reporting Ana nea:meeAing gnulomdnu 460.51161x1- Cover e d Om. vnr Sotem rnonaorina xn uirements 460.x2? -Comm Dwro Mwtdnggnulmmems IxoAA •Atorese vassal A prAvlarely dotarrnIn.d•ubl•dto xsrsa000dnmmmtumo.b,w6nnq.wnvxon.a appliuNltra .•rm'neon d•ta abowar•m•Inq•am •ux5Ps0000gr6aazespgxl awn IA polm.aIVac mi.slenr drop below rengyArl partOCDq•,stad•N•of P•rfornurc•br muda oe And x mdora p•aWa.forAMA Candr:W,ry MAdlrral,n,r.Ahemctlemmn,ronerlAWrs•purob•rae,am5 t. Mut Pr, proi..waterstorams d Ism doNnkton 90 CFA 60:21 after September 1B.20157 s? 1. xeAnnItkAl reconstructed, Does this vessel A axndRyb the crude and natural gas production iegroArA.rumor fpsp,nesfn6 segment or natural gatnrsmissan and Monnsegment of Ow Idorel slons2 from Ale torageAssel greater than or al o6 tons Aar rl 5. Is the �usbld to odxo,rt did ante®:dnce wish mul:ementswrratwveveuel. In 40 ag Port 60 Subpart Kb a 90 CM Part 63 so RAH, w1 ra.aSA. AAtAAA.. MP-"..e.a PACrIDAhua PAC r.dw a nkuing egulaaonTgm. iwtaPdv AND K WUr.,btl.:romattanmerA arm Kt. "Alms. barb..Para, tlwn'Wow PAU ...A.A.. Disclaimer This document assists opera,. &femininpapploablo of certain roquirotnenh alias CleanA. Acted implementing isolation. and Ah CuaPh Con. Cmmasion This sitaSiatisai is f.'s, a srrapulefun.andlieenaysts mrynd apply Ste Sasadupn las ins ottya llach and grow nws.Thb document does not an a angan sedulity's har any lalverepiiiipg, many altar lsgalry banding requirement andislwf bgalry n! ,able. kilts even, al any contact bahnenlae Massaged Ibis txerdgios,. Maknguaga dam Clean Air Actr ihlmpamanangpdnellans, and AirQuakyCanal Commission regulations. Ma languegi d'he statutes, regulation will waits" The m.dalor language such as may,' Shouhi,'entl •era' Is Mender to class." APCD inlagpehfona andrecommenddbns. Montaldylarminbgy sacs gas la000 Y nd'requaal re Infendad to durlM canvass tleWparnonfs under Ina terms of Ma Clean Ape Act and Air Duaby Lonbd Commission tears..., dal this tlawmenl does sal eaadisa lepagy bind. regimmen's in antl at 'Usk NOW tifit ConAnuarrouev Wteatd IAA home otyononrn.prgm Summary sheer. omw geT•:b Is not Inn 0000 n.lank qua construct. eutslae oftnrepdfnmrcyd.re tthe nett aaeAln Gotothernert 5roraeerea bmtsugm Nsrso000a. COLORADO Air Pollution Control Division Department of Public Health & Environmen€ Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE 1144 Issuance: 1 Extraction Oil &t Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: C Street Production Facility 123/9DD4 SWSE SEC 36 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Water Tanks 003 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, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result Page 1 of 9 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 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 Water Tanks 003 --- --- 0.9 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled Water Tanks 003 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 , 003 Produced water throughput 600,000 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; Page 3 of 9 COLORADO Air Pollution Control Division Department of Public Heath & tovirorenerrt Dedicated to protecting and improving the health and environment of the people of Colorado • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVILC.2. OPERATING &t 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 O&tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 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. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point New Emission Point GP05 123/9DD4/003 123/9DD4/003 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: Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Heath bEnvironment Dedicated to protecting and improving the health and environment of the people of Colorado 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 (Regulation Number 3, Part D, Section VI.B.4/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. Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division ''denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a ',cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Permit for two (2) produced water storage vessels at a synthetic minor oil and gas well production facility. Page 6 of 9 COLORADO Air Pollution Control Division Department of Pub'sic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible,? but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific -compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions ([b/yr) Controlled Emissions (lb/yr) Benzene 71432 1,017 51 003 Toluene 108883 969 49 Ethylbenzene 100414 29 2 Xylenes 1330207 296 15 n -Hexane 110543 2,325 117 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 5.63x10-2 2.82x10-3 Gas Analysis 71432 Benzene 1.69x103 8.47x10-5 108883 Toluene 1.61x10-3 8.07x10-5 1330207 Xylene 4.93x10'4 2.47x10-5 Page 7 of 9 COLORADO Air Pollution Control Division Department cif Public Health E; - Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 110543 n -Hexane 3.87x10-3 1.94x10"4 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 CS Scott 01-1-12 well. The results of the analysis provided a speciation of the flash gas, a gas to water ratio of 2.1 scf/bbl and a flash gas molecular weight of 32.3892 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 Synthetic Minor Source of: VOC, n -Hexane a Total HAPs PSD and NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 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 Page 8 of 9 COLORADO ! Air Pollution Control Division Department of Public: Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 0: Received Date: Review Start Date: Harrison Slaughter 386981 10/30/2'018 3/21/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc: County AIRS ID: 123 Plant AIRS ID: 9004 Facility Name: C Street Production Faqili Physical Address/Location: County: Type of Facility: Explo€ation,& Production Well What industry segment? Oil & Neterel Gas Pradttction& Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? LI Carbon Monoxide (CO) SWSE quadrant of Section 36, Township 6N, Range 66W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range Particulate Matter (PM) ❑J Ozone (NOx & VOC) SWSE 36 6N 66 AIRs Point #i Emissions Source Type Equipment Name Emissions Control? Permit it Issuance S Self Cert Required? Action Engineering Remarks 005 ; S aratOr Veptuig - -. ,. VRT Gas Combustion Yes .. 18W E11451. - 1 y "yes �ttiT7a� � latuattce Section 03 - Description of Project Extraction Oil & Gas, Inc, (Extraction) submitted an application requesting permit coverage for several sources at an existing synthetic minoroilas r n .andg wellpgd ctionfacility located in the ' ozone non -attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydracerbori loadout VRT venting, and separator venting. This preliminary analysis only addresses the VRT venting source. - - The VRTventing source zs APEN required because uncontrolled requested VOC emissions are greater than 1 tpy (Colorado AQCC Regulation 3, Part A, Section 11.5.3.5.). Addit€onally, 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, Season II.0.2.a.).: Public comment is required for this source because new synthetic minor limits are being established in order to avoid otherrequirements. 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? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes . 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 Yea NOx CO Is this stationary source a major source? N If yes, explain what programs and which pollutants herE SO2 NOx Prevention of Significant Deterioration (PSD) Title V Operating Perml2s (OP) Non -Attainment New Source Review (NANSR) VOC I PM2.5 PM10 TSP HAPs R O CO VOC PM2.5 PM10 TSP HAPs Bo O Separator Venting Emissions Inventory 005 Separator Venting 'Facility AIRS ID: 23 Coon' 9504 Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: EncFused Ca bysHai Devi Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Informationfor Emissions Estimates Requested Permit Limit Throughput :5 tl5H MMscf per year Requested Monthly Throughput = 0 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 3.8 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of wane gas emitted per BBL of liquids throughput __.. Section 04- Emissions Factors & Methodologies l Description 2682: Btu/sct All Weight% Hydrogen Sulfide Oxygen/Argon CO2 N2 methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n Hexane cyclohexane Other hex es heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes Cat Heavies 00 to 0: 0`17 2.73 i2 MENSIMMWA 22i 10..00 88' n 1.64 0. 2.06 0.00 0i . 0.02 Total VOC Wt % 100.00 53.8711 cf/bbl Ib/Ib-mol Displacement Equation Ex=Q•MW•X3/C Separator Venting Emission Factor Source Pollutant Uncontrolled Controlled (Ib/MMecf) (1b/MMscf) VOC - Elammimmomm''®t' ®' ®MiElll ffEEIN MINI= !E053 Pollutant PrimaryControl Device Emission Factor Source (Ib/MMBri( lb/MMscf (Waste Heat Combusted( (Gas Throughput) t l i l t 1 810073 31111 - Y / tom` e f 4-. .'. ' 51007610, M irm IL0006 3313 3 a0608 :6n v,3iti01l.�i, Ef: Heat Value Calculation Component LHV 15:gad) mole% HHV Kitt/srt: Water CO2 0 ;ii'dsrOOP e 52 0 „1rh 1291 1 C methane 539.4 rfiNifig647 1010 ethane 1613.; 4921037' 1769.7 propane 2314.8 .3992541i.> -l:. 2516.2 leobutene .3000.4 ��'5 b0'^. 3252 n hutan=_ 3010.8 311194.73' 3262.4 i500V::latne 2599. 11"1 4s52.4fA 4000.9 n -pentane a 70:6.9 : /higj69f% 4008.7 Cyclooentene 353.2 MaK5ta 3763.6 090:00ex=ne 4179.7 ..30.8640. 4481.6 Hempen (heating value of n=Hexane} 4403.8°. r.ifi 4756 heptsne„s 5100 15fifilififiEfitlg :502.5 Metlyl00O;oheXene 4863.7 1 0 5215.9 Octanes, 5796 fififitfiE4100 6248.9 Non8nes 6493.2 ,502 6996.4 Deoanes+ 71895 (lEE13:-Y5 = 7743 Benzene :590.9 0.0324;`:: 3741.9 Toluene 4273.7 f'. r!6i0569/? 4474.9 Ethylbenzene 4970.4 5111%fifififit.3j 5222 Xylenes'Avg ut o. rn. 0 xNene) 4057 =.= 199P20055l 5200.7 n -Hexane 3473.0 3lla P , ,,i 1756 224-`cov:LHV(HHV of isooctane) 17703 i3..+.i0:000'13i.>s 5231.6 H2S 556.0 /5i1ylAo'v 6371 99.9230 Lower Heating Value 0f Gas Higher Heating Value tr1 Gas 2419.550653 Btu/scf 2627.737333 Sty/act 2 of K:\PA\2018\18WE1145.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tans/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.038 0.006 0.006 0.038 0.038 6 0.038 0.006 0.006 0.038 0.038 6 0.003 0.000 0.000 0.003 0.003 1 0.35 0.05 0.05 0.55 0.35 59 196.80 31.07 1.55 196.80 9.84 1671 1.58 0.25 0.25 1.58 1.58 268 Hazardous Air Pollutants Potential to Emit Uncontrolled (hs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) Dim/year) Requested Permit Limits Uncontrolled Controlled libs/year) (Ibs/year) . Benzene Toluene Ethylbenzene Arlene n -Hexane 224 TMP 722.73 114.11 5.71 722.73 36.14 525,13 82.92 4.15 525.13 26.26 9.92 1.57 0.08 9.92 0.50 88.48 13.97 0.70 88.48 4.42 7693.05 1214.69 60.73 7693.05 384.65 134 0.21 0.01 1.34 0.07 Section 06 - Regulatory Summery Analysis Regulation 3, Parts A, B Regulation 7, Section 3311.6, G Regulation 7, Section XVII.6.2.e (See regulatory applicability worksheet for detailed analysis) Section 07- Initial end Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, The control device for this separator Is not subject to Regulation 7, Section X011.0.2.0 Does the company use site specific emission factors based on a =sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that theemission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are lessthan 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 lessthan or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value In section 03. Does the company request a control device efficiency greater than 95% 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 questlens don t require an answer. 3 of 5 K:\PA\2018\18WE1145.CP1 Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes 'meter:Wasins€dlled`atthisracT Iesaiespipeline. Thistldw mete:Pk ata fo,demanstfatewmplio rare installed andoperattonaiat aNtyieste were fieludedinthe 'and nonduct repairso[,2ant5 . dteef ftb+If?C'=10d;B58:93I0/MMto (i not matchxacftyttha,valutd provided So permitting purposes. Tile differences3rrtk Sal -1 the molar votumeofat liDet ,e 7 The aper0t r AIRS Point it 005 irtainei€direet(ytroen-tHA V@ lecalculationda notxnatalye iA0 Sdssets, tweisty welQII y these newwellswere{ra JfVII_6. Condit€0ns reffl'ey5 Process It SCC Code 01 3-30-000-60 Flares Section 09 - Inventory SCC Coding and Emissions Factors ntar weir At The Sipe eivedllacth td mmbuseto sAevlcn. mbustion device (E£o 6e suffisientfordemo hecksperthe operatingand°i Iryadthro ghtfiamti,+o"ds7. werefracturedin Au 000. Since newwells,we Pollutant Uncontrolled Emissions Factor Control % Units PM10 19.98 0 b/MMSCF PM2.5 19.98 0 b/MMSCF SOx 1.58 0 b/MMSCF N00 182.37 0 b/MMSCF VOC 103579.17 95 b/MMSCF CO 831.38 0 b/MMSCF Benzene 190.19 95 b/MMSCF Toluene 138.19 95 b/MMSCF Ethylbenzene 2.61 95 b/MMSCF Xylene 23.29 95 b/MMSCF n -Hexane 2024.49 95 b/MMSCF 224 TMP 0.35 95 b/MMSCF 4 of 5 K:\PA\2018\18W E1145:CP1 Separator Venting Regulatory Analysis Worksheet lSauna is.. Nor n Ma nn ant Aron Parma �nulmTtou ATTAINMENT L Ara uncontrolled actual amMlom ham crIhrla polka:an. from Mla IncEvIclual mama areatar than 211,N MegulatIonI1.01? 2 Ara NMI m umrlom ems.araater than smv,N aa<eater men laRYarCO emissions mrercam 10 my Menuatlan 3. Part B. MatIon EDS), 'Nat enough Information ?IONWEIAINMENr Ara encomial. ens horn anyonab polldnnahon this indmdual source greater Man 11py IRadatiom3, Part', Section II.O.1.alr 2 Pretotal balky uncontrolled VOCemmbm from Ma ',eater than2Wr,,NOe arena, Mans TIM oral emtsosgreatotan101Py IIMENME 13, Part 3,SeMann.u.21? 'Samoa n Colorado R.eul. en 2 Samba ggg 1. Was Ma wellrooIr aht2d.IOdmull¢II'yhacta., or,emmgeteal anon after August 1, 2010? son abiostte Re0*Atlan t,secrbntvl.e.2,G Sertbn%VII.62-General Pr,Aslam for Alr Pollution Coned Equipment and Prevention of ETluiore Etalon WIG -Emissions Cant. Mama.. n mmllolnbn.Isecllenl a. Is MN¢paretor controlled by abaak-up aalternate mmbmtianNEON ll.e.,notthe prlmaNaaMENdevl¢ltbatia rwten0med? Section %VII.&2e-Almrraam emission control equipment niscdimer This document assists operators win determining applicability cecenaln requinernentsbased arAct es implsme0firg regulations. end A -r Cam0TyContrd Commission regulations. This daW,rgus not endear �ulaticn, and Maamlysisi l..irs may ndyaWy Iva bio I? ere situation based yon tine incavaluel Awls aMdreunatarcas. This Eecunad Nos needle', orslislf Implementing arty law. regulation, or arty deer legally landingeag2rane t A**uy 0egally000Sthal. In the evert 2farryd1NiA2A. between the lerguegetlt00 document ad.laguagedIha Clean Air Ace. lA Implementig reuldors. and Armalty Cannel Commission rgularwnyme 2'rege of the srenxeormaul.. waken.. The use,rmnmanmtdry language arch as-raanmerq",IY."slard.'and•wan' is inland.. esenyAAFCO iNeryreuHos and rsan u2003hns.alanimootomlrsgWy sane as'mu,rl'review n are indreMEodeurd senneconlroning readnamerts r ire!armsd Air trod the Clean ar ponlay C ranICommission regulations. etis documaddms me esladlsh IegallY lancing mean:ne ats Inane easel,: Vas'Ilteu :Sourcemr aan APEM. Go to Mann question S'R"� ¢Rmdroapeamlt Soo¢boAjout go to matq¢stbn cant rd device fa MN separator Is not subject to ReguM,.7.,SectiantNl.0.2.e COLORADO Air Pollution Control Division Department of Pubtc Health F, £r>v ror rent Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1145 Issuance: 1 Extraction Oil Et Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: General Description: C Street Production Facility 123/9DD4 SWSE SEC 36 T6N R66W Weld County ell Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS . Point Equipment Description Emissions Control. Description VRT Gas Combustion 005 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, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. Page 1 of 9 COLORADO Air Pollution Control Division Department of Public:Heatth &- Env ironment Dedicated to protecting and improving the health and environment of the people of Colorado 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.Qov/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 Divisionas 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.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO VRT Gas Combustion 005 --- --- 9.9 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 9 COLORADO Air Pollution Control Division Departrnent of Pubic Heath & Etwirortrr: rera Dedicated to protecting and improving the health and environment of the people of Colorado 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 005 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 Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT Gas Combustion 005 Natural Gas Venting 3.8 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 shall 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 operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation Page 3 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 £t MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OFtM) 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 I I I.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. Thissource 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 change in Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Heath & Enviroornent Dedicated to protecting and improving the health and environment of the people of Colorado 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 VI.B.4/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 IIB. 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. Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Heatltb &Ertvironmere Dedicated to protecting and improving the health and environment of the people of Colorado 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 iii 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 Et Gas, Inc. Permit for natural gas venting from two (2) vapor recovery towers at a synthetic minor oil and gas well production facility. Page 6 of 9 COLORADO Air Pollution Control Division Department cf Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder 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 005 Benzene 71432 723 37 Toluene 108883 526 27 Ethylbenzene 100414 10 - 1 Xylenes 1330207 89 5 n -Hexane 110543 7,693 385 2,2,4- Trimethylpentane 540841 2 0.1 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. Page 7 of 9 COLORADO Air Pollution Control Division Department of Public Heeitb 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 005: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source VOC 103, 579.17 5,178.96 Gas Analysis 71432 Benzene 190.19 9.51 108883 Toluene 138.19 6.91 110543 n -Hexane 2,024.49 101.22 Note: The controlled emissions factors for this point are based on the enclosed combustion device 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 90° F and 4 psig respectively. The VOC and HAP emission factors were determined using the weight % values and gas molecular weight (46.8418 lb/lb-mot) from the gas sample analysis in conjunction with the `EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). 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 tater than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this, permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane Et Total HAPs PSD and NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z Page 8 of 9 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package It: Received Date: Review Start Date: Harrison Slaughter 384581 10/30/2015. 3/26/2019 Section 01- Facility Information Company Name: Extraction Oil &as; inc. County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: SWSE quadrant of Section 36, Township 6N, Range 66W County: Weld County Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) 9DD?tk C Street Production..Facllitt„j Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SWSE 36 6N Particulate Matta (PM) E✓ Ozone (NOx & VOC) AIRS Point# Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cart Required? Action Engineering Remarks l 006 dill " C :.. -- 3113b LP Gas Combustion Yes. . 18WE1146 1: iT :Yes e nit Initial ssuance! Section 03 - Description of Project Extraction Oil & Gas, Inc. (Extraction) submitted an application requesting perm oVeIage for several sources at an existing syntheticetic minoroil and gas well production facility local ozone non -attainment area With this application, the operator is requesting pe l: CoVerage for condehsate storage vessels, produced water storage vessels, hydrocarbon loadout, venting, and separator venting.. This preliminary analysis only addresses the low pressure separator venting source. The low pressure separator venting source. is APEN required because uncontrolled requestedVOC emissions are greater than 1. tpy (Colorado AQCC Regulation 3rP Addiitionaliy, the source_ is permit requiredbecause uncon trolled VOC emissions from all APEN required sources at the facilityare- greater than 2 tpy (ColoradoAQCtrl Section p.R2.a.). Public comment is required forhissource because new synthetic minor limitsarebeing established in order to avoid other requirements. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting sq 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 (P5D) 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) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs PM2.5 ❑ ❑ PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory 006 Separator Venting IFacllity AIRs ID: Plant Point Section 02 - Equipment Description Details ncCos dCombustfph Emission Control Device Description: _ Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Separator Actual Throughput =:-,,`.. yT'm-':�31,','a',1,':,"�-'�i'•i''- MMscf per year Requested Permit Limit Throughput =lilliikligiFiSill344i3A&& MMscf per year Requested Monthly Throughput = MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment 15.0 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is. bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions- Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted pr BBL of y5' liquids throughput: Section 04- Emissions Factors & Methodologies 1'; '' 2859 Btu/scf scf/bbl Description rwert 20 o.ly I throe It": Uri _. y( ) culls produce to:went; 20) inlet high -low pressure sepamtors.G from the law pea uesldedt the sepetnrdrbl typically routed to pipeline tfiroug$the to ate VRU. Outing VH combustion devlceis) on1 cation. A gas sample was obtained from the outlet of the low pressure separators on 09/18/2018: Thosample temperature and pressure ..re 904°P.and 50 psigrespeo MW 7.2637 eigh Hydrogen Sulfide O CO2 612 methane ethane propane Isobutane n -butane pentane n -pentane 6.14 cyclopentane 0.28 n -Hexane cyclohe Other hexane tartane methylryclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C6t Heavle gen/A 0:00 2 2.35: 0:93 9:89. 6169 .1..06 5.51 3.24 2.58 0.68 one 3.89 2.17 0:85 .00 0.29 0.58 .02 0'.25 98 Total VOC Wt % 00.00 64.8866 Ib/Ib-mot Displacement Equation =Q MW MWXx/C Pollutant VOC Separator Venting Emission Factor Source MENNINETEI =UM= Pollutant 126.8044 0.0461 Primary Control Device Uncontrolled (Ib/MM Btu) (Waste Heat Combusted) Uncontrolled Ib/MMscf 0.0075 .....0.0075 0.0680.'2.,222, 0 3190 (Gas Throughput) Emission Factor Source 85 Heat Value Calculation Component L.HV (Btu/r? -.. HNV (BoWsei) Water 0 0_J. D 002 0 1.9923 -.': 0 92 0 12394 ;: I methane 900.4 34.5873 ':'. 1010 ethane 1618.7 : 20.6837. : 1769.7 prbp010 2314.9 '177952,;': 25162 Iebb5tane ;000.4 5' 3.5304 _ 5262 n -butane. 3010.0 8.9802.:::: 3262`4 saneo:Tdn2 36999 :: 2.7653'. -:. 4000.9 n -pentane 37064 3.1717 4008.7 CycyuPentane 3512 0.1501'. 3763.6 CyciohoX.ne 4179.7 0.3018 4481.6 Hexaneslhealn0Yam ofn-Hexane) 4403.6 1.6822 >. 4755 hent-ates 5100 0.807 5502.5 Mel-uu(m.oheXane 9163.7 0.3229 'i' 5215.9 Octanes* 5796 0.3976 :: : 6248.9 010:1anes. 6-107.'2 0.0629 '':': 6995.4 De0anesn 7189.5 0.142 ''. 7743 Benzene 3650.6 0.1387 ''' 3741.5 Toluene 4273.7 0.233 i 4974.9 E8rylbenzene 4970.1 >- 0.0035-i1'. 5222 Xylenee (Avg at o, in, p xylene) 4957.3 0.0882 '!'' 5208.7 it -Hexane 440.3.8 1 162 4756 224 -PAP iLHVIAHV of isoc9tenel 5778.5 0.0003 -' 62'61.6 925 •586.:9 0 627.1 Lower Heating Value of vas Higher Heating Value of Gas 1897.897968 Btufett 2067.278629 8tuject 2085 K:\PA\2018\18WE1146.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tans/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.117 0.040 0.040 0.117 0.117 20 0.117 0.040 0.040 0.117 0.117 20 0.009 0.003 0.003 0.009 0.009 2 1.07 0.37 0.37 1.07 1.07 181 478.11 163.67 8.16 478.11 23.906 4061 4.87 1.67 1.67 4.87 0.87 826 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year] Actual Emissions Uncontrolled Controlled (Ito/year) Ohs/year) Requested Permit Limits Uncontrolled Controlled (Ws/year) (Ibs/year) Benzene Toluene Ethylbenrene Xylene n -Hexane 224 IMP 4285.76 1467.16 73.36 4285.76 214.29 8490.17 2906.47 145.32 8490.17 424.51 357.98 322.55 6.13 357.98 17.90 3704.02 1268.01 63.40 3704.02 185.20 38041.31 13022.81 651.14 38041.31 1902.07 13.84 4.74 0.24 13.84 0.69 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section 3111.8, G Regulation 7, Section 3011.8.2.0 (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source Is subject to Regulation 7, Section KVII.8.2, G The control device for this separator Is not subject to Regulation 7, Seddon CVil.0.2.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, lithe facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collecta 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 equalto the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than err equal to 90 tons per year? f _ 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 fags established with this appjicatt n. -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 to calculate gas throughput using the liquid throughput until the meter is Installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% fora flare or combustion device? If yes, the permitwill 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 se answer. loll K:\PA\2018\18W E1146.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Not 1 Based on the p I '.a flowmeteiii sailed artity omeasu th t £y f h u separator gasventedaed eoiltedta tG encio ed cambustl n- device. Thisftaw x0580 facility that a• 9t8.4,F8,4,8-W.- meterpressute sepa afar gasand rout ICY the p p e n 010w thus s d t measure fetelilaw peenstae sep_5ratergas that Ferooted to ihsendoset location,to operator will treed ck IfU dodo 6u# ion wife flow meter data to demonstratecompliance with the permit limns. Theflost measured'by thetlowmotnrwJlB 2, The applicator indicates the flow meters5 - 5doperatl sal, --8. Nether initial nor perodicm thod22 ooa iq'ie'sis vereiaeluded-m the peen it hocausethe operator is required to do weekVveible emi'sslons cheeks perthenperating and maetenanceplan. in the 000etvu{ble� to either shut in the equipment mme2atelyandconduct repo s of conducf oformal method 22 opacity tactln theeventvsrbin a observed throughdlamettod:22, theopera£oricraquired to tmmeth:" nsar epa Ire cannot be co nddeted mmedatey Since hiss amore bust on -gong eomplancedem nstration than acme -time method 22 thicinitaicompliaeae"d moostradoh iseabeoreaeary lethe permltAddlYioda .subsequentrequ rementa if visible emissions are observed is soffit en.:on gomg comp) ante d reonstratoryso periodic method 22 opacityteating s not requ red inthe permit -- 4, The heatcontent used to calculate NOx and CO emissione_w bt ed dir ctly room the g pie provided in she application The haat content calculation presented in this analys content based on waste gas mole%values_The-eesnitoofthe: pl Iculationd not match actlywith the:Value used from the gas sample - - 5. Based an the APES provided for drilled and tarought onl mein 2018 Based an-COGCC da iiisepanation-dquipment u subject to Regulation 7, Se* 6. In this analysis, the standard equation to olculate emissfasi' a� calculated (J 405 =63,797.22 Ib/MMscf, fill BeMen= o2059.. factors do not match exactly to the valuesprovided by the ope for permitting purposes. The differences in:th icuiet ono ap match, the molar volume of an Ideal gas was adjusted in the _T. The operators Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point it 006 Process it SCC Code 01 0-10-001-60 Flares st g wells that produce to this facility were fro h 2008 and be ran production in August 2018, S nc0 d I n the permit,:i: elghtr% (pollutant x17n100)"s37.20371b/ltemol1/1270 cot/tlis ardene=2384 ih/MM5of, Fl Xylehe = 2a7.o8lb//IMsct,4 n thevoloesealcutated using tnestandard equdtan and the values calculetol (ant mole ular. eghts toconvertfrom noneto weight % and the e of mriar nts mid expressed they had no comments. Feel prodoct'ae In Sepeeml:er2 Impieaed-at the facility after0 Moc�_Usl gthls equation, thetk b(MMscf, and fs l224TMP=(L t,egiigible. ho a result, the opera1 -noel rather than 379 sof/lb-reef. Pollutant Uncontrolled Emissions Factor PM10 15.59 PM2.5 15.59 500 1.23 NO0 142.30 VOC 63748.08 CO 648.74 Benzene 285.72 Toluene 566.01 Ethylbenzene 23.87 Kylene 246,93 n -Hexane 2536.09 224 TMP 0.92 Control % Units O b/MMSCF O b/MMSCF O b/MMSCF O b/MMSCF 95 b/MMSCF O b/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 95 b/MMSCF 4085 K:\PA\2018\18WE1146.CP1 Separator Venting Regulatory Analysis Worksheet ISurm Parrs Aand a- APEN and Parmp Renuln'mmna n the No m-Atm mment Area ATTAINMENT 1. Are uncontrolled actsal emissions from any criteria polupnts from Nls Individual source greater than 21PY iReaMatlon 3, Part A,secuon f Il.o.i.ali 2. Are total lOlltyunamtroled POC emissions greater Nan 5mV, NOz greater than 10TPY or greatrthan 10 TPT fliegrlatlon 3. Part B. Section li.031i h iMomnetlon 1 Are rolled emhaions from any olterla pdim s Individual source greater Nan 1TAY (Regulation%Part A,Sectlon R.O.ia)J 2 Aretotal facility uncontrolled VOCemislons from the greater than 2 TAY, Not greater than 5 TOY w on emisslmsgeater than 10 TAY (Regulallon3, Part B,Sectlon Il.O.212 'Son r trims a a It Cobmao goggle -don J. Section %1nI 1 washaW Il newly constructed, hyrauiam 'Sourcen lvfmatured, or on or after August 1, 20142 Sectionitv- fforAlr Pollution ControlEquipmentand Prevention d Emissions Snctbn%We-Emissions control Somme Paquin. anAPEN. no to the next question Source Paquinpermit [AS ,`4Source issubject go to neat yuestIon Emlaalore CorArol factional 5eNont a, nIs Nlzxpaanrcontrolled ova back-up or alternate wmhustlondevIceMe.,notthe primary coned device) that rs not enclosed] contra, de+rcefotMzxparatw is notsubjec[m PegWagon J, ft ionlMl.e.2e Th to Rueumu 1, 5nmen%VII8.2.o Sctbnr apez.e-Alternagw emissions controlequlpmere Disclaimer thrsaaamentessists opeai«swith?¢termingappliea(iify cram fain requirements or the Clean NrAct Ps implementing regdafw», and AfrOuwiifycorAM Commission regulations. this dmummtis not a rule arrwutafim, aqd Me analysis it contains may Wan* to a particular situation based spangle iMrvldllral foots and circumstances. This document does not changed subs"... any law, regal -agar; or any star all bindingrequirement and is nor legally enforceable. In the event denycw"kt between Me language erMis d¢ume,t amide laguagedthmClean Air Act, ihimplemmerg regulations, and Ainwisiry Control Commission regulations, Ina language ofIhest.. mmulahonwill central. Tile use ofnon-mandate y language such as'recernmeM."may,"should' and Man," is intender describeAPCD ineryrem5oss aM reconmerdations. Mancawrytennlnalgy such as "must- and 'required. are Intended to describe controlling requirements wader Me lemns elMe Clean AlrAct and AM Qualify Control commission r55ula1ons, but fns cbcume. rice, Trot es.bl.sh Dally binding regWlemechs in ad d4selr. COLORADO Air Pollution Control Division Department of Public Health 8 Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1146 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc.` C Street Production Facility 123/9DD4 SWSE SEC 36 T6N R66W Weld County Well Production Facility Equipment or activity subject to this perm Facility Equipment ID AIRS Equipment Description Point Description Emissions Control LP Gas Combustion 006 Low pressure ' natural gas venting from twenty (20) low pressure separators. 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, 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.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 I Air Pollution Control Division I Department ct ?Wit. Health c ErMrch ent 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.eov/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 HI 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. VOC CO LP Gas Combustion 006 --- 1.1 23.9 4.9 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for 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 Heatth 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 006 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 006 Natural Gas Venting 15.0 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 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 Aar Pollution Control Division ^aranMent a# P s€ -Ai Hean c Environment 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 a MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject . to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, 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 ne^artencr(PuNi; Me3ithb. Ea+rircnrant. 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 is 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 VI.B.4/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. IC©LORADO Air Pollution Control Division ^rrartrnent Qf Public Meth h E renree..t. 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(Aon grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQ.CC), 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 This Issuance Issued to Extraction Oil Et Gas, Inc. Permit for natural gas venting from twenty (20) low pressure separators at a synthetic minor oil and gas well production facility. COLORADO Air Pollution Control Division 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 it, 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 Benzene 71432 4,286 215 006 Toluene 108883 8,491 425 Ethylbenzene 100414 358 18 ''Xylenes 1330207 3,704 186 n -Hexane 110543 38,042 1,902 2'2'4 Trimethylpentane 540841 14 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 006: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 142.3 142.3 AP -42 Chapter 13.5 COLORADO Air Pollution Control Division Gwrart:nenc 09 ?'ti31ii;�. h ai2F # Fnriron V CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source CO 648.74 648.74 AP -42 Chapter 13.5 VOC 63,748.08 3,187.4 Gas Analysis 71432 Benzene 285.72 14.29 Gas Analysis 108883 Toluene 566.01 28.3 Gas Analysis 100414 Ethylbenzene 23.87 1.19 Gas Analysis 1330207 Xylenes 246.93 12.35 Gas Analysis 110543 n -Hexane 2,536.09 126.8 Gas Analysis Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 95%. The VOC 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 104°F and 50 prig respectively. The VOC and HAP emission factors were determined using the weight % values and gas molecular weight (37.2637 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 NO; 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 2,092.7019 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 Synthetic Minor Source of: VOC, n -Hexane Et Total HAPs PSD and NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z COLORADO Air Pollution Control Division Dnpartrnvtt Publt^ Healthc Fnvi n.mf,^.t. 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 f.iwoofffroot r.# % Nis'.. Ne:at-ft c E'xn:s,^r,'v;rrr Page 9 of 9 C Street Liquid Loading APEN Hydrocarbon Liquid Loading APEIST3(} 1J1 Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0812 AIRS ID Number: 123 / 9DD4 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. C Street Production Facility Site Location: SWSE Sec 36 T6N R66W 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 alt 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. 389577 ,ctotxAaa Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I C Street Liquid Loading APEN Permit Number: 15WE0812 AIRS ID Number: 123 / 9DD4 / 002 [Leave blank unless APCD has already assigned a permit rt and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment Change company name3 ❑✓ Change permit limit O Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Please issue permit modifications for hydrocarbon liquid loading permit # 15WE0812. 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: 8/1/2018 Will this equipment be operated in any NAAQS nonattainment area? Yes No 12 • 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 ■ NI Is this source located at an oil and gas exploration and production site? Yes No p ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • p Does this source splash fill less than 6750 bbl of condensate per year? Yes No • 4 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 21 Permit Number: 15WE0812 C Street Liquid Loading APEN AIRS ID Number: 123 / 9DD4 / 002 [Leave blank unless APCO has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 126,299 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 105,249 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: N/A Average temperature of bulk liquid loading: N/A °F True Vapor Pressure: N/A Psia ® 60 ° F Molecular weight of displaced vapors: N/A lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year Product Density: N/A lb/ft3 Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I C Street Liquid Loading APEN Permit Number: 15WE0812 AIRS ID Number: 123 1 9DD4 1 002 [Leave blank unless APCD has already assiened a permit # and AIRS ID] Section 5 - Stack Information 40.438965, -104.723218 N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) O Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) O Circular Interior stack diameter (inches): O Other (describe): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: % Used for control of: VOC, HAPs Rating: MMBtu/hr Combustion Device: - Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% % Minimum Temperature: °F Waste Gas Heat Content: 25c1Lt Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: MMBtu/hr Type: ECD Make/Model: ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: (-sco S o'51t,� Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I C Street Liquid Loading APEN Permit Number: 15WE0812 AIRS ID Number: 123 / 9004 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information 40.438965, -104.723218 e N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): O Other (describe): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOC, HAPs Rating: Type: ECD MMBtu/hr hr Make/Model: Requested Control Efficiency: 95% Manufacturer Guaranteed Control Efficiency: 98% % Minimum Temperature: °F Waste Gas Heat Content: 2_Sq►.1_ Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I (4 DS O 1 �CfiLBR.#I}s7i awsrocaNils Permit Number: 15WE0812 C Street Liquid Loading APEN AIRS ID Number: 123 / 9004 / 002 '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): V �s� � PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: ❑✓ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑✓ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL O 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 --o ,� }s} �', u F �� tea' PM SOX NOX CO VOC 0.236 lb/bbl PS Memo 14-02 12.419 - 0.621 - 14.903 - 0.745 . Benzene 71432 Toluene 108883 Ethylbenzene Xylene n -Hexane 100414 1330207 110543 0.0036 • lb/bbl PS Memo 14-02 378.896 • 18.945' 2,2,4- Trimethylpentane Other: 540841 5 Requested values will become permit limitations. Requested timit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 51 co okdac; C Street Liquid Loading APEN Permit Number: 15WE0812 AIRS ID Number: 123 / 9DD4 / 002 [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. ItD Y%3 Signa of Legally Authorized Pe on (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 E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-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.Rov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 'COLORADO! Ikpoionet4Polic- mmeam C Street 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 tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: (�WEIfq-3 AIRS ID Number: 123 / 9DD4 / 001 [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: C Street Production Facility Site Location: SWSE Sec 36 T6N R66W Mailing Address: (include zip code) 370 17th St. Suite 5300 Site Location County: Weld NAICS or SIC Code: 211111 Denver, CO 80202 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 389575 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1 I Ilepriamt it POW 0CT30 2618 C Street Condensate Tank APEN Permit Number: 11)06 IN -13 [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 123 / 9DD4/ 001 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) O Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 0 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 £t Notes: Please issue individual permit for Condensate Tanks. Previously permitted under GP01. Please cancel GP01 to be replaced with this permit. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Storage of Condensate at E&P Facility. For new or reconstructed sources, the projected start-up date is: 08/01/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration a Production (E&P) site 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? O Yes ■ No Are Flash Emissions anticipated from these storage tanks? 17 Yes • No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? 12 Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: p. 1,,, m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No SI • Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualSI emissions ≥ 6 ton/yr (per storage tank)? Yes No • caipk0,na Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 2 I C Street Condensate Tank APEN Permit Number: teb'1y2 AIRS ID Number: 123 / 9DD4 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information 2,593,234.20 to hT egt 2,161,028.50 From what year is the actual annual amount? Projected Average API gravity of sales oil: 54.5 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 12.5 ❑ External floating roof �ia ti a d3Sto e Ves e s StT n1 ��, o a Vo ...�4,. _,,.:'� a for Date o�lc ≥i i a anoT±#hr � Via... __ , �- D mo Y N/A 8 x 400 bbls 3200 Before 8/2018 8/2018 We see cce b is�ag� [ r I x --a 1 �� Re oLLal-7 t See Attached II ■ I ■ IN 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 40.438965, -104.723218 W67.--- t '`sue₹ rte- N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) Interior stack diameter (inches): Unknown ❑r Circular ❑ Square/rectangle 0 Other (describe): ❑ Upward with obstructing raincap Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I C Street Condensate Tank APEN Permit Number: l$tOE1143 AIRS ID Number: 123 / 9DD4 / 001 [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: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr Make/Model: 95% % 98% % Waste Gas Heat Content: Constant Pilot Light: E Yes ❑ No Pilot Burner Rating: 2 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP separator, Vapor Recovery Tower Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 I C Street Condensate Tank APEN Permit Number: AIRS ID Number: 123 / 9DD4 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction ): 01� � � z � DQsLI' �firr o[ h@'® � % raIt1 eq` rested Contro Efficiency uctson sn emwssxo�. VOC ECD 95% NOx Co HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected 124.151 ' 6.208 . 148.981 • 7.449 - VOC 0.1149 lb/bbl Site Specific Sampling z�a nssions NOx CO 0.31 . lb/MMBtu AP -42 Chapter 13.5 1.036 • 1.036 . 1.243 . 1.243 ' L T SSl0 *aa . > �t�s © . ....s,�-..? isstor� .i Benzene 71432 0.0001839 • Ib/bbl Site Specific Sampling 397.413 ' 19.871 . Toluene 108883 0.0002459 • lb/bbl Site SpecificSampling 531.397 • 26.570 • Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.002629 • lb/bbl Site Specific Sampling 5,681.344 ' 284.067 • 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. C*4..0ar,na Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 I C Street Condensate Tank APEN Permit Number: 1tt II45 AIRS ID Number: 123 / 9DD4 / 001 [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. I ° 11 91)\ Sign Legally Authorized Person (not a vendor or consultant) Date 0a re of Le a Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www. colorado. Roy /cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 61 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form1 Company Name: Extraction Oil & Gas, Inc. Source Name: C Street Production Facility Condensate Tanks Emissions Source AIRS ID2: 123,/ 9DD4 / 001 e ‘Pc \"7\ Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 42937 ' CS BITTERSWEET 03-01-13 ►1 05 - 123 - 42936 . CS BITTERSWEET C01-01-13 /1 05 - 123 - 38819 . CS KINKADE 01-01-13 ►1 05 - 123 - 38818 CS KINKADE 02-01-13 ►1 05 - 123 - 38823 • CS KINKADE 03-01-13 ./ 05 - 123 - 38822;311p CS KINKADE 04-01-13 /1 05 - 123 - 38816 , CS KINKADE 05-01-12 ❑ 05 - 123 - 42915 ' CS KINKADE C06-01-13 ►1 05 - 123 - 42916 • CS KINKADE C08-01-13 .1 05 - 123 - 42476 CS LONGMEADOW 01-01-13 .1 05 - 123 - 42475 ' CS LONGMEADOW 02-01-13 .1 05 - 123 - 38821 ,. CS SCOTT 01-1-12 ❑ 05 - 123 - 38824 • CS SCOTT 02-1-12 ❑ 05 - 123 - 38813i3881.4Misa. CS SCOTT 04-01-13 .1 05 - 123 - 38820 . CS SCOTT 05-01-13 ►1 05 - 123 - 42908 . CS SCOTT CO2-01-13 .1 05 - 123 - 42914 CS SCOTT C04-01-13 .1 05 - 123 - 42911 . CS SHERWOOD 01-01-13 a 05 -123 - 42909 • CS SHERWOOD 02-01-13 .1 05 - 123 - 42912 CS SHERWOOD 03-01-13 .1 Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 Condensate Tank Addendum C Street Produced Water Tank APEN Produced Water Storage Tank(s) APEN - Form APCD-207 3113° 76% 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.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) wars. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID / gDD4 / Number: 123 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: C Street Production Facility Site Location: SWSE Sec 36 T6N R66W 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. 389576 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 I catae�oni alhilIve C Street Produced Water Tank APEN Permit Number: 146(14�{ [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 123 / 9DD4 / 003 Section 2 - Requested Action O NEW permit OR newly -reported emission source ▪ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑ .MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit 0 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 a Notes: Please Issue individual permit for produced water tanks. Previously permitted under GP05. Please cancel GP05 to be replaced with this permit. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Storage of Produced Water at E&P Facility. For new or reconstructed sources, the projected start-up date is: 8/1/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ✓❑ Exploration a Production (EEtP) site 52 weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS •nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ../ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes ❑ No ✓ Are you requesting a 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 Aar COLORAO _$- C Street Produced Water Tank APEN Permit Number: AIRS ID Number: 123 / 9DD4 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information used'', ater Through 261,745 600,000 From what year is the actual annual amount? Tank design: Before 8/2018 8/2018 N/A ❑✓ Fixed roof 2 x 400 bbls Projected ❑ Internal floating roof 800 ❑ External floating roof an See Attached CI 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 40.438965, -104.723218 era S c s a o, Unknown Unknown Unknown N/A Unknown Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Horizontal Downward El Other (describe): ❑ Upward, with obstructing raincap Indicate the stack opening and size: (check one) ElCircular Interior stack diameter (inches): Unknown ['Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3 I caiaanna or riaie Permit Number: C Street Produced Water Tank APEN AIRS ID Number: 123 / 9DD4 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 9$% Minimum Temperature: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Waste Gas Heat Content: U- Btu/scf tics \�, MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (Eat) 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 •tOtOkAt. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4 I`Ithi'`•ikaRMANIMINP " • C Street Produced Water Tank APEN Permit Number: AIRS ID Number: 123 / 9DD4 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected lb/bbl 7.368 • 0.368 - 16.891 0.845 VOC 0.056 " Site Specific Sampling NOx Co 0.001694 - lb/bbl 443.266 22.163 Benzene 71432 Site Specific Sampling Toluene 108883 0.001614 • lb/bbl Site Specific Sampling 422.373 . 21.119. Ethylbenzene 100414 Xylene 1330207 0.000493• lb/bbl Site Specific Sampling 129.109. 6.455 • n -Hexane 110543 0.003874 • lb/bbl Site Specific Sampling 1,014.044 • 50.702 • 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. c+taa,.na Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 C Street Produced Water Tank APEN Permit Number: AIRS ID Number: 123 / 9DD4 / 003 [Leave blank unless APCD has already assigned a permit ft 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. x) /fir t) Signa a of Legally uth ►zed 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 I✓ 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 COLORk6d Deprimmt Mac E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Extraction Oil & Gas, Inc. Source Name: C Street Production Facility Produced Water Tanks Emissions Source AIRS ID': 123 I 9DD4 / 003 \\D-2 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 42937 CS BITTERSWEET 03-01-13 a 05 -123 - 42936 CS BITTERSWEET C01-01-13 /1 05 - 123 - 38819 CS KINKADE 01-01-13 .1 05 - 123 - 38818 CS KINKADE 02-01-13 .1 05 -123 - 38823 CS KINKADE 03-01-13 .1 05 -123 - 38822 Mil. CS KINKADE 04-01-13 ►1 05 -123 - 38816 CS KINKADE 05-01-12 ❑ 05 - 123 - 42915 CS KINKADE C06-01-13 I1 05 - 123 - 42916 CS KINKADE C08-01-13 /1 05 - 123 - 42476 CS LONGMEADOW 01-01-13 .1 05 -123 - 42475 CS LONGMEADOW 02-01-13 ►.1 05 -123 - 38821 CS SCOTT 01-1-12 ❑ 05 - 123 - 38824 CS SCOTT 02-1-12 ❑ 05 - 123 - 38817'3q%u CS SCOTT 04-01-13 �1 05 - 123 - 38820 CS SCOTT 05-01-13 05 -123 - 42908 CS SCOTT CO2-01-13 ►1 05 - 123 - 42914 CS SCOTT C04-01-13 ►1 05 -123 - 42911 CS SHERWOOD 01-01-13 05 -123 - 42909 CS SHERWOOD 02-01-13 /1 05 -123 - 42912 CS SHERWOOD 03-01-13 /1 Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 PW Tank Addendum C Street VRT Gas Venting APEN Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/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 W E i ( y'S AIRS ID Number: 123 / 9DD4 / OOS [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: C Street Production Facility Site Location: SWSE Sec 36 T6N R66W Mailing Address: 370 17th St. Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211 111 Contact Person: Phone Number: 720-354-4579 E -Mail Address2: cnelson@extractionog.com Catie Nelson 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I 389578 C Street VRT Gas Venting APEN Permit Number: t'-€ tlyS" AIRS ID Number: 123 / 9DD4 / [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 a Notes: Please issue individual permit for VRT Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of VRT Gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 8/1/2018 ✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year Yes Yes Yes Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I ❑ No 0 No ❑ No Isom. terreavram C Street VRT Gas Venting APEN Permit Number: tc6c,OE1tt-ts AIRS ID Number: 123 / 9DD4 / ObS- [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 2681.886 BTU/SCF Requested: 3.800 MMSCF/year Actual: 0.600 MMSCF/year -OR- Requested: NA bbl/year Actual: NA bbl/year Molecular Weight: 46.8418 • VOC (Weight %) 83.871 • Benzene (Weight %) 0.1540. Toluene (Weight %) 0.1119 • Ethylbenzene (Weight %) 0.0021 . Xylene (Weight %) 0.0189. n -Hexane (Weight %) 1.6393 . 2,2,4-Trimethylpentane (Weight %) 0.000'' a� *A Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 tcttM as wommetanwhe C Street VRT Gas Venting APEN Permit Number: 4 CZEI 11-1AIRS ID Number: 123 / 9DD4 / 005 — [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 5 - Stack Information 40.438965, -104.723218 ,� .� �� . ��. -.�.. '>>��._ _ a _ �_ -.�� .� .� N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ 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: 0 Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature: Waste Gas Heat Content: Btu/scf 7cp-bl.ct Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: totokAoto Form APCD-211 - Gas Venting APEN - Revision 7/2018 4 I °n ?,CCV".s.L ( C-WkCC&AOOV • E-I�`� () 1t,s[ll C Street VRT Gas Venting APEN Permit Number: t�6 1 at—tt S [Leave blank unless-APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 123 / 9DD4 / ooS 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): ol1 . a De i® D,� r0 t ads 3Y �t..,.._...e __:-- � _ 'i '� Overall Requeste Control Eft c-jency y ieductiokil liilSsion5 PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected PM SOX NO. CO 0.310 Ib/MMBtu AP -42 Chapter 13.5 0.249 - 0.249 • 1.580 - 1.580 VOC 103, 579.173 Ib/MMscf Site Specific Sampling 31.074 1.554 ' 196.800 9.840 - 190.191 - Ib/MMscf 114.115 • 5.706 • Benzene 71432 Site Specific Sampling Toluene 108883 138.190' Ib/MMscf Site Specific Sampling 82.914 ' 4.146 • Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,024.490 Ib/MMscf Site Specific Sampling 1,214.694 . 60.735 2,2t4- 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. a1_oeAaa Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 I C Street VRT Gas Venting APEN Permit Number: ISgcZChNS [Leave blank unless APCD has already assigned a permit #t and AIRS ID] AIRS ID Number: 123 / 9DD4 / COS — Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Oti I (j111 Signature of L gaily Aut -i d Person (not a vendor or consultant) Catie Nelson I613 .10% Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: 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: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I =MM. tlalliMIMION ecstORADa• 1HIVEL OCT 302018 C Street LP Gas Venting APEN Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/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 5WE I I / AIRS ID Number: 123 / 9DD4 / 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: C Street Production Facility Site Location: SWSE Sec 36 T6N R66W 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. 389579 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I swami hl61aki- Si R C Street LP Gas Venting APEN Permit Number: AIRS ID Number: 123 / 9DD4 f6UJC [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership4 0 Other (describe below) - OR 0 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: 8/1/2018 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 Yes Yes Yes Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I ❑ No ❑✓ No ❑ No d6lOftAOes C Street LP Gas Venting APEN Permit Number: `gatZE1 �b AIRS ID Number: 123 / 9DD4 / ookD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing D Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 2092.702 BTU/SCF Requested: 15.000 MMSCF/year Actual: 5.135 MMSCF/year -OR- Requested: N/A bbl/year Actual: N/A bbl/year Molecular Weight: 37.264 - VOC (Weight %) 64.887 • Benzene (Weight %) 0.2908. Toluene (Weight %) 0.5761• Ethylbenzene (Weight %) 0.0243- Xylene (Weight %) 0.2513 - n -Hexane (Weight %) 2.5814 - 2,2,4-Trimethylpentane (Weight %) 0.000`l Additional Required Information: { 1 ids Ol l uo I la\ ❑✓ 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 APED -211 - Gas Venting APEN - Revision 7/2018 31 INparlmmt cDiOkADCr C Street LP Gas Venting APEN Permit Number: t %,LO lo -043 [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 123 /9DD4/ Section 5 - Stack Information phica ordfna 40.438965, -104.723218 N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 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: % % 0 Combustion Device: Pollutants Controlled: Rating: Type: VOC, HAPs ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% Minimum Temperature: Waste Gas Heat Content: LogZ k 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 ` 4 I d\\: ,.'C, ct-)( 61 -Wk i CCt` c) . “D5 dal Zto C Street LP Gas Venting APEN Permit Number: ,S (.10E, tAket AIRS ID Number: 123 / 9OD4 1 ocKt) [Leave blank unless APCD has already assigned a permit ei 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 efficienc%reduction): U ta t� a � � —� Descr tton 4 -tint ---, o � �, a ,. (3 ecall �3e Haste b (ice uc, intrr,raissto2$ PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected PM SOx NO. 0.068 ' Ib/MM Btu AP -42 Chapter 13.5 0.365 0.365 . 1.067 - 1.067' CO 0.310 - Ib/MMBtu AP -42 Chapter 13.5 1.666 • 1.666 4.866 - 4.866 VOC 63,748.076 lb/MMscf Ste Specific Sampling 163.681' 8.184 ' 478.111' 23.906 - „ � i �e, n tale Ua a i ss o. flyentooa� � ` e ea a en3tc ll _� issIM,-- r��.,_ gat E r z3tr _ urc s „ ef me t o n lie rst7 sf e Benzene 71432 285.717 • Ib/MMscf site speclficsae,pling 1,467.223- 73.361 - Toluene 108883 566.012.. Ib/MMscf Ste SpeclficSampling 2,906.607• 145.330- Ethylbenzene 100414 23.866 • Ib/MMscf Site Specific Sampling 122.556- 6.128. Xylene 1330207 246.934 • lb/MMscf Site Specific Sampling 1,268.064- 63.403 n -Hexane 110543 2,536.100 • lb/MMscf Site Specific Sampling 13,023.482 • 651.174• 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. c 1.aPAD Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 I C Street LP Gas Venting APEN Permit Number: AIRS ID Number: 123 / 9DD4 / oo' [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. Signatilc'of Legally Authbrized erson (not a vendor or consultant) \,t\n Date i5 Catie Nelson Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-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 6I cpicrrAoa moats sm.....a Hello