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Home My WebLink About20192073.tiffCOLORADO Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 May 29, 2019 Dear Sir or Madam: RECEIVED JUN 032010 WELD COUNTY COMMISSIONERS On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil ft Gas, Inc. - Jesser 3-I Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer �I ob\\c Pexl\eu CoikaIR HL.( >, PWWMIiRICH (CV - (4,13/1q 2019-2073' Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Jesser 3-I Production Facility - Weld County Notice Period Begins: June 6, 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: Jesser 3-I Production Facility EEtP Well Pad Site NWSW Sec 3 T4N R68W Weld County The proposed project or activity is as follows: The applicant proposes to permit a new oil and gas production facility located within the eight -hour (8 -hr) Ozone Control Area of Weld County. Emission points with this facility include hydrocarbon liquid loadout, vapor recovery tower (VRT) gas venting, low pressure (LP) separator gas venting, five (5) internal combustion engines, condensate storage tanks, and produced water storage tanks. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0762.CP1 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: ;COLORADO 1 I A a Daniel E Williams Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 2' A COLO R.& DO flapareznane K.01,4 Knrimomato CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0762 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Extraction Oil Et Gas, Inc. Jesser 3-I Production Facility 123/9FD5 NWSW SEC 3 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Jesser 3-I Liquid Loading 003 Truck loadout of condensate by submerged fill Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, ty 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 CDPHE COLORADO Air Pollution Control Division Department of Public Health & Environment Page 1 of 9 days may result in revoca of p m _ A se icati arm anguidance on how to self -certify compl.vnc ;w re red t s per at m � be obtaid online at www.colorado.gov/cdphe air -permit -se -certi ication. •egu ation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Jesser 3-I Liquid Loading 003 --- --- 0.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division Department of Pubic Heath & Environment Page 2 of 9 Facility Equipment ID AIRS Point Co ro vic I ollutants ontrolled Jesser 3-1 Liquid Loading 003 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Jesser 3-1 Liquid Loading 003 Condensate Loaded 72,017 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.D.2) 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): CDPHE COLORADO Mr Pollution Control Division Department of Public 4{eattn & Environment Page 3 of 9 a. The owner or ope .w'tor sh l i =•ef onsi m."•.'ng a ipent t ensure that hoses, couplings, A= d es a A ms tai e ed to , rev nl t drippin leaking, or other liquid or vapor oss during owing and un oading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 13. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. COLORADO Air Pollution Control Division Departrremt of Public Health b Environment Page 4 of 9 Periodic Testin Re • wire ,w.�-a„ • • lE_ - _ 'a.,, mom. 16. This source is not requir-�� ` m •uct � - �� g, ��-rwise�� ted by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). CDPHE COLORADO Air Pollution Control Division Departrvenc of Public Health E 'Environment Page 5 of 9 GENERAL TERMS AND CONDITIO 19. This permit and any attan ailabl r or inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Air Pollution Control Division Department of public tiea?rh & Er iro, ment Page 6 of 9 By: Daniel E Williams Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. COLORADO Air Pollution Control Division Department. cif Public Beath & Environment Page 7 of 9 Notes to Permit Holder at the ti 1) The permit holder is requireees he sin his peAn 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) 003 Benzene 71432 30 1 n -Hexane 110543 259 13 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 003: Pollutant CAS # Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 0.236 0.0118 Source Benzene 71432 0.00041 0.0000205 HAP Source n -Hexane 110543 0.0036 0.00018 Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received COLORADO Air Pollution Control Division Departrnerl of Public P 4e& & Environment Page 8 of 9 by the Division. A revised APE year term expires. Please ref: to �r mode rec�ti a ual f APEN expiration date for eac emissions point associated wit questions regarding a specific expiration date call the Division 7) This facility is classified as follows: s befo the five - e to det � ine the this permit. or any at (303)-692-3150. Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, N -Hexane, &t Total HAPs NANSR Synthetic Minor Source of: VOC, &t NOx 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.govt Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Dep3.trner of Asbtc Health b Envvorunent Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Daniel Williams Package #: 383445 Received Date: 6/25/2018 Review Start Date: 1/8/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc. County AIRS ID: 123 Quadrant Section Township Range NWSW = ..., 68 Plant AIRS ID: 9FD5 Facility Name: Physical Address/Location: County: Jesser 3-i Production Facility NWSW quadrant of Section 3, Township 4N, Range 68W (Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? I I Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Liquid Loading _lesser 3-I Liquid Loading Yes 18WE0762 1 Yes _ Permit initial Issuance Section 03 - Description of Project Extraction is applying for a permit for a condensate liquid loadout at a new facility in Weld County in the NAAQS non -attainment area. Extraction has drilled 16 new, 1.0 mile horizontal wells at this location with a date of first production of 3/27/18. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Yes Was a quantitative model ng 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) 5O2 NOx Is this stationary source a major source? If yes, explain what programs and which pollutants herE 5O2 Prevention of Significant Ceterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) ✓ CO NOx CO VOC PM2.5 PM10 TSP HAPs rs/.1 VOC PM2.5 PM10 TSP HAPs Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements tioarce is in the Non•Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? YoJ have indicated that source is in the Non -Attainment Area • NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Ye NG No Ne� 'Lc Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? t4;-; The loadout must be operated with submerged fill to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation. and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances_ This document does not change or substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as -recommend," "may, " 'should, "and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as -must" and `requ.red" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Go to next Go to the n Go to next Go to next Go to next The loadou The loadou Hydrocarbon Loadout Emissions Inventory 003 Liquid Loading Facility AIRs ID: 123 9FD5 003 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Condensate liquid loadout to trucks. Enclosed Combustor Requested Overall VOC & HAP 2ontrol Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded = Yes 100.0 95 95.00 60,014 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 60,014 Barrels (bbl) per year Requested Permit Limit Throughput = 72,017 Barrels (bbl) per year Requested Monthly Throughput = 6117 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded Waste Gas to Combustion Device(s) Liquid loading waste gas flow rte= Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 72,017 Barrels (bbl) per year 0.43286 MSCFD 2495.29 Btu/scf 157993 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? *Taken from ProMax Liquid Loading Stream and corrected to throughput with truck loadout. (Condensate goes directly to pipeline under normal operating conditions.) *Taken from ProMax Liquid Loading stream Yes Yes 329 MMBTU per year 394 MMBTU per year 394 MMBTU per year The state default emissions factors may be used to estimate emissions. l actuF # Meia niny t N,;;#`raft Units- (jE♦ 74. .-...1..+..-.^-.".N« va1.-.....h-•'. Mw♦ -N. III W"....... n."M I . 4M.-."..N0.ft, Y._r.y!^N.. _ •••••••••••••••••• Me.wM.♦ .1N.�L..+u+...4a -4 rM•.Y rk'I a', i a3 ..:',:e•'Z.:11 .. ,. F \.C.,)z-i l f }r cy.. ,L ..r,l «--«.r•..- ` -... . s -`c ,. "'• .-.•r.-.. ...-r -:,,..', ^• ' ' ' ' .—..-sue-. ..-.-a.-.... < . }}`:ft.i 7'ptn1 atu •� z-...s........y..N.. ...+.. :_.e...» .-.--............. 1#<≥A;�J1'1tz .- ..7.4.- - w. • .rte...-.- y .. f,; "-y.. '- --_l.:...:..- ,..4-$..- -.. 1. - »_...-...,. _____._________......—.„____________._________ Cf npan is r_c...`Y Mass . F:a ttor k'.iur -It3t; F tt r ijriI w .____ _ .n .n+ -is++ --M I' a H..0 Source WiW....-. �- _ .N' 4....^^4_`.x. u.✓-..�`-[ .«.- / :'/„- " .+ . s iyp+.. Der~ztne. �.. 4 .J .>' .r. i' ..„-.....4:-.--4.-,;_,.....„...............o :. .v+_. • .-N:^-r.lr- 11s 'Y.?# _ ,._.. .. w,- »:« .. _ »..:. _ _ 4......M..., -...9..............•.=:--..«._,...,i. ... .' » ifYlt Cr1e ty Pt' "N' ;.." -)l it .. /. '_j (. ,i_ s..+-� �...'..S( ..1../.%"//'/ /". .'n'f/ ..Y. /:�,n./:•••/,':•••/:;',/,.."./ /'... II II I-tnxane .1.. i II � u x •+-.4-m * ._w w...-.-- .. [. Y i / .-.( /. �n v.. J Trot}' w -w i lb.`s ¶%...:w r . w. r-** 4 r_f Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (Ib/bbl) (Ib/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 2.36E-01 1.18E-02 :=ondensate Loadout State E.F. Benzene 4.10E-04 2.05E-05 Condensate Loadout State E.F. Toluene 0.00E+40 0.00E+00 Ethylbenzene 0.00E+00 0.00E+00 Xylene 0.00E+00 0.00E+00 Condensate loadout State ES. n -Hexane 3.60E-03 1.80E-04 224 TMP 0.00E+00 0.00E+00 Control Device Uncontrolled Uncontrolled Emission Factor Source Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 4.08E-05 ..P-42 Table 1.4-2 (PM1O/PM.2.5) PM2.5 0.0075 4.08E-05 \P-42 Table 1.4-2 (PM20/PM.2.5) \P-42 Table 1.4-2 (SOx) ?P•42 Chapter 133 Industrial Flares (NOx) -' P-42 Chapter 13.5 Industrial Flares (CO) SOx 0.0006 3.22E-06 NOx 0.0680 3.72E-04 CO 0.3100 1.70E-03 3 of 6 K:\PA\2018\18WE0762.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.01 0.01 0.01 0.01 0.01 2 8.50 7.08 0.35 8.50 0.42 72 0.06 0.05 0.05 0.06 0.06 10 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene 30 25 1 30 1 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n -Hexane 259 216 11 259 13 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must be operated with submerged fill to satisfy RAG. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes State emission factors were used. Combustion emissions were developed based on the pressurized liquid sample and accompanying ProMax model. The liquid loading waste gas flowrate and heating value were taken from the liquid loading stream of the ProMax model. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # 01 SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.S 0.00 0 Ib/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.6 95 Ib/1,000 gallons transferred CO 0.04 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.09 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 4 of 6 K:\PA\2018\18WE0762.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Extraction Oil & Gas, Inc. County AIRS ID 123 Plant AIRS ID 9FD5 Facility Name Jesser 3-I Production Facility History File Edit Date 4/9/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 1.6 1.6 0.0 0.0 147.9 472.8 0.0 219.5 27.6 1.6 1.6 0.0 0.0 27.2 42.9 0.0 52.9 8.7 Hew Facility - No Previous Total Previous Permitted Facility total 1.6 1, 6 0.0 0.0 27.2 42.9 0.0 52.9 001 GP08 Condensate Tanks (8) x 400 -bbl 0.2 98.0 0.9 2.1 0.2 5.9 0.9 0.1 New Point 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 1.2 87.1 5.6 9.6 1.2 5.9 5.6 0.5 003 18WE0762 Condensate Loadout 8.5 0.1 0.1 0.4 0.1 0.0 004 18WE0763 VRT Venting 0.1 0.1 0.2 132.3 1.0 3.1 0.1 0.1 0.2 6.6 1.0 0.2 005 18WE0764 LP Separator Venting 0.1 0.1 0.3 123.2 1.3 4.8 0.1 0.1 0.3 6.2 1.3 0.2 006 GP02 RICE: Doosan-PSI D146L 0.3 0.3 27.5 2.5 46.2 0.4 0.3 0.3 3.5 2.5 7.0 0.4 008 GP02 RICE: Caterpillar G3306B TA 0.2 0.2 27.8 1.3 27.8 0.5 0.2 0.2 1.8 1.3 3.6 0.5 009 GP02 RICE: Caterpillar G3408 TA 0.2 0.2 49.9 2.3 50.0 0.7 0.2 0.2 3.2 2.3 6.4 0.7 010 GP02 RICE: Caterpillar G3516B 0.4 0.4 13.3 15.1 40.4 5.8 0.4 0.4 13.3 9.3 20.0 5.8 0.0 0.0 0.0 0.0 FACILITY TOTAL 1.3 1.3 0.0 0.0 120.4 470.3 0.0 173.3 27.2 1.3 1.3 0.0 0.0 23.7 40.4 0.0 45.9 8.3 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor C6 & Total HH: Area ZZZZ: Area Permitted Facility Total 1.3 1.3 0.0 0 0 120.4 470.3 0.0 173.3 27.2 1.3 1.3 0.0 0.0 23.7 40.4 0.0 45.9 8.3 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.3 -0.3 0.0 0 0 -3.5 -2.5 0.0 -7.0 Pubcom required based on new syn minor and VOC increase > 25 tpy Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 40.4 Facility is eligible for GP02 because < 90 tpy _Project emissions greater than 25 tpy -2.5 Note 1 Operator lowered VRT and LP Sep Venting throughputs and cancelled Point 007 before June 2018 permits were issued. Note 2 Page 5 of 6 Printed 5/29/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Extraction Oil & Gas, Inc. 123 9FD5 Jesser 3-I Production Facility Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane MeOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Condensate Tanks (8) x 400 -bbl 335 293 27 113 3438 2.1 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 4655 14628 9.6 003 18WE0762 Condensate Loadout 259 0.1 004 18WE0763 VRT Venting 601 439 33 152 4997 3 3.1 005 18WE0764 LP Separator Venting 875 1056 119 517 7112 5 4.8 006 GP02 RICE: Doosan-PSI D146L 510 69 65 39 76 0.4 4 008 GP02 RICE: Caterpillar G3306B TA 817 36 34 20 39 0.5 009 GP02 RICE: Caterpillar G3408 TA 1218 63 60 36 69 0.7 010 GP02 RICE: Caterpillar G3516B 10128 717 441 38 215 5.8 0.0 0.0 TOTAL (tpy) 6.3 0.4 0.3 3.3 0.9 0.1 0.4 15.2 0.2 0.0 0.0 0.0 27.2 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane MeOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0.0 0 001 GP08 Condensate Tanks (8) x 400 -bbl 17 15 172 1 0.1 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 233 731 0.5 003 18WE0762 Condensate Loadout 13 0.0 004 18WE0763 VRT Venting 30 22 250 0 0.2 005 18WE0764 LP Separator Venting 44 53 26 356 n 0.2 006 GP02 RICE: Doosan-PSI D146L 510 65 3E 7 0.4 008 GP02 RICE: Caterpillar G3306B TA 817 36 34 20 39 0.5 009 GP02 RICE: Caterpillar G3408 TA 1218 63 60 36 69 0.7 010 GP02 RICE: Caterpillar G3516B 10128 717 441 38 215 5.8 0.0 0.0 TOTAL (tpy) 6.3 0.4 0.3 0.2 0.0 0.0 0.0 0.8 0.2 0.0 8.3 0.0 0.0 6 18WE0762.CP1 5/29/2019 Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE0763 Issuance: 1 Extraction Oil Et Gas, Inc. Facility Name: Plant AIRS ID: Physical Location: County: General Description: Jesser 3-I Production Facility 123/9FD5 NWSW SEC 3 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT Gas Venting 004 Two (2) vapor recovery towers (VRTs) during gas compression downtime Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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 COLORADO Air Pollution Control Division Department o! Public Health & Environment Page 1 of 9 on. It is er or op •'responsibi to self- onditionsdemo r ate ompliance 'thin 180 catif the r'rmit. A f certi tion form and •ance on lian ed b ,� y be obta P �w-�•,ine 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, VOC CO VRT Gas Venting 004 --- --- 6.6 1.0 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. CDPH COLORADO Air Pollution Control Division Department of Pubiic Health 6 Environment Page 2 of 9 7. e emissio fissions co the limit ad lity Equipment ID oint of e tabli AIRS Point ble belo as listed i permi e opera= m`' maintain with the educe ssio Q to less th £ '3 or equal Numb . 3, Part B, Secti III.E.) Control Device Pollutants Controlled VRT Gas Venting 004 Emissions from the VRTs are routed to an Enclosed Combustor during gas compression 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, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT Gas Venting 004 Natural Gas Venting 2.2 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 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 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: CDPHE COLORADO Air Pollution Control Division Denartnten! 0 Public Hearth & Environment Page 3 of 9 installed • or;``er May 1, =i ust be eq ped with niter upo r x ` • n of th • m. stion devi busti devic stall before 1, 20 °" must be equip, `w with an operation. ."'1 •="gnit ore M. . ter the ne • •ustion 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 these points, 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&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. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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 COLORADO Air Pollution Control Division Department of Public Heath & vnrvonment Page 4 of 9 0 tons pe s per ye N sub r more, , which in actual less, abov ssions of he level 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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. COLORADO Air Pollution Control Division Department. of Public Heailh 5'vwvonment Page 5 of 9 23. hand ev 'vt con«u , . is permit erial par . and is no' .verable. conditioi �� t�r � all cons to . t ejection e entire ce, th permit ll be d ed denied ab io. This to se, � i �' end final a ion by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Daniel E Williams Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. COLORADO Air Pollution Control Division Department of Public Health & cnvrooroent Page 6 of 9 Notes tthis perm .nice: 1) Th rmit hold s re •� ed gay fees fe p -ssing ti his permit '`'n invoice for se fe I be i ed a a the • mit is is d Th ermit holder s pay the .,.; &.in 30 da, eip ,a,, �. M oice. <. �: , Pp he invoic- ult 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-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 Venting 004 Benzene 71432 601 30 Toluene 108883 439 22 Ethylbenzene 100414 33 2 Xylenes 1330207 152 8 n -Hexane 110543 4997 250 2,2,4- Trimethylpentane 540841 3 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division Department of Public Health 5 Environment Page 7 of 9 ed on the • . w£ g emissio :: ctors: E CAS # Pollutant „� = f . • lled Emission Factors (lb/MMSCF) Emission Factors (lb/MMSCF) Source NOx 197.073 197.073 AP -42 CO 898.420 898.420 AP -42 VOC 120305.5 6015.3 Extended Gas Analysis 71432 Benzene 273.4 13.67 Extended Gas Analysis 108883 Toluene 199.6 9.978 Extended Gas Analysis 100414 Ethylbenzene 15.17 0.7583 Extended Gas Analysis 1330207 Xylene 69.31 3.466 Extended Gas Analysis 110543 n -Hexane 2271.5 113.6 Extended Gas Analysis 540841 2'2'4-1.330 Trimethylpentane 0.06652 Extended Gas Analysis Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, N -Hexane, a Total HAPs NANSR Synthetic Minor Source of: VOC, Et NOx COLORADO Air Pollution Control Division Decortmera of Public Health & Eowo:vnent Page 8 of 9 n of Envir below: f Federal ^m . ulations Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Department of Public Health & Environment Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Daniel Williams Package #: 333445 Received Date: 6/25/2018 Review Start Date: 1/8/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc. County AIRS ID: 123 Quadrant Section Township Range NWSW Plant AIRS ID: Facility Name: Physical Address/Location: County: 9FDS Jesser 3-1 Production Facility NWSW quadrant of Section 3, Township 4N, Range 68W IVAeld County Type of Facility: Exploration & Production Well Pad What industry segment? O I & Natural Gas Production & Processing 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 Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Separator Venting VRT Gas Venting `_ 18WE0763 ; _ ; Permit lnitia; Issuance Section 03 - Description of Project Extraction is applying for a permit to vent gas from two (2) vapor recovery towers (VRTs) during gas compression downtime at a new facility in Weld County in the NAAQS non -attainment area. Extraction has drilled 16 new, 1.0 mile horizontal wells at this location with a date of first production of 3/27/18. On 4/4/19, Extraction requested to modify the requested throughtput on both the VRT and LP separator venting, dropping the facility total requested VOC emissions below 50 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit 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) SO2 NOx Is this stationary source a major source? If yes, explain what programs and which pollutants her€ SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs J J CO VOC PM2.5 PM10 TSP HAPs Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 17t). County 9F05 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Two (2) vapor recovery towers (VRTs) during gas compression downtime Enclosed Combustor 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 = MMscf per year Requested Permit Limit Throughput = 2.20 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 equ pment: 2.20 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description Btu/scf scf/bbl A gas sample sample was taken from one of the vapor recovery towers (VRTs) at 3 psig (sampled: 5/30/18). The sample analysis mot% values were entered into a ProMax 4.0 model. The mass fractions, molecular weight (MW), and heat value were taken from the Protvlax LP Gas stream output. The waste gas flow rate is directly measured by a flow meter directly upstream of the combustor. MW 50.4217 Weight % Oxygen 0.07 CO2 0.38 N2 0.19 methane 1.28 ethane 7.66 propane 31.86 isobutane 8.55 n -butane 27.23 isopentane 6.66 n -pentane 7.75 cyclopentane 0.54 n -Hexane 1.71 cyclohexane 0.44 Other hexanes 3.01 heptanes 1.04 methylcyclohexane 0.41 224-TMP 0.00 Benzene 0.21 Toluene 0.15 Ethylbenzene 0.01 Xylenes 0.05 C8+ Heavies 0.81 Total 100.00 VO:Wt% 90.43 lb/lb-mol Displacement Equation Ex = Q * MW * Xx / C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (Ib/MMscf) Emission Factor Source (Gas Throughput) (Gas Throughput) VOC 120305.5 6015.3 _:° -;;red gas analysis Benzene 273.4 13.67 Extended gas analysis Toluene 199.6 9.978 Extended gas analysis Ethylbenzene 15.17 0.7583 Extended gas analysis Xylene 69.31 3.466 Extended gas analysis n -Hexane 2271.5 113.6 Es;.tended gas analy'.: , 224 TMP 1.330 0.06652 tt 5,risd Q n aria`>. Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) Ib/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 '5 21.594 AP -42 'Sabpe 1;4-2 (P≥ 310/PM.2.5) 'AP -42 Table 1.4-2 (S0A) AP -42 Cnaptec 13$ Industrial Flares (NC:„ PM2.5 0.0075 21.594 SOx 0.0006 1.705 NOx 0.0680 197.073 CO 0.3100 898.420 K:\PA\2018\18W E0763.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.02 0.00 0.00 0.02 0.02 4 0.02 0.00 0.00 0.02 0.02 4 0.00 0.00 0.00 0.00 0.00 0 0.22 0.02 0.02 0.22 0.22 37 132.34 14.44 0.72 132.34 6.62 1124 0.99 0.11 0.11 0.99 0.99 168 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 601 66 3 601 30 Toluene 439 48 2 439 22 Ethylbenzene 33 4 0 33 2 Xylene 152 17 1 152 8 n -Hexane 4997 545 27 4997 250 224 TM P 3 0 0 3 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being Jermitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. • fi If CYf7 the. �. ,"F'Pt �>:Lz�?.�;�i)��t�t 2>� ��friitfctf r,.il�,�)��7�{� , feST;t J.}C_rCcr 3t,•'a•t� .till, to 4, ;r:; ni,>ta :}e t'.l.jt. the .1 sJ"1.<,13-its: try �� i� ��': ti, Sts :.i cigta:i ET:t2,3twL'.. thjr: 3 of 7 K:\PA\2018\18WE0763.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Emission factors are based on & VRT gas sample analysis, which was then entered into ProMax. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 21.59 0 Ib/MMSCF PM2.5 21.59 0 Ib/MMSCF SOx 1.70 0 Ib/MMSCF NOx 197.07 0 Ib/MMSCF VOC 120305.51 95 Ib/MMSCF CO 898.42 0 Ib/MMSCF Benzene 273.39 95 Ib/MMSCF Toluene 199.56 95 lb/MMSCF Ethylbenzene 15.17 95 Ib/MMSCF Xylene 69.31 95 Ib/MMSCF n -Hexane 2271.50 95 Ib/MMSCF 224 TMP 1.33 95 Ib/MMSCF 4 of 7 K:\PA\2018\18WE0763.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements _ Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section .I.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility cncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? Source requires a permit Yes Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Yes Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? No. The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Discaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances_ This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. in the event of any conflict betweer the language of this document and the language of the Clean Air Act., its implementing regulations. and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," 'may." "should, "and 'can, "is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req Source Req Source is si The contro COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Extraction Oil & Gas, Inc. County AIRS ID 123 Plant AIRS ID 9FD5 Facility Name Jesser 3-I Production Facility History File Edit Date 4/9/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 1.6 1.6 0.0 0.0 147.9 472.8 0.0 219.5 27.6 1.6 1.6 0.0 0.0 27.2 42.9 0.0 52.9 8.7 New Facility - No Previous Total Previous Permitted Facility total 1.6 1.6 0.0 0.0 27.2 42.9 0.0 52.9 001 GP08 Condensate Tanks (8) x 400 -bbl 0.2 98.0 0.9 2.1 0.2 5.9 0.9 0.1 New Point 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 1.2 87.1 5.6 9.6 1.2 5.9 5.6 0.5 003 18WE0762 Condensate Loadout 8.5 0.1 0.1 0.4 0.1 0.0 004 18WE0763 VRT Venting 0.1 0.1 0.2 132.3 1.0 3.1 0.1 0.1 0.2 6.6 1.0 0.2 005 18WE0764 LP Separator Venting 0.1 0.1 0.3 123.2 1.3 4.8 0.1 0.1 0.3 6.2 1.3 0.2 006 GPM RICE: Doosan-PSI D146L 0.3 0.3 27.5 2.5 46.2 0.4 0.3 0.3 3.5 2.5 7.0 0.4 008 GP02 RICE: Caterpillar G3306B TA 0.2 0.2 27.8 1.3 27.8 0.5 0.2 0.2 1.8 1.3 3.6 0.5 009 GP02 RICE: Caterpillar G3408 TA 0.2 0.2 49.9 2.3 50.0 0.7 0.2 0.2 3.2 2.3 6.4 0.7 010 GP02 RICE: Caterpillar G3516B 0.4 0.4 13.3 15.1 40.4 5.8 0.4 0.4 13.3 9.3 20.0 5.8 0.0 0.0 0.0 0.0 FACILITY TOTAL 1.3 1.3 0.0 0.0 120.4 470.3 0.0 173.3 27.2 1.3 1.3 0.0 0.0 23.7 40.4 0.0 45.9 8.3 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor C6 & Total HH: Area ZZZZ: Area Permitted Facility Total 1.3 1.3 0.0 0.0 120.4 470.3 0.0 173.3 27.2 1.3 1.3 0.0 0.0 23.7 40.4 0.0 45.9 8.3 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.3 -0.3 0.0 0.0 -3.5 -2.5 0.0 -7.0 Pubcom required based on new syn minor and VOC increase > 25 tpy Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 40.4 Facility is eligible for GP02 because < 90 tpy Project emissions greater than 25 tpy -2.5 Note 1 Operator lowered VRT and LP Sep Venting throughputs and cancelled Point 007 before June 2018 permits were issued. Note 2 Page 6 of 7 Printed 5/29/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Extraction Oil & Gas, Inc. 123 9FD5 Jesser 3-I Production Facility Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene,Xylenes n -Hexane MeOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Condensate Tanks (8) x 400 -bbl 335 293 2 113 3438 27 2.1 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 4655 14628 9.6 003 18WE0762 Condensate Loadout 259 0.1 004 18WE0763 VRT Venting 601 439 33 152 4997 3 3.1 005 18WE0764 LP Separator Venting 875 1056 119 517 7112 5 4.8 006 GP02 RICE: Doosan-PSI D146L 510 69 65 39 0.4 Pu._..CN ..lu,J 008 GP02 RICE: Caterpillar G3306B TA 817 36 34 39 0.5 009 GP02 RICE: Caterpillar G3408 TA 1218 63 60 69 0.7 010 GP02 RICE: Caterpillar G3516B 10128 717 441 215 5.8 0.0 0.0 TOTAL (tpy) 6.3 0.4 0.3 3.3 0.9 0.1 0.4 15.2 0.2 0.0 0.0 0.0 27.2 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane 224 TMP H2S TOTAL (tpy) MeOH Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0.0 0 0 001 GP08 Condensate Tanks (8) x 400 -bbl 17 15 172 1 0.1 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 233 731 0.5 003 18WE0762 Condensate Loadout 0.0 13 004 18WE0763 VRT Venting 30 22 250 0.2 005 18WE0764 LP Separator Venting 44 53 26 356 0.2 006 GP02 RICE: Doosan-PSI D146L 510 69 65 0.4 008 GP02 RICE: Caterpillar G3306B TA 817 36 34 20 0.5 009 GP02 RICE: Caterpillar G3408 TA 1218 63 60 36 0.7 010 GP02 RICE: Caterpillar G3516B 10128 717 441 38 5.8 0.0 0.0 TOTAL (tpy) 6.3 0.4 0.3 0.2 0.0 0.0 0.0 0.8 0.0 8.3 0.2 0.0 0.0 7 18WE0763.CP1 5/29/2019 Permit number: Date issued: Issued to: ADO n Contro is Healt CONSTRUCTION PERMIT 18WE0764 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Extraction Oil &t Gas, Inc. Jesser 3-I Production Facility 123/9FD5 NWSW SEC 3 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP Gas Venting 005 Low pressure (LP) gas from sixteen (16) VHLP separators during gas compression downtime Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, jy 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 COLORADO Air Pollution Control Division Department of Plbfic Health & Environment Page 1 of 9 d t•` • i on. It is ., per or op responsibito self- nce h onditionsdemo ate ompliance 'thin 180 t in f the rmit. A f certi tion form and •ante on -certi . lian ` .a ed b _�.- - y be obta •,• ine at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO LP Gas Venting 005 --- --- 6.2 1.3 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. CDPHE 4 - COLORADO Air Pollution Control Division Department of Public Health b Environment Page 2 of 9 7. e emissio fissions co the limit aci lity Equipment ID oint of e tabli AIRS Point ble belo as listed i permi e opera i ` maintain with the educe .- ssio . to less th or equal Numb ;:43, Part B, Secti III.E.) Control Device Pollutants Controlled LP Gas Venting 005 Emissions from the VHLP separators are routed to an Enclosed Combustor during gas compression 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, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LP Gas Venting 005 Natural Gas Venting 4.0 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 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 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: COLORADO Mr Pollution Control Division Department of Public Health E. Environment Page 3 of 9 installed er May 1, niter upo n of th ust be eq stion devi ped with devic stall before 1 20 must be equi with an operationgnit- . v • ` • - ore M , + •, • . ter the neustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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 COLORADO Air Pollution Control Division Dtpartment of Rabtic Hearth E EovGonment Page 4 of 9 0 tons pe ns per ye N sub r more, , which in actual less, abov ssions of he level 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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. COLORADO Air Pollution Control Division Department of Pubic Heath & FxrFvonment Page 5 of 9 23. "= hand eve ¢t con , . is permit . -_r : erial par Fr and is noFes;t verable. or yea a conditio all cons to ejection • Jd e entire on su t aR occu ce, th permit II be d ed denied ab ;, io. This e re F r an t. s* :; to se .,.._. fiend final a ..zen ,.ion by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Daniel E Williams Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. COLORADO Air Pollution Control Division Department of Public Health & Ern ronment Page 6 of 9 Notes tthis perm ce: 1) Th 6 rmit holds re • ed �ay fees fe p -ssing ti his permit for se fe�l be i�: ed a the • mit is is d Th ` ermit holder s ��f - � P in 30 da, eip . � � ` oice. , . -� _••• . he invoic revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) n invoice pay the ult in 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: / /www.colorado. gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP Gas Venting 005 Benzene 71432 875 44 Toluene 108883 1056 53 Ethylbenzene 100414 119 6 Xylenes 1330207 517 26 n -Hexane 110543 7112 356 2,2,4- Trimethytpentane 540841 5 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COPHE 'COLORADO 1 Air Pollution Control Division I Department of H biic PiealNh & Environment Page 7 of 9 5) Th ission le Poi =r 005: ed on the • ,. g emissio : ctors: CAS # Pollutant lied Emission Factors (lb/MMSCF) �a Emission Factors (lb/MMSCF) Source NOx 139.739 139.739 AP -42 CO 637.044 637.044 AP -42 VOC 61613.8 3080.7 Extended Gas Analysis 71432 Benzene 218.8 10.94 Extended Gas Analysis 108883 Toluene 264.1 13.20 Extended Gas Analysis 100414 Ethylbenzene 29.73 1.486 Extended Gas Analysis 1330207 Xylene 129.2 6.461 Extended Gas Analysis 110543 n -Hexane 1777.9 88.89 Extended Gas Analysis 540841 2,2,4- Trimethylpentane 1.338 0.06691 Extended Gas Analysis Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, N -Hexane, a Total HAPs NANSR Synthetic Minor Source of: VOC, a NOx COLORADO Air PoUution Control Division Department of Public Health 6 t vironment Page 8 of 9 n of Envir d below: f Federal •ulations Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Department of Public Health & ErnOronment Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Daniel Williams Package #: 333445 Received Date: 6/25/2018 Review Start Date: 1/8/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc. County AIRS ID: 123 Quadrant Section Township Range NWSW ..r.i 68 Plant AIRS ID: Facility Name: Physical Address/Location: County: 9FD5 Jesser 3-I Production Facility NWSW quadrant of Section 3, Township 4N, Range 68W 'Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? n Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point 14 Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Separator Venting LP Gas Venting 18WE0764 1 Yes Permit Initial Issuance Section 03 - Description cf Project Extraction is applying for a permit to vent the low pressure (LP) gas from sixteen (16) VHLP separators when during gas compression downtime at a new facility in Weld County in the NAAQS non -attainment area. Extraction has drilled 16 new, 1.0 mile horizontal wells at this location with a date of first production of 3/27/18. On 4/4/19, Extraction requested to modify the requested throughtput on both the VRT and LP separator venting, dropping the facility total requested VOC emissions below 50 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit 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 Scurce Review (NANSR) SO2 NOx Is this stationary source a major source? If yes, explain what programs and which pollutants her€ SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) CO J NOx CO VOC PM2.5 VOC PM2.5 PM10 TSP HAPs PM10 TSP HAPs Separator Venting Emissions Inventory 005 Separator Venting Facility AIRs ID: A( J County 9FDS Plant 005 Point Section 02 - Equipment Description Details Low pressure (LP) gas from sixteen (16) VHLP separators during gas compression downtime Detailed Emissions Unit Description: Enclosed Combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Thrcughput = 1.80 MMscf per year 95 Requested Permit Limit Thrcughput = 4.00 MMscf per year Requested Monthly Throughput = 0 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Ye Is VRU process equipment: Yes 4.00 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description 2055 Btu/scf scf/bbl A gas sample sample was taken from one of the VHLP separators 3 psig (sampled: 5/30/18). The sample analysis mol% values were entered into a ProMax 4.0 model. The mass fractions, molecular weight (MW), and heat value were taken from the PreMax LP Gas stream output. The waste gas flow rate is directly measured by a flow meter directly upstream of the combustor. MW 36.225 Weight % Oxygen 0.14 CO2 2.08 N2 0.58 methane 15.25 ethane 17.49 propane 26.38 isobutane 4.6`_, n -butane 14.14 isopentane 3.73 n -pentane 5.05 cyclopentane 0.42 n -Hexane 1.8E cyclohexane 0.53 Other hexanes 2.84 heptanes 1.69 methylcyclohexane 0.65 224-TMP 0.00 Benzene 0.23 Toluene C. _. Ethylbenzene 0.;� Xylenes 0.1 4 C8+ Heavies 1.84 Total 100.00 VOC Wt % 64.4€ Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor Source (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 61613.8 3080.7 Benzene 218.8 10.94 Toluene 264.1 13.20 Ethylbenzene 29.73 1.486 Extended gas analysis Xylene 129.2 6.461 n -Hexane 1777.9 88.89 224 TM P 1. 312 0.06691 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 15.312 - AP-4i'Eable l.4.2 (F < <r; s .... �/ AP -42 Table 1.4-2 (PM10,'PM.2.5) AP -42 Table 1.4-2 (5Ox) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 133 Indu ctri'1 Fhr s (CO) PM2.5 0.0075 15.312 SOx 0.0006 1.209 NOx 0.0680 139.739 CO 0.3100 637.044 2 of 7 K:\PA\2018\18WE0764.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx 0.03 0.01 0.01 0.03 0.03 5 0.03 0.01 0.01 0.03 0.03 5 0.00 0.00 0.00 0.00 0.00 0 NOx 0.23 0.13 0.13 0.28 0.28 47 VOC 123.23 55.45 2.77 123.23 6.16 1047 CO 1.27 0.57 0.57 1.27 1.27 216 Hazardous Air Pollutant) Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 875 394 20 875 44 Toluene 1056 475 24 1056 53 Ethylbenzene 119 54 3 119 6 Xylene 517 233 12 517 26 n -Hexane 7112 3200 160 7112 356 224 TM P 5 2 0 5 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are ess than or equal to the emissions factors established with this application. No -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 ess than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit wil contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 3 of 7 K:\PA\2018\18WE0764.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Emission factors are based on a LP gas sample analysis, which was then entered into ProMax. ProMax low pressure separator gas stream mass flow rates (lb/hr) were used to develop emi ssion factors. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM 10 15.31 0 Ib/MMSCF PM2.5 15.31 0 Ib/MMSCF SOx 1.21 0 Ib/MMSCF NOx 139.74 0 lb/MMSCF VOC 61613.75 95 Ib/MMSCF CO 637.04 0 lb/MMSCF Benzene 218.78 95 Ib/MMSCF Toluene 264.09 95 lb/MMSCF Ethylbenzene 29.73 95 Ib/MMSCF Xylene 129.22 95 lb/MMSCF n -Hexane 1777.89 95 lb/MMSCF 224 TMP 1.34 95 Ib/MMSCF 4 of 7 K:\PA\2018\18WE0764.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section I.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Sourca requires a permit Colorado Regulation 7, Section XVfl 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 - General Provisions f6r Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section! a. Is thi≤ separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? No The control device for this separator is not subject to Regulation 7, Section XVll.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document rs not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regu.ation, 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 regu ations, 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 interded to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req Source Req Source is si The contro COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Extraction Oil & Gas, Inc. County AIRS ID 123 Plant AIRS ID 9FD5 Facility Name Jesser 3-I Production Facility History File Edit Date 4/9/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total ' HAPs 1 PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 1.6 1.6 0.0 0.0 147.9 472.8 0.0 219.5 27.6 1.6 1.6 0.0 0.0 27.2 42.9 0.0 52.9 8.7 New Facility - No Previous Total Previous Permitted Facility total 1.6 1.6 0.0 0.0 27.2 42.9 0.0 52.9 001 GP08 Condensate Tanks (8) x 400 -bbl 0.2 98.0 0.9 2.1 0.2 5.9 0.9 0.1 New Point 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 1.2 87.1 5.6 9.6 1.2 5.9 5.6 0.5 003 18WE0762 Condensate Loadout 8.5 0.1 0.1 0.4 0.1 0.0 004 18WE0763 VRT Venting 0.1 0.1 0.2 132.3 1.0 3.1 0.1 0.1, 0.2 6.6 1.0 0.2 005 18WE0764 LP Separator Venting 0.1 0.1 0.3 123.2 1.3 4.8 0.1 0.1 0.3 6.2 1.3 0.2 006 GP02 RICE: Doosan-PSI D146L 0.3 0.3 27.5 2.5 46.2 0.4 0.3 0.3 3.5 2.5 7.0 0.4 008 GP02 RICE: Caterpillar G3306B TA 0.2 0.2 27.8 1.3 27.8 0.5 0.2 0.2 1.8 1.3 3.6 0.5 009 GP02 RICE: Caterpillar G3408 TA 0.2 0.2 49.9 2.3 50.0 0.7 0.2 0.2 3.2 2.3 6.4 0.7 010 GP02 RICE: Caterpillar G3516B 0.4 0.4 13.3 15.1 40.4 5.8 0.4 0.4 13.3 9.3 20.0 5.8 0.0 0.0 0.0 0.0 FACILITY TOTAL 1.3 1.3 0.0 0.0 120.4 470.3 0.0 173.3 27.2 1.3 1.3 0.0 0.0 23.7 40.4 0.0 45.9 8.3 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor C6 & Total HH: Area ZZZZ: Area Permitted Facility Total 1.3 1.3 0.0 0 0 120.4 4/0.3 0 0 173.3 27.2 1.3 1 3 0.0 0.0 23.7 /10..1 0.0 45.9 8.3 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.3 -0.3 0.0 0.0 -3.5 -2.5 0.0 -7.0 Pubcom required based on new syn minor and VOC increase > 25 tpy Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 40.4 Facility is eligible for GP02 because < 90 tpy Project emissions greater than 25 tpy -2.5 Note 1 ,-operator lowered VRT and LP Sep Venting throughputs and cancelled Point 007 before June 2018 permits were issued. Note 2 Page 6 of 7 Printed 5/29/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Extraction Oil & Gas, Inc. 123 9FD5 Jesser 3-I Production Facility Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acroleln Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Condensate Tanks (8) x 400 -bbl 335 293 113 3438 2.1 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 4655 14628 9.6 003 18WE0762 Condensate Loadout 259 0.1 004 18WE0763 VRT Venting 601 439 152 4997 3.1 005 18WE0764 LP Separator Venting 875 1056 517 7112 4.8 006 GP02 RICE: Doosan-PSI D146L 510 69 65 39 0.4 008 GP02 RICE: Caterpillar G3306B TA 817 36 34 20 39 0.5 009 GP02 RICE: Caterpillar G3408 TA 1218 63 60 36 69 0.7 010 GP02 RICE: Caterpillar G3516B 10128 717 441 38 215 5.8 0.0 0.0 TOTAL (tpy) 6.3 0.4 0.3 3.3 0.9 0.1 0.4 15.2 0.2 0.0 0.0 0.0 27.2 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 IMP H25 TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0.0 0 0 0 0 001 GP08 Condensate Tanks ;8; x 400 -bbl 17 15 172 0.1 1 002 GP08 Produced Water Storage Tanks (2) x 400 -bbl 233 731 0.5 003 18WE0762 Condensate Loadout l 13 0.0 004 18WE0763 VRT Venting 30 22 250 0.2 005 18WE0764 LP Separator Venting 44 53 26 356 0.2 006 GP02 RICE: Doosan-PSI D146L 510 65 76 0.4 008 GP02 RICE: Caterpillar G3306B TA 817 36 34 20 39 0.5 009 GP02 RICE: Caterpillar G3408 TA 1218 63 60 36 69 0.7 010 GP02 RICE: Caterpillar G3516B 10128 717 441 38 215 5.8 0.0 0.0 TOTAL (tpy) 6.3 0.4 0.3 0.2 0.0 0.0 0.0 0.8 0.2 0.0 0.0 8.3 0.0 I 7 18WE0764.CP1 5/29/2019 Jesser 3-I Liquid Loadout APEN Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and' I JUN 252018 Application for Construction Permit I All sections of this APEN and application must be completed for both new and existing facilities, including APEN';;'r 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. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: WF0AIRS ID Number: I23 /JFm/ 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Jesser 3-I Liquid Loading [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. Jesser 3-I Production Facility Site Location: NWSW Sec 3 T4N R68W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 '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 APCD via e-mail to the address provided. 34i5 31 t3 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 1 tOt©itE,flU Awakened. ei Jesser 3-I Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action 2 NEW permit OR newly -reported emission source 2 Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Please issue individual permit for hydrocarbon liquid loadout. Pipeline is used for all production, permit addresses possibility of truck loading in the future. 3 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. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 3/27/2018 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? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? O Yes ❑ No El Yes El No ❑ Yes 0 -No 0 Yes ❑ No ❑ Yes El No O Yes 0 No ❑ Yes 0 No Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 2 I pepwirtierdic Jesser 3-I Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information. Product Loaded: ❑✓ Condensate ❑ Crude Oil D Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 72,017.3 Bbl/yr Actual Volume Loaded: 60,014.4 Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") Tank Trucks If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: °F True Vapor Pressure Psia 60 ° F Molecular weight of displaced vapors 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/yr Actual Volume Loaded: N/A Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Load Line Volume: N/A N/A Lb/ft3 ft3/truckload Vapor Recovery Line Volume N/A ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 3 I OLOStAbfa Eloprionreeralhe Jesser 3-I Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APO has already assigned a permit ≥? and AIRS ID] Section 5 - Geographical Information 40.341138, -104.997324 ft Y 4 @ 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 Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system: Requested Control Efficiency % ❑✓- Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr Make/Model: 95% % 98% ' % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 4 I Jesser 3-I Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 7✓ Yes ❑ No the overall control efficiency (% reduction): ___ ,-x � — _x. i Re 70 -it' t ve uc€lon eaxrssyons _ PM SOX NO,, CO VOC ECD 95% HAPs ECD 95% Other: ✓L7 Using State Emission Factors (Required for GP07) VOC ✓0 Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: '17'uli.i a ss1a ctox ,,,,,- e c �� cct 1r �� et � s/ ear nt:rolled in �year PM SOX NO,' VOC 0.236 IbVOC/ bbl APCD Memo 14-02 7.082 .- 0.354.- 8.498 - 0.425 CO Benzene Toluene Ethylbenzene Xylenes n -Hexane 0.0036 lb n-Hexane/bbl APCD Memo 14-02 0.108 - 0.005 - 0.130 / 0.006 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. • 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. //q Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 51 LSSLGRA[r GL V.wisrarl zi Jesser 3-I Liquid Loadout APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit iF 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 the applicable General Permit. Signature of Legally Authorized) Person (not a vendor or consultant) Catie Nelson C4e) / Date otlri 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 $152.90 and the General Permit registration fee of $250 as 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 6 I Lig Milt MIME. bralirimmela. S�• — Sc_e— t�-�^-e-_ A -PE N Re_c.f2_) v e 1-O4/1 Jesser 3-I VRT Gas Venting APEN Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and ! JUN25 5 201 Application for Construction Permit i? All sections of this APEN and application must be completed for both new and existing facilities, including APEN �' `'r ```' 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 Natural Gas Venting only. Natural 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. 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: 14g NE (51 tol) AIRS ID Number: 123 4F16'004 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: VRT Gas Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Jesser 3-I Production Facility Site Location: NWSW Sec 3 T4N R68W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 Please 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 APCD via e-mail to the address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 '33 ?,� 1 I fiLGttAOO1 w Jesser 3-I VRT Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 0 Other (describe below) -OR - ❑ APEN submittal for update only (Please 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 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. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: l J Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: / / 3 / 27 / 2018 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 days/week weeks/year ❑✓ Yes ❑ Yes ❑ No 0 No t Ot.0RAifd Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I Jesser 3-I VRT Gas Venting APEN Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information 0 Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 5000 SCF/hr Vent Gas Heating Value: 2830 BTU/SCF Requested: 5.500 MMSCF/year Actual: 0.240 MMSCF/year -OR- Requested: N/A Bbl/yr Actual: N/A Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 50.5016 lb/lbmol VOC (mole %) 82.257 VOC (Weight %) 90.444 Benzene (mole %) 0.133 Benzene (Weight %) 0.205 Toluene (mole %) 0.082 Toluene (Weight %) 0.150 Ethylbenzene (mole %) 0.005 Ethylbenzene (Weight %) 0.011 Xylene (mole %) 0.025 Xylene (Weight %) 0.052 n -Hexane (mole %) 0.999 n -Hexane (Weight %) 1.705 2,2,4-Trimethylpentane (mole %) 0.000 2,2,4-Trimethylpentane (Weight %) 001 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) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 31 dirdifile cct.cRAaa Jesser 3-I VRT Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCO has already assigned a permit # and AIRS ID] Section 5 - Stack Information 40.341138, -104.997324 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 Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency VRU Downtime or Bypassed Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: 95% % Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 98% % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-2O5 -Natural Gas Venting APEN - Rev 03/2017 tiEffilble StAtgCd Jesser 3-I VRT Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit * and AIRS 101 Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): overall Requeste Co o, CSI Efficient cr:c:i it .ririfssk PM sox NO„ VOC ECD 95% CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) PM Sox NO„ VOC CO Benzene Toluene Ethylbenzene Xylenes n -Hexane 2,2,4- Trimethylpentane Other: 120.36 0.31 ' 0.273 0.199 , 0.069 2.269 � IbVOC/MSCF IbCO/MMBtu lb Benzene/MSCF lb Toluene/MSCF lb Xylenes/MSCF lb n-Hexane/MSCF Site Specific Sampling AP -42 Site Specific Sampling Site Specific Sampling Site Specific Sampling Site Specific Sampling 14.444 / 0.722 0.033 - 0.002 0.024 — 0.001 0.008 ' 0.000 . 0.272 - 0.014 330.997 , 16.550- 2.413 , 2.413 0.751 - 0.038 . 0.548 0.027 0.190 , 0.010 i 6.238 , 0.312 , 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I sad Jesser 3-I VRT Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit fr and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson X20 1?/LA ate Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance J Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-205 -Natural. Gas Venting APEN - Rev 03/2017 6 r Ptak Jesser 3-I VRT Gas Venting Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 18WE0763 AIRS ID Number: 123 /9FD5 /004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Site Name: Site Location: Extraction Oil & Gas, Inc. Jesser 3-I Production Facility NWSW Sec 3 T4N R68W Mailing Address: 370 17th St. Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address2: cnelson@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 AV1COLORADO annum Jesser 3-I VRT Gas Venting Permit Number: 18W E0763 AIRS ID Number: 123 /9FD5/OO4 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Please issue individual permit for VRT Gas Venting. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of VRT gas when compression is unavailable. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 3/27/2018 Q 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 1COLORADO ' I{eY1�S EnWronmenl Jesser 3-I VRT Gas Venting Permit Number: 18WE0763 AIRS ID Number: 123 / 9FD5 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameterss: Liquid Throughput Process Parameterss: Vented Gas Properties: ❑✓ Yes ❑ No Vent Gas Heating Value: 2898.13 ,BTU/SCF Requested: 2.200 MMSCF/year Actual: 0.240 MMSCF/year -OR- Requested: N/A bbl/year Actual: NA bbl/year Molecular Weight: 50.422 VOC (Weight %) 90.429 -- Benzene (Weight %) 0.2055 - Toluene (Weight %) 0.1500 Ethylbenzene (Weight %) 0.0114 Xylene (Weight %) 0.0521 n -Hexane (Weight %) 1.7074 , 2,2,4-Trimethylpentane (Weight %) 0.0010 / 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 timit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 31 !COLORADO �� oe Ha�iS EnvlmnmeM Jesser 3-I VRT Gas Venting Permit Number: 18WE0763 AIRS( ID Number: 123 /9FD5/004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical. Coordinates (Latitude/Longitude or UTM) 40.341138, -104.997324 Discharge Height Abov e Ground Level Temp Flow Rate (ACM Velocl eft .ex - O erator ' Stack ID No 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) 0Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 2898.13 Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO .«Pumi% l EdhlihF Erviq. f Jesser 3-I VRT Gas Venting Permit Number: 18WE0763 AIRS ID Number: 123 /9FD5/004 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant — Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 _ Uncontrolled Basis Units_(?P Source 42 Mfg,, etc.) Uncontrolled Emissions (tons/year) - Controlled Emissions6 (tons/year) Uncontrolled Emissions -:- (tons/year). = Controlled - Emissions (tons/year) PM SOX NO. CO 0.31 Ib/MMBtu AP -42 Chapter 13.5 0.108 0.108 - 0.988 - 0.988 VOC 120,305.326 lb/MMscf sit. Specific Sampling 14.437 / 0.722 ' 132.336 , 6.617 , Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled _ Basis Units Source (AP 42,r Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,271.473 Ib/MMscf Site Specific Sampling 545.154 27.258 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 IA COLORADO 0.y,m Hol➢uWc FwahE F.nvi:cnmrnl Jesser 3-I VRT Gas Venting APEN Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson L'2/0l20 l ate 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) Send this form along with $152.90 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: / /www.colorado.gov/cdphe/apcd Form APCD-2O5 -Natural Gas Venting APEN Rev 03/2017 6 I cotta AO CI a..e.,.If - See_ A c Re co ,2_,), Jesser 3-I LP Gas Venting APEN Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit JUN 252IB D 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 Natural Gas Venting only. Natural 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. 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: wErn (Q4 AIRS ID Number: 123 / FD6/ 006 [Leave blank unless APCD has already ar,signed a permit ft and AIRS ID] Company equipment Identification: LP Gas Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. Jesser 3-I Production Facility Site Location: NWSW Sec 3 T4N R68W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 E -Mail Address': ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 'Please 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 APCD via e-mail to the address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 I 38'311-5 ©1.©ithbel ➢rrQment •I rift Amax. 11worraam li (, Jesser 3-I LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ▪ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR - • APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: Please issue individual permit for LP Gas Venting. 3 For 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. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 3 / 27 / 2018 ✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year Yes ❑ Yes ❑ No No <COL4lt100r Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I Jesser 3-I LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 5000 SCF/hr Vent Gas Heating Value: 2036.75 BTU/SCF Requested: 16.50 MMSCF/year Actual: 1.80 MMSCF/year -OR- Requested: N/A Bbl/yr Actual: N/A Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 36.38 lb/lbmol VOC (mole %) 41.873 VOC (Weight %) 64.616 Benzene (mole %) 0.106 Benzene (Weight %) 0.228 Toluene (mole %) 0.109 Toluene (Weight %) 0.275 Ethylbenzene (mole %) 0.011 Ethylbenzene (Weight %) 0.031 Xylene (mole %) 0.046 Xylene (Weight %) 0.135 n -Hexane (mole %) 0.782 n -Hexane (Weight %) 1.852 2,2,4-Trimethylpentane 2,2,4-Trimethylpentane (mole %) 0.000 (Weight %) 001 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX a* n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and pressure) O Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 31 DOo Allpillamet rS Jesser 3-I LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it and AIRS IDS Section 5 - Stack Information 40.341138, -104.997324 .ea 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) ✓❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency VRU Downtime or Bypassed Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr 95% 98% % % Waste Gas Heat Content Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 Permit Number: Jesser 3-I LP Gas Venting APEN AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction) PM SOX NO„ VOC ECD 95% CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the -criteria pollutant emissions from source: CIO P •go e a s g.E mrs7y nrr u T d fir, e r con 6 ors r `I1 .-,W PM SOX. NO. 0.068 IbN0x/MMBtu AP -42 0.125 / 0.125 1.143 1.143 VOC 61.950 IbV0C/MSCF SIMSPedficSanpping 55.755 / 2.788 ' 511.085 -- 25.554, CO 0.310 IbCO/MMBtu AP -42 0.568 ' 0.568 -- 5.209 — 5.209 Benzene 0.219 IbBenzene/MSCF SlleSpecific Sampling 0.197 - 0.010 ' 1.803 0.090 - Toluene 0.264 IbToluene/MSCF sit. specific sampling 0.237 - 0.012 - 2.176 / 0.109 - Ethylbenzene 0.030 IbEthylbenzene/MSCF Site Specific Sampling 0.027 - 0.001 . 0.245 --- 0.012 Xylenes 0.129 IbXylenes/MSCF sit. SpecigcSampling 0.116 - 0.006 .' 1.065 0.053 n -Hexane 1.776 Ibn-Hexane/MSCF See Specific Sampling 1.598 - 0.080 - 14.649' 0.732 ' 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 -Natural Gas Venting, APEN - Rev 03/2017 5 I tiida Jesser 3-I LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank.unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. C9V1P-VC Signature of Legally A t orized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 6 I gf?_r Ive A 1 -1 -kA v;c 1 Jesser 3-I LP Gas Venting Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.6ov/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: 18WE0764 AIRS ID Number: 123 19FD5 /005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Extraction Oil & Gas, Inc. Jesser 3-I Production Facility NWSW Sec 3 T4N R68W Mailing Address: 370 17th St. Suite 5300 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Catie Nelson Phone Number: 720-354-4579 E -Mail Address': cnelson@extractionog.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices wilt be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I !COLORADO Department Public Douu_aiM. Jesser 3-I LP Gas Venting Permit Number: 18WE0764 AIRS ID Number: 123 /9FD5/005 [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2 - Requested Action Q 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 It 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: 3/27/2018 Q 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? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No COLORADO 2 I �_� �e .7„t �', xc�i*mse�v�mnmore Jesser 3-I LP Gas Venting Permit Number: 18W E0764 AIRS ID Number: 123 / 9FD5 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Capacity: gal/min 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: 2054.98 BTU/SCF Requested: 4.000 MMSCF/year Actual: 1 .800 MMSCF/year -OR- Requested: N/A bbl/year Actual: N/A bbl/year Molecular Weight: 36.2250 VOC (Weight %) 64.463 Benzene (Weight %) 0.2289 Toluene (Weight %) 0.2763 Ethylbenzene (Weight %) 0.0311 Xylene (Weight %) 0.1352 n -Hexane (Weight %) 1.8601 2,2,4-Trimethylpentane (Weight %) 0.0014 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX It n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I !COLORADO Dane orn,nt. Hea!Th f Enrim'v h , l Jesser 3-I LP Gas Venting Permit Number: 18WE0764 AIRS ID Number: 123 /9FD5/005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.341138, -104.997324 Ope afo S ck D 0= *_r - Discharge Height a round Level = (Feet) Temp. (° F) Flow Rate (ACFM) _.e Velocity (ft/sec) 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) ID Circular Other (describe): Interior stack diameter (inches): [] 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. VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC, HAPs ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Btu/scf Waste Gas Heat Content: 2054.98 Constant Pilot Light: Q✓ Yes No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 4I NCOLORAOO tore Kaa0hfr Erwfennmonl Jesser 3-I LP Gas Venting Permit Number: 18WE0764 AIRS ID Number: 123 / 9FD5 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (/ reduction in emissions) PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant_ Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units ' Source (AP 42"' Mfg, etc.) _ Controlled ] Emissions (tons/year) Uncontrolled: Emissions - (tons/year) C ontrolled Emissions (tons/year) Uncontrolled Emissions (tons/year) PM SOX NO. CO 0.31 Ib/MMBtu AP-42Chapter13.5 0.573 - 0.573 / 1.274 ./ 1.274" VOC 61,614.086 lb/MMscf SiteSpecificSampling 55.453 l 2.773 r 123.228 ' 6.161. Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name - Chemical Abstract (CAS) ( ) Number Emission Factor - Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (Pounds/year) Benzene 71432 218.801 lb/MMscf Site SpeclgoSamPling 393.842 ' 19.692 Toluene W8883 264.109 lb/MMscf Site Speak Sampling 475.396 / 23.770 7 Ethylbenzene 100414 Xylene 1330207 129.245 Ib/MMscf Sae Specific Sampling 232.640 / 11.632 n -Hexane r 110543 1,777.914 lb/MMscf SiteSpecificSampling 3,200.246 / 160.012 2,2,4- Trimethylpentane 540841 Other: ) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 5I COLORADO noaims��acnm�ii Jesser 3-I LP Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally A t orized Person (not a vendor or consultant) Kathy Steerman O\,c6 Date Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 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 Telephone: (303) 692-3150 Form APCD-205 •Natural Gas Venting APEN • Rev 03/2017 For more information or assistance call: Small Business Assistance Program (303) 692.3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd toti7RA,G 6 IAt, a,.. z= Hello