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Home My WebLink About20192070.tiffCOLORADO Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 May 29, 2019 Dear Sir or Madam: RECEIVED MAY 3 1 201D WELD COUNTY COMMISSIONERS On May 30, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil &t Gas, Inc. - Hergert - Launer 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 PUb\ic P%Jj eu-) Co/l0/la CC: PL.CTp) NLCS 1, QW M?ER /cm IGV-) 51311 ►A 2019-2070 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil & Gas, Inc. - Hergert - Launer Production Facility - Weld County Notice Period Begins: May 30, 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: Hergert - Launer Production Facility Exploration Et Production Well Pad NENE Quadrant of Section 35, Township 7N, Range 67W Weld County The proposed project or activity is as follows: The Hergert - Launer Production Facility is a new Oil and Gas Well Pad located in Weld County. It processes a 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 18WE1039.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: James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 Ayr COLORADO 1 I . art COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1039 Issuance: 1 Date issued: Issued to: Extraction Oil &t Gas, Inc. Facility Name: Hergert - Launer Production Facility Plant AIRS ID: 123/9FF9 Physical Location: NENE Quadrant of Section 35, Township 7N, Range 67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TKs 001-008 001 Eight (8) 400 barrel fixed roof storage vessels used to store condensate 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, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall 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,t VOC CO TKs 001-008 001 0.0 0.4 10.5 1.8 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health Es Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled TKs 001-008 001 Enclosed Combustor VOC and HAPs PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TKs 001-008 001 Condensate Throughput 3,058,471 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1,'2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. 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 XII.C, XVII.B.2. and XVII.A.16) Page 4 of 10 COLORADO Mr Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,t) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit Number AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit 18WE1039.CP1 001 Condensate Storage VOC 100 10.5 18WE1040.CP1 002 Produced Water Storage VOC 100 0.6 18WE1041.CP1 003 Venting - LP Separator Gas VOC 100 46.4 18WE1042.CP1 004 Venting - VRT Flashed Gas VOC 100 27.4 GP02 005 CAT G3508BLE Engine 690hp SN: RBK01117 VOC 100 4.7 SUM VOC 100 89.6 GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B.;,upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable: Otherwise, the issuance of this construction permit does not provide "final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties),' -122.1 (criminal penalties), C.R.S. DRAFT James Ricci Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction 0il'£ Gas, Inc. for condensate storage tanks at a synthetic minor facility in the non -attainment area Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:'https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 1018 51 Toluene 108883 821 41 Ethylbenzene 100414 69 3 Xylenes 1330207 255 13 n -Hexane 110543 6748 337 2,2,4-Trimethylpentane 540841 63 3 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 2.56 x 10"4 AP -42 Chapter 13.5 CO 1.17 x 10-3 V0C 1.38 x 10-1 6.88 x 10-3 ProMax + TANKS 4.0 Modeling with Liquid Site Specific Sample 71432 Benzene 3.33 x 10-4 1.66 x 10-5 108883 Toluene 2.68 x 10-4 1.34 x 10"5 100414 Ethylbenzene 2.27 x 10-5 1.13 x 10-6 1330207 Xylene 8.33 x 10-5 4.16 x 10-6 110543 n -Hexane 2.21 x 10"3 1.10 x 10-4 540841 2,2,4-Trimethylpentane 2.05 x 10"5 1.02 x 10.6 , Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: V0C, n -Hexane, Toluene, Benzene, Total HAPs NANSR Synthetic Minor Source of: V0C MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: James Ricci 388075 8/21/2018 2/6/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc. County AIRS ID: 123 Quadrant Section Township Range NENE 35 7N 67 Plant AIRS ID: Facility Name: Location: County: Type of Facility: 9FF9 Hergert - Launer Production Facility NENE Quadrant of Section 35, Township 7N, Range 67W Weld County Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? C Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) ❑, Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank TKs 001-008 Yes 18WE1039.CP1 1 Yes Permit Initial Issuance Section 03 - Description of Project A commingled liquid stream (containing natural gas, condensate and produced water) flows from twenty-four (24) wellheads to twenty-four (24) inlet high -low pressure ("HLP") 3 -phase separators. The HLP separators split the fluids into individual phases (natural gas, condensate and produced water). The condensate flows to a VRT. Flash emissions from the VRT are routed to a vapor recovery unit ("VRU") onsite under normal operating conditions. The resulting condensate is routed to eight (8) 400 bbl condensate storage tanks. Emissions from the condensate storage tanks are sent to ECDs rated at >98% destruction efficiency. Extraction Oil & Gas, Inc. has submitted an APEN associated with the emissions from the eight (8) 400 bbl condensate storage tanks. They have requested a construction permit for this emission point. • Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement≤ Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here 5O2 NOx Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ No Yes 5O2 NOx CO VOC 7 No Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ El PM2.5 PM10 TSP HAPs ❑ ❑ ❑ E Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank 'Facility AIRs ID: 123 9FF9 001 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Eight (8) 400 barrel fixed roof storage vessels used to store condensate Enclosed Combustors, Manufacturer Guaranteed 98% Control Efficiency 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit Condensate Throughput = 2,216,283 3,058,471 3,058,471 Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes 2468 1.5 Actual Condensate Throughput While Emissions Controls Operating = 2,216,283 Requested Monthly Throughput = 259761 Barrels (bbl) per month Btu/scf scf/bbl 8,342 MMBTU per year 11,512 MMBTU per year 11,512 MMBTU per year Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 1.38E-01 6.88E-03 Site Specific E.F. (includes flash) Benzene 3.33E-04 1.66E-05 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Toluene 2.68E-04 1.34E -0S Ethylbenzene I 2.27E-05 V 1.13E-06 Xylene 8.33E-05 4.16E-06 Site Specific E.F. (includes flash) n -Hexane 2.21E-03 1.10E-04 Site Specific E.F. (includes flash) 224 TMP 2.05E -0S 1.02E-06 Site Specific E.F. (includes flash) Control Device Emission Factor Source Uncontrolled Uncontrolled I Pollutant (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 0.0000 AP -42 Table 1.4-2 (PM10/PM.2.S) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 0.0000 NOx 0.0680 0.0003 CO 0.3100 0.0012 Section 05 - Emissions Inventcry From ProMax From ProMax + Estimated W&B Emissions (lb/bbl) Flash (From ProMax) W&B (From TANKS) 0.0510 0.086628855 0.000123332 0.000210 9.94442E-05 0.000169 8.39635E-06 0.000014 3.08413E-05 0.000052 0.00081719 0.001389 7.58429E-06 0.000013 Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 210.4 152.5 7.6 210.4 10.5 1787 0.0 0.0 0.0 0.0 0.0 7 0.0 0.0 0.0 0.0 0.0 7 0.4 0.3 0.3 0.4 0.4 66 1.8 1.3 1.3 1.3 1.8 303 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Uncontrolled (lbs/year) Limits Controlled (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1013 738 37 1018 51 821 595 30 821 41 69 50 3 69 3 255 185 9 255 13 6748 4890 245 6748 337 63 45 2 63 3 Section 06 - Regulatory Summary Analysis Barrels (bbl) per year Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2 of 4 K:\PA\2018\18W E1039.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. N/A Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), ther it may be appropriate to use an older site -specific sample. If no, the permit will contain an 'Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Yes 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 A pressurized liquid sample was taken from the Launer 26W -15-8C well at the Hergert/Launer facility on 8/21/2018 and analyzed by Alliance Source Testing on 8/23/2018. Based on the probe, the sample was taken at 110 deg F and 61.9 psig. The applicant ran this pressurized sample through ProMax by sending it through a VRT which had two outputs, VRT Oil and VRT Vapors. The VRT Oil then flowed to the condensate tank inlet which also had two outputs, Oil Loaded and Gil Tank Flash Vapors. The Oil Loaded was set to 1 bbl/day to normalize emissions. Oil Tank Flash Vapors stream data was used to calculate flash emissions from these tanks. The applicant than used TANKS 4.0.9d to estimate working and breathing losses associated with these tanks. RVP = 11.5 was assumed to be the tank contents in the model. This is conservative based on three random COGCC Production data points (41.225 API Gravity, 41.233 API Gravity and 41.32 API Gravity and the API —> RVP equation in PS Memo 14-03. ProMax also modeled the RVP of Oil Loaded as 10.8492. TANKS was able to estimate W&B losses for each tank which was assumed to be 100% VOC. Weight percentages from the ProMax flash simulations were used to estimate HAP W&B Emissions. The flash emissions from ProMax were combined with the W&B losses from TANKS to develop the site specific emission factors. The heating value and waste gas value were also modeled in ProMax to determine the secondary emissions from the combustor. Only the flash waste gas could be determined using ProMax so W&B waste gas was calculated using the VOC ratio between Flash & W&B losses and multiplying flash waste gas by this ratio. ................ Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # 01 SCC Code 4-04-003-11 Fixed Roof Tank, Condensate, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 Ib/1,000 gallons condensate throughput NOx 0.01 0 Ib/1,000 gallons condensate throughput VOC 3.3 95 lb/1,000 gallons condensate throughput CO 0.03 0 lb/1,000 gallons condensate throughput Benzene 0.01 95 lb/1,000 gallons condensate throughput Toluene 0.01 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.00 95 lb/1,000 gallons condensate throughput n -Hexane 0.05 95 Ib/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 4 K:\PA\2018\18WE1039.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes No Yes Source requires a permit Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section XIt.C -F Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII C.2 - Emission Estimation Procedures Section XII.D- Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Yes Yes Yes Yes No Yes Storage Tank is not subject to Regulation 7, Section XII.G Section XII G.2 - Emissions Control Requirements Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII C.2 — Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC? No Yes Yes Yes Storage tank is subject to Regulation 7, Section XVII, B. CA & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? No Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) ["472 BBLsj? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer2 as defined in 60.11lb? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.1116? 5. Does the storage vessel store a "volatile organic liquid (VOL)"5 as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [-29.7 psij and without emissions to the atmosphere (60.11ob(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressure° less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 [`472 BBL] but less than 151 m3 ("950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11ob(b))? No NA NA NA NA NA Source Req Go to next Source Req Continue - ' Continue -' Source is st Continue - Storage Tar Source is st Continue -' Go to the n Go to the n Source is st Source is si Storage Tai Storage Tank is not subject to NSPS K Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions= from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS OOOO NA NA NA YcS No NA NA Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids2 (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user3 (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"5 per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Storage Tank is not subject to MACT HI - Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. in the event of any conflict between the language of this document and the language of the Clean Air Act,. its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as recommend, " "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself NA No NA NA NA Continue -' Storage Tar Continue - Storage Tar COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1040 Issuance: 1 Date issued: XX Issued to: Extraction Oil &t Gas, Inc. Facility Name: Hergert - Launer Production Facility Plant AIRS ID: 123/9FF9 Physical Location: NENE Quadrant of Section 35, Township 7N, Range 67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description PW 001-002 002 Two (2) 400 barrel fixed roof storage vessels used to store produced water 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, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall 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,t VOC CO PW 001-002 002 0.0 0.0 0.6 0.2 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled PW 001-002 002 Enclosed Combustor VOC and HAPs 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 andmade available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Poirrt Process Parameter Annual Limit PW 001-002 002 Produced Water Throughput 1,348,992 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shallcalculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0&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.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant:' If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit Number AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit 18WE1039.CP1 001 Condensate Storage VOC 100 10.5 18WE1040.CP1 002 Produced Water Storage VOC 100 0.6 18WE1041.CP1 003 Venting - LP Separator Gas VOC 100 46.4 18WE1042.CP1 004 Venting - VRT Flashed Gas VOC 100 27.4 GP02 005 CAT G3508BLE Engine 690hp SN: RBK01117 VOC 00 4.7 SUM VOC 10O;_, 89.6 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.8. 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. Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. for produced water storage tanks at a synthetic minor facility in the non -attainment area Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health @ F.nuironment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated ..in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:https://www.colarado.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) 002 Benzene 71432 701 35 Toluene 108883 399 20 Ethylbenzene 100414 28 1 Xylenes 1330207 107 5 n -Hexane 110543 261 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 Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health 6, Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 5.15 x 10"5 AP -42 Chapter 13.5 CO 2.35 x 104 VOC 1.84 x 10-2 9.21 x 10-4 Flash Liberation Analysis 71432 Benzene 5.20 x 10-4 2.60 x 10-5 108883 Toluene 2.96 x 10-4 1.48 x 10"5 100414 Ethylbenzene 2.07 x 10-5 1.03 x 10-6 1330207 Xylene 7.95 x 10-5 3.98 x 10-6 110543 n -Hexane 1.93 x 10-4 9.66 x 10-6 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shalt be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN ` expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Toluene, Benzene, Total HAPs NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: James Ricci Package #: 388075 Received Date: 8/21/2018 Review Start Date: 2/6/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc. County AIRS ID: 123 Quadrant Section Township Range NENE 35 7N 67 Plant AIRS ID: Facility Name: Location: County: 9FF9 Hergert - Launer Production Facility NENE Quadrant of Section 35, Township 7N, Range 67W 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? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes n Particulate Matter (PM) ❑✓ Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit If Issuance # Self Cert Required? action Engineering Remarks 002 Produced Water Tank PW 001-002 Yes 18WE1040.CP1 1 Yes Permit Initial Issuance Section 03 - Description of Project A commingled liquid stream (containing natural gas, condensate and produced water) flows from twenty-four (24) wellheads to twenty-four (24) inlet high -low pressure ("HLP") 3 -phase separators. The HLP separators split the fluids into individual phases (natural gas, condensate and produced water). The produced water streams exit the HLP separators and is sent to two (2) 400 bbl produced water storage tanks. Emissions from the produced water storage tanks are sent to ECDs rated at >98% destruction efficiency. Extraction Oil & Gas, Inc. has submitted an APEN associated with the emissions from the two (2) 400 bbl produced water storage tanks. They have requested a cons -ruction permit for this Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greater than 25 tons per year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. No Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ J ❑ LI C Title V Operating Permits (OP) ❑ ❑ EDO ] E ,] Non -Attainment New Source Review (NANSR) ❑ ❑ No Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ ❑ LI o ❑ ❑ ❑ o ❑ ❑ No Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 County 9FF9 Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Two (2) 400 barrel fixed roof storage vessels used to store produced water Emissions are sent to ECDs rated at >98% destruction efficiency. (95% Claimed) 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Wafer Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 1,124,160 1,348,992 1,348,992 1263 0.6 Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Btu/scf scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes Actual Produced Water Throughput While Emissions Controls Operating = Requested Monthly Throughput = 114572 Barrels (bbl) per month Net Dry Real, From Flash Liberation Analysis Flash Liberation Results 852 1,022 MMBTU per year MMBTU per year 1,022 MMBTU per year [mission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water Throughput) (Produced Water Throughput) VOC 1.84E-02 9.21E-04 Site Specific E.F. (includes flash) Benzene 5.20E-04 2.60E-05 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Toluene 2.96E-04 1.48E-05 Ethylbenzene 2.07E-05 1.03E-06 Xylene 7.95E-05 3.98E-06 n -Hexane 1.93E-04 9.66E-06 224 TMP 0.00E+00 0.00E+00 Pollutant Control Device Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat combusted) (Produced Water Throughput) PM10 7.45E-03 5.64E-06 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 7.45E-03 5.64E-06 NOx 6.80E-02 5.15E-05 CO 3.10E-01 2.35E-04 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC 12.4 10.4 0.5 12.4 0.6 106 PM10 PM2.5 NOx 0.0 0.0 0.0 0.0 0.0 1 0.0 0.0 0.0 0.0 0.0 1 0.0 0.0 0.0 0.0 0.0 6 CO 0.2 0.1 0.1 0.2 0.2 27 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 701 584 29 701 35 Toluene 399 333 17 399 20 Ethylbenzene Xylene 23 23 1 28 1 107 89 4 107 5 n -Hexane 261 217 11 261 13 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis 69.49338072 5.15E-05 316.8080592 2.35E-04 1,124,160 Regulation 3, Parts A, B Source requires APEN, is permit exempt Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO (See regulatory applicability worksheet for detailed analysis) 2 of 5 K:\PA\2018\18WE1040.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Yes Does the company request a control device efficiency greater than 95% for a flare or combustion device? No 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 A sample of pressurized water was taken by AIM from the Hergert/Launer site on 8/21/18, Unit ID Launer 26W-15-8C(c). It was analyzed by Alliance Source Testing on 8/23/18 by Analyst CLB, Cylinder Number 37373. The sample was taken at 58 psig and 114 deg F. The pressurized water was flashed from 58psig and 114 deg F to 12.4 psia and 60 deg F. Base conditions were assumed to be 12.4 psia and 60 deg F. The Gas Water Ratio was reported to be 0.6 SCF flashed gas/bbl stock tank liquid. It was assumed that this value was already converted to standard condition since it is reported as "SCF" An extended analysis of the flashed gas from the pressured water was also supplied. Mass Fraction Percentages from this analysis were used along with the MW reported to develop site specific emission factors on a per bbl basis. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 007 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 Ib/1,000 gallons liquid throughput NOx 0.00 0 Ib/1,000 gallons liquid throughput VOC 0.4 95 lb/1,000 gallons liquid throughput CO 0.01 0 lb/1,000 gallons liquid throughput Benzene 0.01 95 Ib/1,000 gallons liquid throughput Toluene 0.01 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 Ib/1,000 gallons liquid throughput n -Hexane 0.00 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 3 of 5 K:\PA\2018\18WE1040.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emission! greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area Yes NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.0.2)? Yes Yes Source requires APEN, is permit exempt Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor station' or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional prcvisions apply. Ltorage tank is subject to Regulation 7, Section XVII.C Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transm ssion and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? Storage Tank is not subject to NSPS OO00 Source Req Source is Al Source is Al No Continue -' Yr Continue -' Yes Go to the n Source is si Yes No Yes Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements (Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations. the language of the statute or regulation will control The use of non -mandatory language such as 'recommend,"'may." 'should "and 'can is intended to describe APCD interpretations and recommendations Mandatory terminology such as 'must.. and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself No NA NA Source is sL Continue -' Storage Tar EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C *Xx/C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm MW 32.7091 Ib/Ib-mol Throughput 1348992 bbl/year Gas -to -Oil Ratio (GOR) 0.6 scf/bbl mass fraction (%) Emission Factor (lb/bbl) Emissions (lbs/year) Helium 0.00 0.000E+00 0.00 CO2 19.89 1.029E-02 13875.58 N2 7.84 4.057E-03 5472.45 H2S 0.00 0.000E+00 0.00 methane 14.37 7.430E-03 10022.77 ethane 22.28 1.152E-02 15541.33 propane 20.41 1.055E-02 14234.83 isobutane 1.89 9.751E-04 1315.43 n -butane 6.28 3.246E-03 4379.20 isopentane 1.06 5.487E-04 740.13 n -pentane 1.33 6.881E-04 928.20 cyclopentane 0.34 1.752E-04 236.41 n -Hexane 0.37 1.9314E-04 260.55 cyclohexane 0.27 1.400E-04 188.90 Other hexanes 0.81 4.197E-04 566.16 heptanes 0.29 1.489E-04 200.83 methylcyclohexane 0.23 1.172E-04 158.07 224-TMP 0.00 0.000E+00 0.00 Benzene 1.00 5.19543E-04 700.86 Toluene 0.57 2.95995E-04 399.30 Ethylbenzene 0.04 2.068E-05 27.90 Xylenes 0.15 7.953E-05 107.29 CS 0.20 1.054E-04 142.24 C9 0.07 3.604E-05 48.62 C10 0.30 1.565E-04 211.09 C11+ 0.00 0.000E+00 0.00 Total 100.00 VOC Wt % 35.62 1.842E-02 12.42301 GOR Conversion Check Actual Pressure (P1) 1 psia Actual Temperature (T1) 1 Rankine Actual GOR (V1) 1 cf/bbl Standard Pressure (P2) 1 psia Standard Temperature (T2) 1 Rankine Standard GOR (V1) 1 scf/bbl COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1041 XX Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil £t Gas, Inc. Hergert - Launer Production Facility 123/9FF9 NENE Quadrant of Section 35, Township 7N, Range 67W Weld County Well Production Facility Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 003 Venting of Low Pressure Separator Gas 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, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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: AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO 003 0.6 5.3 46.4 24.0 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. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 003 During VRU downtime, low pressure separator gas is routed to an Enclosed Combustor 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, Process Limits AIRS Point Process Parameter Annual Limit 003 Natural Gas Venting 88.97MMSCF Compliance with the annual throughput limits shall be determined on a rol ing 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. 10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING! Initial Testing Requirements 16. 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) 17. A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. 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,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the levelreported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less,above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. 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). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Department of Pubic Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit Number AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit 18WE1039.CP1 001 Condensate Storage VOC 100 10.5 18WE1040.CP1 002 Produced Water Storage VOC 100 0.6 18WE1041.CP1 003 Venting - LP Separator Gas VOC 100 46.4 18WE1042.CP1 004 Venting - VRT Flashed Gas VOC 100 27.4 GP02 005 CAT G3508BLE Engine 690hp SN: RBK01117 VOC 100 4.7 SUM VOC 100 89.6 GENERAL! TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied 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. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. for venting of low pressure separator gas during VRU downtime at a synthetic minor facility in the non -attainment area Page 7 of 10 COLORADO Air Pollution Control Division Department of Pubiic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part, II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions J' (lb/yr) Benzene 71432 15481 310 003 Toluene 108883 19391 388 Ethylbenzene 100414 2965 59 Xylenes 1330207 12027 241 n -Hexane 110543 88407 1768 2,2,4-Trimethylpentane 540841 104 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Mr Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 1.18 x 10z AP -42 Chapter 13.5 CO 5.40 x 10 VOC 5.22 x 104 1.04 x 103 Extended Gas Analysis y 71432 Benzene 1.74 x 102 3.48 x 10° 108883 Toluene 2.18 x 102 4.36 x 10° 100414 Ethylbenzene 3.33 x 101 6.66 x 10"t 1330207 Xylene 1.35 x 102 2.70 x 10° 110543 , n -Hexane 9.94 x 102 1.99 x 101 540841 2,2,4-Trimethylpentane , 1.17 x 10° 2.34 x 10-2 Note: The controlled emissions factors for this point are based on the Enclosed Combustor control efficiency of 98%. The emission factors listed above are based on separator temperature of 108 °F and separator pressure of 56 psig 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Toluene, Benzene, Total HAPs NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health Is Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer Package # Received Date Review Start Date 'Ja`me's Rica '34075 388075 -. rs/21/2018 (2/6/2019 Section 01- Facility Information Company Name iExtractioSOd &Gas" Iunc, m County AIRS ID 123 Plant AIRS ID 9FF9, Facility Name ii-LaunersProducnorJ Facility,, Location NENE Quadrant of Section 35, Township 7N Range 67W LCounty Weld County Type of Facility Exploration & Productio> Well Pad " v .71-71-...77-'-'7. rr What industry segment?Oil,& Netural,Ga5Pjgductiorr & Processing Is this facility located in a NAAQS non attainment area? 1, LL ,, "(Y If yes, for what pollutant? O \ carbon Monoxide (CO) - Section 02 - Emissions Units In Permit Application i ❑ Particulate Matter (PM) 9 Quadrant Section Township Range �h �NEfJE�r Ozone (Nth ® VOC) 7Nyax AIRS Point 8 - Emissions Source Type Equipment Name / Emissions Control' Permit q Issuance #Required? Self Cert Action Engineering Remarks %.44N 0O3 ' 093"""' t rt {J r'i > 4xY i Separator - r i ,. "x'x x _ 9 Y 1 , ct , yes "` 4�R� 5 7c^c v�x.,c ` x b+� 18WE1041 CPI" o�yn �`r� k� t t5^Y »1 ( rtin1 ,�� yid 1 Y^ 4� ;Yes < Permit,lnitial9 iy b >Issuancerr *+°u' � + fir ttie � _ A hoax ?,,z,T.+4 � i%3'^ r "":� A'.,ri!-;F2'p v 's.- `-r�."t � � d s iy;r, xY,.e.r,= � i+ ,.. x < .- mss'}"<§ ` Section 03 - Description of Project Section 04 Public Comment Requirements Is Public Comment Required? t: '` _ Yes - } If yes, why? da r Requesting Synthetic Minor Permit„ Section 05 -Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? E v"fs If yes, attach a copy of Technical Services Unit modeling results summary Section 06 - Facility Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non Attainment New Source Review (NANSR) ,No N f:j tf .`iYes,t r``wd`,. tai S02 NOX CO VOC PM2 5 PM10 TSP HAPs ❑ O ❑ ❑ O ❑ ❑ ❑ ❑ © ❑ ❑ ❑ O Is this stationary source a major source? F , — If yes, explain what programs and which pollutants here SO2 NOx CO VOC PM2 5 PM10 TSP HAPs Prevention of Significant Deterioration (P5D) ❑ O O O O O Title V Operating Permits (OP) O O O O O O O O Non -Attainment New Source Review (NANSR) O O J 1 Separator Venting Emissions Inventory 003 Separator Venting Facility AIRs ID: 123 County 9FF9 Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Venting of low pressure seperator gas while the vapor recovery unit is bypassed Emission Control Device Description: Enclosed Combustor Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented Yes, meter is currently installed and operational Based on correspondence with applicant Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 71.2 MMscf per year Requested Permit Limit Throughput = 89.0 MMscf per year Potential to Emit (PTE) Throughput = 89 MMscf per year Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: o- Yes Yes Requested Monthly Throughput = 8 MMscf per month Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies 1742 Description Btu/scf scf/bbl Net Dry Real, From Lab Analysis The low-pressure gas streams are captured with the vapor recovery unit ("VRU") under normal operating conditions. Under certain conditions, the VRU can be bypassed and the flash gas can be vented. A LP Separator Gas sample was taken on 8/21/18 at 56 psig and 108 deg F by AIM, Cylinder Number GV-16 at the Herget/Lauer site (Unit ID Launer 26W-15-8C(c)). It was analyzed by Alliance Source Testing on 8/23/18, Lab Analyst CLB. Weight% of this sample are entered below are used to derive site specific emission factors. MW 34.17 Ib/Ib-mol Displacement Equation Ex = Q' MW ' Xx / C Weight % Oxygen/Helium 0.23 CO2 2.91 N2 0.99 methane 16.40 ethane 21.53 propane 28.39 isobutane 4.03 n -butane 11.69 isopentane 2.74 n -pentane 3.34 cyclopentane 0.30 n -Hexane 1.10 cyclohexane 0.35 Other hexanes 1.86 heptanes 1.18 methylcyclohexane 0.52 224-TMP 0.00 Benzene 0.19 Toluene 0.24 Ethylbenzene 0.04 Xylenes 0.15 C8+ Heavies 1.83 Total V0C Wt % 100.00 57.95 Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor Source (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 5.22E+04 1.41E+03 Extended gas analysis Extended gas analysis Benzene 1.74E+02 3.48E+00 Toluene 2.18E+02 4.36E+00 Extended gas analysis Ethylbenzene 3.33E+01 6.66E-01 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Xylene 1.35E+02 2.70E+00 n -Hexane 9.94E+02 1.99E+01 224 TMP 1.17E+00 2.34E-02 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 12.981 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 12.981 SOx 0.0006 1.025 NOx 0.0680 118.472 CO 0.3100 540.093 K:\PA\2018\18W E 1041.CP 1.xlsm 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 0.58 0.46 0.46 0.6 0.6 98 0.58 0.46 0.46 0.6 0.6 98 SOx 0.05 0.04 0.04 0.0 0.0 8 NOx 5.27 4.22 4.22 5.3 5.3 895 VOC 2321.67 1857.44 37.15 2321.7 46.4 7887 CO 24.03 19.22 19.22 24.0 24.0 4081 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 15481 12385 248 15481 310 Toluene 19391 15514 310 19391 388 Ethylbenzene 2965 2372 47 2965 59 Xylene 12027 9622 192 12027 241 n -Hexane 88407 70729 1415 88407 1768 224 TM P 104 83 2 104 2 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 XVI1.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? Yes This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. 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 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. Using ` uld 1 h of ghp Does the company use site specific emission factors based on a pressurized liquid sampl equipment covered under this AiRs ID) and process simulation to estimate emissions? This sample should have been collected within one year of the application received date. How new wells brought on-line), then it May be appropriate to tie an older site -specific sample. If no, the permit will contain an "initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission fact analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this applicatio Does the company request a control device efficiency greater than 95%.for a flare or combustion device If yes, the permit will contain .and Thal inlet and outlet concentration sampf 3 of 5 K:\PA\2018\18WE1041.CP1.xlsm Separator- Venting Emissions Inventory Section 08 - Technical Analysis Notes The weight% entered in the analysis above were taken directly from the lab analysis. The applicant's calculations slightly differed. This could have been due to converting Mol% to Weight% or more significant figures could have been supplied to them from the testing company. However, controlled emission calculated are nearly identical, their calculation method is acceptable. Based on correspondence with the applicant, a flowmeter is already installed to directly measure low pressure separator gas sent to the control device. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 12.98 0 lb/MMSCF PM2.5 12.98 0 lb/MMSCF SOx 1.02 0 lb/MMSCF NOx 118.47 0 Ib/MMSCF VOC 52189.86 98 Ib/MMSCF CO 540.09 0 lb/MMSCF Benzene 174.00 98 lb/MMSCF Toluene 217.95 98 lb/MMSCF Ethylbenzene 33.32 98 Ib/MMSCF Xylene 135.18 98 lb/MMSCF n -Hexane 993.67 98 Ib/MMSCF 224 TMP 1.17 98 lb/MMSCF 4 of 5 K:\PA\2018\18WE1041.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit Yes Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Yes Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change cr substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as "recommend." 'may," "should," and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. No Source Req Source Req Source is si. The control COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1042 Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Extraction Oil a Gas, Inc. Hergert - Launer Production Facility 123/9FF9 NENE Quadrant of Section, 35, Township 7N, Range 67W Weld County Well Production Facility Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 004 Venting of VRT gas 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, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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: AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO 004 0.3 2.3 27.4 10.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 004 During VRU downtime, VRT gas is routed to an Enclosed Combustor 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 AIRS Point Process Parameter Annual Limit 004 Natural Gas Venting 30.79 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. 10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit.' Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. 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) 17. A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days .prior to testing. No compliance test shall be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) Page 4 of 10 COLORADO Air Pollution Control Division Department of Pubitc Health & Environmen i Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons, per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. 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). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit Number AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit 18WE1039.CP1 001 Condensate Storage VOC 100 10.5 18WE1040.CP1 002 Produced Water Storage VOC 100 0.6 18WE1041.CP1 003 Venting - LP Separator Gas VOC 100 46.4 18WE1042.CP1 004 Venting - VRT Flashed Gas VOC 100 27.4 GPO2 005 CAT G3508BLE Engine 690hp SN: RBK01117 VOC 100 4.7 SUM VOC 100 89.6 GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied 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. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. for venting of VRT gas during VRU downtime at a synthetic minor facility in the non -attainment area Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application farm 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 ail of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 4254 85 004 Toluene 108883 1642 33 Ethylbenzene 100414 84 2 Xylenes 1330207 258 5 n -Hexane 110543 41529 831 2,2,4-Trimethylpentane 540841 17 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. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 1.51 x 10Z AP -42 Chapter 13.5 CO 6.88 x 10 VOC 8.90 x 104 1.78 x 103 Extended Gas Analysis y 71432 Benzene 1.38 x 102 2.76 x 10° 108883 Toluene 5.33 x 10' 1.07 x 10° 100414 Ethylbenzene 2.72 x 10° 5.44 x 10-2 1330207 Xylene 8.38 x 10° 1.68 x 10-' 110543 - n -Hexane 1.35 x 103 2.70 x 10' 540841 2,2,4-Trimethylpentane 5.56 x 10"' 1.13 x 10'2 Note: The controlled emissions factors for this point are based on the Enclosed Combustor control efficiency of 98%. The emission factors listed above are based on VRT temperature of 85 °F and VRT pressure of 6 psig. 6) In accordance with L.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Toluene, Benzene, Total HAPs NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: James Ricci Package #: 388075 Received Date: 8/21/2018 Review Start Date: 2/6/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas, Inc. County AIRS ID: 123 Quadrant Section Township Range NENE 35 7N 67 Plant AIRS ID: Facility Name: Location: County: Type of Facility: 9FF9 Hergert - Launer Production Facility NENE Quadrant of Section 35, Township 7N, Range 67W Weld County Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Carbon Monoxide (CO) ❑ Section 02 - Emissions Units In Permit Application Particulate Matter (PM) C Ozone (NOx & VOC) AIRs Point 14 Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 004 Separator Venting VRT Venting Yes 18WE1042.CP1 1 Yes Permit Initial Issuance Section 03 - Description of Project A commingled liquid stream (containing natural gas, condensate and produced water) flows from twenty-four (24) wellheads to twenty-four (24) inlet high -low pressure ('HLP' ) 3 -phase separators. The HLP separators split the fluids into individual phases (natural gas, condensate and produced water). The condensate streams exit the HLP separators and flows to a VRT. Flash emissions from the VRT are routed to a vapor recovery unit ("VRU") onsite under normal operating conditions. Under certain conditions, the VRU can be bypassed and the flash gas can be sent to an enclosed combustion device ("ECD") rated at >99% destruction efficiency. Extraction Oil & Gas, Inc. has submitted an APEN associated with the emissions from venting the gas from the VRT gas during VRU downtime. They have requested a construction permit for this emission point. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ No Yes SO2 NOx CO VOC PM2.5 PM10 TSP ❑ ❑ C C ❑ ❑ C C C O ❑ ❑ C I No HAPs Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123 County 9FF9 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Venting of gas from the vapor recovery tower while the vapor recovery unit is bypassed Emission Control Device Description: Enclosed Combustor Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented 98 Yes, meter is currently installed and operational Based on correspondence with applicant Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 27.0 MMscf per year Requested Permit Limit Throughput = 30.8 MMscf per year Requested Monthly Throughput = 3 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 31 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 2219 Description Btu/scf scf/bbl Net Dry Real, From Lab Analysis Flash emissions from the VRT are routed to a vapor recovery unit ("VRU") onsite under normal operating conditions. Under certain conditions, the VRU can be bypassed and the flash gas can be vented. A gas sample from the VRT was taken on 8/21/18 at 6 psig and 85 deg F by AJM Cylinder Number Bag at the Herget/Lauer site (Unit ID Launer 26W-15-8C(c)). It was analyzed by Alliance Source Testing on 8/24/18, Lab Analyst CLB. Weight% of this sample are entered below are used to derive site specific emission factors. MW 43.0 Weight % Oxygen/Argon 0.12 CO2 1.14 N2 0.44 methane 4.91 ethane 14.83 propane 35.78 isobutane 6.71 n -butane 20.46 isopentane 4.83 n -pentane 5.71 cyclopentane 0.37 n -Hexane 1.19 cyclohexane 0.23 Other hexanes 2.10 heptanes 0.58 methylcyclohexane 0.16 224 -IMP 0.00 Benzene 0.12 Toluene 0.05 Ethylbenzene 0.00 Xylenes 0.01 C8+ Heavies 0.28 Total 100.00 VOC Wt % 78.57 Ib/Ib-mol Displacement Equation Ex = Q * MW * Xx / C Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor (lb/MMscf) (Ib/MMscf) Source (Gas Throughput) (Gas Throughput) VOC 8.90E+04 1.78E+03 Extended gas analysis Benzene 1.38E+02 2.76E+00 Extended gas analysis Toluene 5.33E+01 1.07E+00 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Ethylbenzene 2.72E+00 5.44E-02 Xylene 8.33E+00 1.63E-01 n -Hexane 1.35E+03 2.70E+01 224 IMP 5.66E-01 1.13E-02 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) Ib/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 16.534 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 16.534 SOx 0.0006 1.305 NOx 0.0680 150.892 CO 0.3100 687.890 K:\PA\2018\ 18 W E 1042.CP 1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 0.25 0.22 0.22 0.3 0.3 43 PM2.5 0.25 0.22 0.22 0.3 0.3 43 SOx NOx VOC CO 0.02 0.02 0.02 0.0 0.0 3 2.32 2.04 2.04 2.3 2.3 395 1369.76 1201.60 24.03 1369.8 27.4 4653 10.59 9.29 9.29 10.6 10.6 1799 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 4254 3732 75 4254 85 Toluene 1642 1441 29 1642 33 Ethylbenzene 84 73 1 84 2 Xylene 258 226 5 258 5 n -Hexane 41529 36430 729 41529 831 224 TM P 17 15 0 17 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? Yes 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 ggl sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: - An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. 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 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. Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of tt equipment covered under this AIRs ID) and process simulation to estimate emissions? This sample should have been collected within one year of the application received date. Fin new wells brought on-line), then it may he appropriate to use an older site -specific sample. If no, the permit, will Contain an "Initial Compliance" testing requirement to collect a sinl•specihc liquid sample 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. ) 1 Does the company request a control device efficiency- greater than 95% for a flare o, combustion do , ice '/ If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and rtutk:l concentration 50111Pling 3 of 5 K:\PA\2018\18WE1042.CP1.xIsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes The weight%'s entered in the analysis above were taken directly from the lab analysis. The applicant's calculations slightly differed. This could have been due to converting Mol% to Weight% or more significant figures could have been supplied to them from the testing company. However, controlled emission calculated are nearly identical, their calculation method is acceptable. 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 16.53 0 lb/MMSCF PM2.5 16.53 0 Ib/MMSCF SOx 1.31 0 lb/MMSCF NOx 150.89 0 Ib/MMSCF VOC 88974.39 98 Ib/MMSCF CO 687.89 0 lb/MMSCF Benzene 138.16 98 Ib/MMSCF Toluene 53.34 98 lb/MMSCF Ethylbenzene 2.72 98 Ib/MMSCF Xylene 8.38 98 lb/MMSCF n -Hexane 1348.77 98 Ib/MMSCF 224 TMP 0.57 98 lb/MMSCF 4 of 5 K:\PA\2018\18WE1042.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. 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 Yes 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)? Yes Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Sectionl a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend.- 'may. "'should. " and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'required' are intended to descnbe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. No Source Req Source Req Source is st The control Ci SUS e — See G+35 43, A N Ad),„„ 1 Cece,Jol 3/Y(7oi� Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processir - ' "itional APEN fee if the APEN is filled out incorrectly or is missing in) This APEN is to be used for emission source does not fa crude oil storage tanks, prc APEN (Form APCD-200) is a, available APEN forms and a website at: www.colorado. 0s\ d with oil and gas industry operations. If your more specific APEN available for your source (e.g. bon liquid loading, etc.). In addition, the General will not satisfy your reporting needs. A list of all nd on the Air Pollution Control Division (APCD) This emission notice is valk evised 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: IS W E' 'o59 AIRS ID Number: 12.3 qFF / 0(1 I [Leave blank unless APCD has already assigned a permit At and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Hergert - Launer Production Facility Site Location: NENE Section 35 T7N R67W Mailing Address: (Include Zip code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Kelli Cox (720) 354-4597 KCox@ExtractionOG.com 1 Use the full, legal company name registered with the Colorado Secretary of State. Thisis 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-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 388070 pp ; COLORADO 1 I mn:pf Permit Number: AIRS ID Number: [Leave blank unles APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit O GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 O Change permit limit O Transfer of ownership4 O Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Eight (8) - 400 bbl Condensate Storage Vessels Company equipment Identification No. (optional): TKs 001-008 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 6/23/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: CIExploration 8 Production (E£tP) site I:=1Midstream or Downstream (non EftP) site Will this equipment be operated in any NAAQS nonattainment area? 12 Yes • No Are Flash Emissions anticipated from these storage tanks? Fl Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? GI Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.0001 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Ol Yes ■ No Are you requesting ≥ 6 ton/yr V0C emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No al ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 2j COLORAR© b ate Permit Number: AIRS ID Number: I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information ondensate Throughput ",ctualAn nual Amount ,......., a'fbbl/year) 1,962,605 equested Annual Perm_ rt Limrt (bb!/year) 2,355,126 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 44.7 degrees Tank design: 0 Fixed roof ❑ Internal floating roof RVP of sales oil: 11.4 O External floating roof 8 3200 TK 001-008 nstaUation Date of Mos lecent Storage Vesseli torsi a Tank 'month year 05/2018 06/2018 ells Serviced. Num Yy: �.t 6 orage Tank or Tank Battery {EEfP Saes Only) ame ;of ewly RePoete SEE ATTACHED FORM APCD - 212 ❑ ., - ❑ — - 5 Requested values will become permit limitatiors. Requested limit(s) should consider uture growth:- 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information 40.535038, -104.855463 OperatoreStack ID No ,:. s Discharge Abo Height ve ° �' , < Ground Level .(feet): ...,;f Temp °F ( .:).::,.. _., .-: ., ,:. Flow Rate ACF M,, ( ) ,. Velocity a` (ft/sect, ,m ECDs --20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑r Upward ❑ Downward ❑ Horizontal ❑ Other •(describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle Interior stack width finches): ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I !COLORADO Lepvewed d ndlm Xu[N�b Mi. tonta rd Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % % ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECDs Make/Model: TBD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 2,468 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr ❑ Closed Loop System Description of the closed loop system: 0 Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig Describe the separation process between the well and the storage tanks: HLP Separator, VRT, Condensate Storage Tanks Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 712018 //x •• CoLORARO �„wrn:.�wm� i3a. k�.,,utbI+a.clu� x VOC 0.139 VOC Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): escription of Control Method(s), Overall Requested Control. Efficiency' (% reduction in emissions): ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions Inventory.. ; ... . mission Fact Source (AP -42, Mfg. etc) Actual; AiihUal: Emissions Requested Annual Permit':.:: EmissionLimit(s)5.: Uncontrolled Basis Units Ib/bbl Promax/Tanks409d Uncontrolled Emissions (Tons/year) 136.8 ✓ =controlled Emissions8 (Tons/year) 6.84 ✓ Uncontrolled Emissions (Tons/year) 164.16 Controlled. Emissions (Tons/year) 8.21 NOx 0.068 Ib/MM Btu AP -42 0.1 0.1 CO 0.31 Ib/MMBtu AP -42 0.4 0.5 on ., riteria Reportable Pollutant Emissions Inventory :. : Chemical ::. or Emission Factor7 Actual.Annu Emissions.;: al Chemical. Name ... :.Abstract Service CAS'.:,. ( ) Number.. ° ::: Uncontrolled . .Basis Units Source . (Al'(AP-4Z, Mfg. _etc). ' Uncontrolled:.: Emissions . (PaundsJyear). Controlled .: Emissions . (Paundslyeni-). Benzene 71432 3.37E-4 Ib/bbl Promax(ranks409d 662.11 33.11 Toluene 108883 2.72E-4 Ib/bbl Promax?anks409d 533.87 26.69 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.002 lb/bbl Promax,Tanks409d 4,387.11 219.36 2,2,4- Trimethylpentane 540841 s Requested values will become permit Limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 as:anp Etx'ttYV:tplw(.: Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source i,s and will be operated full compliance with each condition of the applicable General Permit. 09/21/2018 Signatue of Legally 9(uthorized Person (not a vendor or consultant) Date Kelli Cox Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: Ej Draft permit prior to issuance ✓� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 !AV A ITqacenttntoi COLORADO (fie ��•��e� 31 s"I►ti Er...-. "3•R1 Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] 123 / 9FF9 / 001 Section 1 - Administrative Information Company Name1: Site Name: Extraction Oil & Gas, Inc. Hergert - Launer Production Facility Site Location: NENE Section 35 T7N R67W Mailing Address: (include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Catie Nelson (720) 354-4579 cnelson@extractionog.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 ®�;ICOLORADO � I :ol�a�� ' ti�11v Fn�lran.n. nl Permit Number: AIRS ID Number: 123 / 9FF9/ 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action El NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change permit limit ❑ Change company name3 ❑ Transfer of ownership4 OR - ❑ Other (describe below) ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info ft Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Eight (8) - 400 bbl Condensate Storage Vessels Company equipment Identification No. (optional): TKs 001-008 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 6/23/2018 Normal Hours of Source Operation: orage tank(s) located at: 24 hours/day 7 ❑✓ Exploration a Production (EftP) site days/week 52 weeks/year O Midstream or Downstream (non EftP) site Will this equipment be operated in any NAAQS nonattainment area? NI Yes ■ No Are Flash Emissions anticipated from these storage tanks? I Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Fl Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.0001 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Igl Yes ■ No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? a Yes • No Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 2 I •V .en: e�rct:�c N�va�lih�'v Envirannu ri Permit Number: AIRS ID Number: 123 / 9FF9 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbl/year) 2,216,283 From what year is the actual annual amount? Average API gravity of sates oil: 44.7 degrees O Internal floating roof 2018 Tank design: ❑✓ Fixed roof Requested Annual Permit Limits (bbl/year) 3,058,471 RVP of sales oil: 10.8 O External floating roof Storage. Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK 001-008 8 3200 05/2018 06/2018 Wells Serviced by this Storage Tank or Tank Battery6 (EEtP Sites On y) API Number Name of Well Newly Reported Well - - SEE ATTACHED FORM APCD - 212 • ■ ■ ■ ■ s Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EftP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.535038, -104.855463 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECDs —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) El Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Interior stack diameter (inches): TBD Interior stack width (inches): ❑r Circular ❑ Square/rectangle ❑ Other (describe): O Upward with obstructing raincap Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I coi.osaoo AV k"Ntlit EZnelmrill Permit Number: AIRS ID Number: 123 / 9FF9 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECDs MMBtu/hr Make/Model: TB D Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 2,468 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr 0 Closed Loop System Description of the dosed loop system: 0 Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -5 psig Describe the separation process between the well and the storage tanks: HLP Separator, VRT, Condensate Storage Tanks Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 //y�!� 'GOIORADO 4 I AV gra. hcn:or R:r ' H�aNk EEneironmcnt Permit Number: AIRS ID Number: 123 / 9FF9 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the • (or combined) control efficiency (% reduction). verall Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECDs ss NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? 2018 Pollutant VOC NOx CO Uncontrolled Basis lb/bbl 0.138 Criteria Pollutant Emissions Inventory - Source (AP -42,' Mfg. etc) PromaxfTanks409d Actual Annual Emissions Uncontrolled Emissions (Tons/year) 152.47 Controlled Emissions8 (Tons/year) 7.62 Requested Annual Permit Emission Limit(s)5 Uncontrolled Emissions (Tons/year) 210.41 Controlled Emissions (Tons/year) 10.52 0.068 lb/MMBtu AP -42 0.28 0.39 0.31 lb/MMBtu AP -42 1.29 1.78 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Emission Factor Actual Annual Emissions Chemical Abstract Service (CAS) Number Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) _ Controlled Emissions8 (Pounds/year) Benzene 71432 0.000333 / lb/bbl Promaxrranks409d 738 37 Toluene 108883 0.000268 / lb/bbl Promaxlaanks409d 595 30 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.002 ✓ lb/bbl PromaxTranks409d 4,890 245 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. $ Annual emissions fees will be.based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 j COLORADO 5 I e ! H�IT,b E�.vl�nmerl Permit Number: AIRS ID Number: 123 /9FF9/001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. u" I \-A4 \ C(Ifl(tlk Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson Name (print) Date Air Quality Engineer Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance (] Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.eov/cdphe/apcd Form APCD-205 Condensate Storage Tank(s) APEN - Revision 7/2018 COLOR•OO 6 AV I ruz�usmp,p.m,e n. t ave n�n.+ai 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Peter Knell <pknell@spiritenv.com> To: "james.ricci@state.co.us" <james.ricci@state.co.us> Cc: Catie Nelson <cnelson@extractionog.com>, Jason Browne <jbrowne@spiritenv.com> Hi James, Fri, Mar 8, 2019 at 10:00 AM We have addressed the remaining questions/comments in blue text below. We have updated emissions estimates based on current actual production data for the Condensate TKs, Produced Water TKs, and VRT emission points. To avoid any additional back and forth with the Division in the future, we have decided to use AP42 values for NOx and CO emissions for the venting sources onsite. Please find all the necessary documentation attached and/or addressed below. Don't hesitate to let us know if you need any additional information. Thanks, Peter Knell Senior Project Manager pknell@spiritenv.com-- mobile: (303) 506-6417 SPIRIT E NVIROMM[NIAC From: Jason Browne Sent: Tuesday, February 26, 2019 8:59 AM To: 'Ricci - CDPHE, James' <james.ricci@state.co.us> Cc: 'Catie'Nelson' <cnelson@extractionog.com> Subject: RE: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi James, Thank you for your patience on the Hergert-Launer permit application. As an update, the corrected APENs and calculations are in the queue for internal QC this week and will be completed for you as soon as possible. In the meantime, I have addressed a handful of your questions in red text, below, to keep us moving forward. Again, thanks for your patience and please feel free to call me anytime with questions/concerns. Jason Browne, PMP Project Manager jbrowne@spiritenv.com k++n.•„n„ik rom/maiuu/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 1/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 DIRECT 720-500-3714 MOBILE 480-329-2614 SPIRIT NYIRONFAENfAt. From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, February 7, 2019 12:09 PM To: Kelli Cox <kcox@extractionog.com>: Jason Browne <jbrowne@spiritenv.com> Subject: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi Kelli, Jason, I started to review the APENs submitted for the Hergert - Launer Production Facility, below are my initial questions: I would appreciate it if you could provide a response by Feb 14th. Thanks! Thermal Oxidizer • I believe there has already been some back and forth with the division regarding our definition of thermal oxidizer. Will a thermal oxidizer be used at this facility in the sense that the combustion chamber can be monitored for temperature? Or should I redline the APEN and - -- call the combustion device an "Enclosed Combustor?" • Yes. Temperature monitoring is available. Please update to ECD and we will comply with the appropriate O&M requirements. Condensate Tanks The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. Can you please also confirm how heat release was calculated (Or how ProMax estimates it)? Does this only include the heat release from the flash emissions or is the W&B heat release estimated as well? We updated our emission calculations to include W&B NOx and CO emissions for the condensate tanks. Please find attached the revised APEN and emission calculations capturing this update. The VRT looks modeled at 5psig in ProMax with the gas sample taken at 6psig. Is this small discrepancy due to variances in sample taking? The Promax model is set up according to expected normal operating parameters of the VRT. While the sample represents a snapshot in time, it is expected the VRT will operate at an average of 5 psig Produced Water • The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? • In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. In section 3 of the APEN, it was noted that these tanks will contain <1% crude. Do these tanks fall under the categorical permit exemption? Or would Extraction like a permit regardless? We do not have a site specific liquid sample to verify this condition. We will correct check box on revised APEN The front page of ProMax stated that the model was run based on 0.5 scf of flashed gas. The GWR on the lab analysis listed it at 0.6 scf of flashed gas. If this was just a typo, can you please provide the throughputs you assumed to go from 0.6 scf of flashed gas to 0.012 MSCFD (ProMax Input) Good catch, this was an error in the Promax Model. We updated the emission calculations (not using Promax) to fix this error. Please find attached the revised APEN and emission calculations capturing this update. Can you please confirm how heat release was calculated? Heat release is calculated using the scf/bbl, btu/scf, and estimated throughput (bbls/yr). • Are W&B Losses from these tanks considered negligible? • Yes Compression Engine • How did you determine the BSFC to be 8203 BTU/hp-hr? Is there a Caterpillar spec sheet for this engine? Please see the USA Compression Emissions Report attached for the BSFC value. Venting t. 1-_«,ll'n.01s.,, nMCCarr.h=all&oermmsaid=msa-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 2/3 3/11/2019 State.co.us Executive Branch Mail APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Can you please provide documentation for the NOx and CO manufacturer emission factors? Will it be possible to revise to AP42 Chapter 13.5 NOx and CO emission factors? Please find the updated APENs (LP and VRT Venting) and emission calculations utilizing AP42 EFs for NOx and CO. Due to increased Condensate and PW throughput (captured in comments above), we revised the VRT Venting volume (decreased) to maintain the GP02 and continue to meet the <90tpy GP02 requirement. I guess more for my own curiosity, the testing company listed three BTU/scf measurements. How did you choose which to select? Our standard procedure to select the lab LHV which closely reflects values calculated in our template calculation workbook O&M Plans • Condensate & Separators: Can you please check the box in Section 3 and email me the new O&M plan? • Attached • Separators: Are the two gas flowmeters already installed and operational in the locations provided on the process diagram? • Yes Form 102 • The condensate tank emissions don't match the APEN. Can you please send an updated Form 102 with this update and any other updated the comments above cause? • In QC. Please find the updated Form -102 attached. Thanks, James Ricci Permit Engineer CDPH COLORADO Air Pollution Control Division Department of Public Health b bnwronment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd 3 attachments Pedigree_Extraction Oil & Gas, Inc2311Hergert.pdf 113K Hergert-Launer Updated APENs_2019.03.07.pdf 352K Hergert-Launer_Updated Form -102 & Emission Caiculations_2019.03.06.pdf 149K _,__:f,..,noa _GG177RaW:if-M ;pw=ntiitsearch=all&Dermmsgid=msg-f%3A1627457494089857032&simpl=msg-f°/D3A16274574940... 3/3 Sv►rrStcle) - S�2 G c d- APEN POf)Pn aar) Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application proc' " rimes- You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missir ttal. This APEN is to be use' - [ associated with oil and gas industry operations. If your emission source does r a. h} ()6)_ ibe a more specific APEN available for your source (e.g. crude oil storage tank rbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is av f\4) t `V ?I,) will not satisfy your reporting needs. A list of alt available APEN forms be found on the Air Pollution Control Division (APCD) website at: www.colc This emission notice i of a revised APEN is required 30 days prior to expiration of the five-year term, or well a cpv, _-__. le (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: �r AIRS ID L. `Q V�' 101..0 Number: 123 g ' FFPP002 [Leave blank unless APCD has already assigned a permit /land AIRS ID Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Hergert - Launer Production Facility Site Location: NENE Section 35 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Kelli Cox (720) 354-4597 KCox@Extraction0G.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 will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 t118011. A C0LORADO b, _thPti Fiikith bErairCNnr.. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source 0 Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit O Transfer of ownership' O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Two (2) - 400 bbl Produced Water Storage Vessels PW 001-002 For new or reconstructed sources, the projected start-up date is: 6/2/2018 Normal Hours of Source Operation: tank(s) located at: 24 hours/day 7 Exploration 8 Production (EftP) site days/week 52 weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes ✓ No Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ✓ Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ✓ Yes ❑ No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 Permit Number: AIRS ID Number: la ik unless APCD has already assigned a permit 11 and AIRS ID] Section 4 - Storage Tank(s) Information educed Water.;Throughput Actual Annual Amount (ball year) 814,315 Requested; Annual:Permit ;Limits (bbl/year) 977,178 From what year is the actual annual amount? Tank design: Fixed roof 2018 ['Internal floating roof ❑ External floating roof 50t#§0 01 ank lD PW 001-002 of Liquid Manifold Storage Vessels in Storage Tank 2 talVolume of z torage Tank (bbl) 800 nstallation Date of Mo; tecent Storage Vessel, in torage Tank'(month/year; 05/2018 Date of Fir: Prpductioi }month/yea 06/2018 eruiced by orage Tank or Tank Ra E£60Sites On. fe ;of r 41j ty Reported V SEE ATTACHED FORM APCD-212 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EftP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or tJTM)' 40.535038, -104.855463 Operator Stack ID.No Discharge Hei tit Alcove �` Ground,. Level (feet):. Temp �' (°F,l _ Flow Rate Acf/i). ' . Velocity fttsec) ECDs —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) Q Upward ❑ Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap TBD Interior stack depth (inches): c Form APCD-207 - Produced Water Storage Tanks) APEN - Revision 7/2018 3 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor O Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECDs Make/Model: TB D Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 1,381 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: TBD MMBtu/hr ❑ Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —41 psig Describe the separation process between the well and the storage tanks: HLP Separator, Produced Water Storage Tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4 1131' N° Benzene Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit /{ and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC NOx CO ECDs 95 HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions Inventory Uncontrolled Basis lb/bbl ual Annual Emissions Requested Annual Permit Emission Limit(s)5 Source Uncontrolled (AP -42, Emissions Mfg., etc.) (tons/year) Controlled =: Emissions8' (tons/year) Uncontrolled Emissions (tons/year)', Controlled Emissions (tons/year) VOC 0.015 Promax 6.29 0.31 7.55 0.38 NOx 0.068 lb/MMBtu AP -42 0.02 0.02 CO 0.31 lb/MMBtu AP -42 0.09 0.10 on -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract ervice (CAS) umber 4.33E-4 lb/bbl Emission Factor' Actual Annual Emissions Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year):; 71432 Promax 352.6 17.63 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 5 I cer�.c��aa� Itc,:an.�•n; of?stele, Permit Number: AIRS ID Number: / I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signatu e of Legall Authorized Person (not a vendor or consultant) Kelli Cox Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: Ei Draft permit prior to issuance D✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 61 A CGL4R ADO 11.*krt uerc MR-bkic HeAkbba:mronmwN E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil and Gas, Inc. Source Name: Hergert-Launer Production Location Emissions Source AIRS ID2: 'T -B"1) I V, - cfFF''- Qaz Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-45170 LAUNER 26W -15-02C • 05-123-45175 LAUNER 26W -15-03N • 05-123-45172 LAUNER 26W -15-05N • 05-123-45173 LAUNER 26W -15-06N • 05-123-45176 LAUNER 26W -15-08C • 05-123-45179 LAUNER 26W -15-09N 1 05-123-45180 LAUNER 26W -15-11N • 05-123-45178 LAUNER 26W -15-12N • 05-123-40830 HERGERT NORTH 35W -15-01C • 05-123-40825 HERGERT NORTH 35W -15-02N • 05-123-40824 HERGERT NORTH 35W -15-04N ■ 05-123-40829 HERGERT NORTH 35W -15-05N • 05-123-40828 HERGERT NORTH 35W -15-07C • 05-123-40827 HERGERT NORTH 35W -15-08N • 05-123-40832 HERGERT NORTH 35W -15-10N ■ 05-123-40822 HERGERT NORTH 35W -15-11N ■ 05-123-45900 HERGERT SOUTH 35W -15-1C • 05-123-45905 HERGERT SOUTH 35W -15-02N • 05-123-45903 HERGERT SOUTH 35W -15-04N • 05-123-45901 HERGERT SOUTH 35W -15-05N ■ 05-123-45907 HERGERT SOUTH 35W -15-07C • 05-123-45902 HERGERT SOUTH 35W -15-8N • 05-123-45906 HERGERT SOUTH 35W -15-10N • 05-123-45904 HERGERT SOUTH 35W-15-1IN • Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter NA 3)f j Ic‘ \)1 M; l .R,at Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID WIVE W% -\Q Number: 123 / 9FF91002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Hergert - Launer Production Facility Site Location: NENE Section 35 T7N R67W Mailing Address: (Include Zip code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Catie Nelson (720) 354-4579 cnelson@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 ®y�COLORADO lti Erzvlic:umiV Permit Number: AIRS ID Number: 123 / 9FF9 /002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment ❑ Change company name3 o Change permit limit 0 Transfer of ownership4 0 Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Two (2) - 400 bbl Produced Water Storage Vessels PW 001-002 For new or reconstructed sources, the projected start-up date is: 6/23/2018 Normal Hours of Source Operation: torage tanks) located at: 24 hours/day 7 days/week 52 weeks/year Exploration E3 Production (EitP) site IDMidstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? / Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes ✓ No Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes ❑ No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 2 1 Permit Number: AIRS ID Number: 123 i 9FF9 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (blot/year) 1,124,160 Requested Annual Permit Limits (bbl /year) 1,348,992 From what year is the actual annual amount? nk design: ❑✓ Fixed roof 2018 ElInternal floating roof O External floating roof Storage Tank ID ' # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW 001-002 2 800 05/2018 06/2018 Wells Serviced by this Storage Tank or Tank Battery6 (EEtP Sites Only) API Number Name of Well Newly Reported Well SEE ATTACHED FORM APCD-212 ❑ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.535038, -104.855463 Operator Stack ID ;No. ECDs Discharge Height Above Ground Level (feet) —20 Temp. (°F) TBD Flow Rate (ACFM) TBD Velocity (ft/sec) TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal O Downward ❑other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): O Square/ rectangle Interior stack width (inches): Interior stack depth (inches): []Other (describe): O Upward with obstructing raincap TBD Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 3 I• Health: i Ertvi�o�emw�l Permit Number: AIRS ID Number: 123 / 9FF9 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: 1:"1 Device: Device: Pollutants Controlled: VOC/NAPS Rating: TBD Type: ECDs Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: Constant Pilot Light: TBD ✓❑ Yes MMBtu/hr Make/Model: TB 95 >98 % % Waste Gas Heat Content: No Pilot Burner Rating: 1,262 TBD Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: Other: Pollutants Controlled: Description: Control Efficiency Requested: 0/0 Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -58 psig Describe the separation process between the well and the storage tanks: HLP Separator, Produced Water Storage Tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4 I ®COLORADO 'V x++nb[g:.i Permit Number: AIRS ID Number: 123 i 9FF9 i 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the combined) control efficiency (A reaucnon/: verall (or Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECDs 95 NOx CO HAPs ECDS s5 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Emission Permit Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.018 lb/bbl FLA Analysis 10.35 ✓ 0.52 1 12.42 0.62 NOx 0.068 lb/MMBtu AP -42 0.03 - 0.03 CO 0.31 lb/MMBtu AP -42 0.13 0.16 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 0.00052 ✓ lb/bbl FLA Analysis 584 29 Toluene 108883 0.000296 ✓ lb/bbl FLA Analysis 333 17 Ethylbenzene 100414 Xylene 1330207 110543 n -Hexane 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 jCOLORADO 5 I � keaGhbE�i•��u:��nenl AIRS ID Number: 123 i 9FF9 / 002 Permit Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of"the applicable General Permit. C A Date Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson Air Quality Engineer Name (print) 3/1- 2<ei Title Check the appropriate box to request a copy of the: ✓Q Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment 6I Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: httas://www colorado eov/cdphe/aped COLORADO xu�m�sr.�n�mw� 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Fri, Mar 8, 2019 at 10:00 AM Peter Knell <pknell@spiritenv.com> To: "james.ricci@state.co.us" <james.ricci@state.co.us> Cc: Catie Nelson <cnelson@extractionog.com>, Jason Browne <jbrowne@spiritenv.com> Hi James, We have addressed the remaining questions/comments in blue text below. We have updated emissions estimates based on current actual production data for the Condensate TKs, Produced Water TKs, and VRT emission points. To avoid any additional back and forth with the Division in the future, we have decided to use AP42 values for NOx and CO emissions for the venting sources onsite. Please find all the necessary documentation attached and/or addressed below. Don't hesitate to let us know if you need any additional information. Thanks, Peter Knell Senior Project Manager pknell@spiritenv.com mobile: (303) 506-6417 SPIRIT CN YIRONMtNIAt From: Jason Browne Sent: Tuesday, February 26, 2019 8:59 AM To: 'Ricci - CDPHE, James' <james.ricci@state.co.us> Cc: 'Catie Nelson' <cnelson@extractionog.com> Subject: RE: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi James, Thank you for your cation. As an e corrected APENs ions are in the internal QC this week andcwill be on e completed for you ae Hergert-Launer s soon mit as possible. In the meantime, I have addressed and handful tof your questions in Bred for text, below, to keep us moving forward. Again, thanks for your patience and please feel free to call me anytime with questions/concerns. Jason Browne, PMP Project Manager jbrowne@spiritenv.com k+fr,,•irr.,a�i nnnnla cnm/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 1/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 DIRECT 720-500-3714 MOBILE 480-329-2614 SPIRIT fNVIit ONN7 AL From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, February 7, 2019 12:09 PM To: Kelli Cox <kcox@extractionog.com>; Jason Browne <jbrowne@spiritenv.com> Subject: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi Kelli, Jason, I started to review the APENs submitted for the Hergert - Launer Production Facility, below are my initial questions: I would appreciate it if you could provide a response by Feb 14th. Thanks! Thermal Oxidizer I believe there has already been some back and forth with the division regarding our definition of thermal oxidizer. Will a thermal oxidizer be used at this facility in the sense that the combustion chamber can be monitored for temperature? Or should I redline the APEN and call the combustion device an "Enclosed Combustor?" • Yes. Temperature monitoring is available. Please update to ECD and we will comply with the appropriate O&M requirements. Condensate Tanks The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. Can you please also confirm how heat release was calculated (Or how ProMax estimates it)? Does this only include the heat release from the flash emissions or is the W&B heat release estimated as well? We updated our emission calculations to include W&B NOx and CO emissions for the condensate tanks. Please find attached the revised APEN and emission calculations capturing this update. The VRT looks modeled at 5psig in ProMax with the gas sample taken at 6psig. Is this small discrepancy due to variances in sample taking? The Promax model is set up according to expected normal operating parameters of the VRT. While the sample represents a snapshot in time, it is expected the VRT will operate at an average of 5 psig Produced Water The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. In section 3 of the APEN, it was noted that these tanks will contain <1% crude. Do these tanks fall under the categorical permit exemption? Or would Extraction like a permit regardless? We do not have a site specific liquid sample to verify this condition. We will correct check box on revised APEN The front page of ProMax stated that the model was run based on 0.5 scf of flashed gas. The GWR on the lab analysis listed it at 0.6 scf of flashed gas. If this was just a typo, can you please provide the throughputs you assumed to go from 0.6 scf of flashed gas to 0.012 MSCFD (ProMax Input) Good catch, this was an error in the Promax Model. We updated the emission calculations (not using Promax) to fix this error. Please find attached the revised APEN and emission calculations capturing this update. • Can you please confirm how heat release was calculated? Heat release is calculated using the scf/bbl, btu/scf, and estimated throughput (bbls/yr). • Are W&B Losses from these tanks considered negligible? • Yes Compression Engine • How did you determine the BSFC to be 8203 BTU/hp-hr? Is there a Caterpillar spec sheet for this engine? Please see the USA Compression Emissions Report attached for the BSFC value. Venting httos://mail.google.com/mail/u/0?i k=5517734b80&view=pt&search=al I&perm msg id=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 2/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 • Can you please provide documentation for the NOx and CO manufacturer emission factors? • Will it be possible to revise to AP42 Chapter 13.5 NOx and CO emission factors? Please find the updated APENs (LP and VRT Venting) and emission calculations utilizing AP42 EFs for NOx and CO. Due to increased Condensate and PW throughput (captured in comments above), we revised the VRT Venting volume (decreased) to maintain the GP02 and continue to meet the <90tpy GP02 requirement. I guess more for my own curiosity, the testing company listed three BTU/scf measurements. How did you choose which to select? Our standard procedure to select the lab LHV which closely reflects values calculated in our template calculation workbook O&M Plans • Condensate & Separators: Can you please check the box in Section 3 and email me the new O&M plan? • Attached • Separators: Are the two gas flowmeters already installed and operational in the locations provided on the process diagram? • Yes Form 102 • The condensate tank emissions don't match the APEN. Can you please send an updated Form 102 with this update and any other updated the comments above cause? • In QC. Please find the updated Form -102 attached. Thanks, James Ricci Permit Engineer CDPHE COLORADO Air Pollution Control Division Department of Public Heath b Envtromnent P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci®state.co.us I www.colorado.gov/cdphe/apcd 3 attachments Pedigree_Extraction Oil & Gas, Inc2311 Hergert.pdf 113K .® Hergert-Launer Updated APENs_2019.03.07.pdf 352K ▪ Hergert-Launer_Updated Form -102 & Emission Calculations_2019.03.06.pdf 149K ,.....,,.,,.iuttmik=ss17734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 3/3 ksqorSO,DX SeQ Chi.kskC,eN o.\ 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 tend row.^ - This APEN is to be used for g casing, pneumatic pumps, bl category, there may be a mo loading, condensate storage 1 specialty APEN options will n( Air Pollution Control Division This emission notice is valid ft of the five-year term, or whet new equipment, change in fue.ee Regulation No. Permit Number: ,emissions from gas/liquid separators, well head If your emission unit does not fall into this amine sweetening unit, hydrocarbon liquid APEN (Form APCD-200) is available if the of all available APEN forms can be found on the %/cdphe/aped. sed APEN is required 30 days prior to expiration 'cant emissions increase, increase production, 3, Part A, II.C. for revised APEN requirements. 1g �VF : -� AIRS ID Number: (2 tiFFet/003 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Hergert - Launer Production Facility Site Location: NENE Section 35 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Kelli Cox Phone Number: (720) 354-4597 E -Mail Address2: KCox@ExtractionOG.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices wilt be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 388072 1 i A COLORADO Raa:+hb�svlrc.vn+ID: Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS IDI Section 2 - Requested Action O NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: ❑ Add point to existing permit Other (describe below) 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Emissions Low Pressure ("LP") Separator Venting Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/23/201 8 O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD days/week TBD weeks/year Wilt this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 ❑✓ Yes Cl No O Yes 0 No O Yes O No 2 cOtaaADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ Yes O No Vent Gas Heating Value: 1,742 BTU/SCF Requested: 88.97 MMSCF/year Actual: 71.18 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 34.17 VOC (Weight %) 57.92 Benzene (Weight %) 0.19 Toluene (Weight %) 0.24 Ethytbenzene (Weight on 0.04 Xylene (Weight %) 0.15 n -Hexane (Weight %) 1.1 2,2,4-Trimethylpentane (Weight %) 0 0001 Additional Required Information: O Attach a representative gas analysis (including BTEX £t 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. pTY eoLuRaoo Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit " and 'b,)RS ID Section 5 - Stack Information Geographical coordinates !. (La(itude/Longitude. or` UTM) 40.535038, -104.855463 Operator 5t�ck If7No� Disc large Hea f A ove Ground Le el LFeet') Temp ��a.......' I low Rate CF .Y3 �,... v� �f eroc� Y tlsec) ',,. TO -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) Q Upward ❑ Horizontal ❑ Downward 0 Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): 0 Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: 0/0 Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: Thermal Oxidizer Make/Model: Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD TBD Waste Gas Heat Content: 1,742 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 4 Hh;as�,;orrcnm�ni Benzene Permit Number: AIRS ID Number: I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM Overail Requested Control Efficiency:.: reduction in emissions, SOx NO. CO VOC Thermal Oxidizer 98 HAPs Thermal Oxidizer 98 Other: From what year is the following reported actual annual emissions data? 2018 PM incontrolled Basis:,:'";:: lb/MMBtu riteraa?Pallutant Emissions Inventory. ource.1 :" AP -42' ' Actual AnnualEmissions.:; Requested Annual Perrnit : ilncantroliel: Emissions Cdntrolled Emissions ..: (tansfyear) -.:. Uncontrolle . Emissions::: Caritrnllea. .... Emissions (trrtrslyear) SOx NO. CO 0.066 Manf. 4.09 5.11 0.05 lb/MMBtu Manf. 3.10 3.87 VOC 52.181 lb/Mscf Eng. Est. 1,856.98 37.14 2,321.22 46.42 on -Criteria Reportable Pollutant:Emiss Chemical Abstract:. ;=;: Service (CAS) Nurrioer 71432 Emission Factor ns Inventory. Actual Annual Emissions Uncontrolled Basis 0.174 Units.:: lb/Mscf .. Source 64)(.3'74.;4•••••.% Mf�,etcJ Eng. Est. Uncontrolled Emissions, (pouhdstyear) 12,380.95 ontrotled • :msons6 pounds/year) ' 247.62 Toluene 108883 0.218 lb/Mscf Eng. Est. 15,499.88 310.0 Ethylbenzene Xylene 100414 0.033 lb/Mscf Eng. Est. 2,369.65 47.39 1330207 0.135 lb/Mscf Eng. Est. 9,617.07 192.34 n -Hexane 110543 0.994 lb/Mscf Eng. Est. 70,716.29 1,414.33 2,2,4- Trimethylpentane Other: 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 51 COLORADO e; rn:�ei tsnc kaxiAsa=xArraimen: 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 alt information contained herein and information submitted with this application is complete, true, and correct. Kelli Cox 09/21/2018 Signaturef Legally /authorized Person (not a vendor or consultant) Date 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) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.aov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 _....____. .. O COLORAD 6vg�r— M. i iFk.Min9s cnmwni -1 x`k1 th(:l 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: t AIRS ID Number: 123 /9FF9 /003 [Leave blan unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Hergert - Launer Production Facility Site Location: NENE Section 35 T7N R67W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, Colorado 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Catie Nelson (720) 354-4579 cnelson@extractionog.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN Revision 7/2018 COLORADO 1 I AV I pa 1{ Ncalil:=FSUlronmrn1l Permit Number: AIRS ID Number: 123 / 9FF9 / 003 [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) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description. of equipment and purpose: Emissions Low Pressure ("LP") Separator Venting Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/23/2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source TBD hours/day TBD days/week TBD weeks/year Operation: Will this equipment be operated in any NAAQS ❑✓ Yes O No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes ❑✓ No considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7,El Yes ❑ No ;/ Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 AV COLOR ADO 2 AV ' °` '�n at Ifaa:lh E ErvVanminl Permit Number: AIRS ID Number: 123 / 9FF9 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ Yes O No Vent Gas Heating Value: 1,742 BTU/SCF Requested: 88.97 MMSCF/year Actual: 71.18 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 34.19 VOC (Weight %) 57.92 Benzene (Weight %) 0.19 Toluene (Weight %) 0.24 Ethylbenzene (Weight on 0.04 Xylene (Weight %) 0.15 n -Hexane (Weight %) 1.10 2,2,4-Trimethylpentane (Weight %) 0.001 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX ii n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 ❑✓ Upward O Horizontal Permit Number: AIRS ID Number: 123 /9FF9/003 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.535038, -104.855463 Operator ack ID No St� Discharge Height Above Ground Level (Feet) Temp (° Flow Rate ACFM) Velocity, "(ft/sec) ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) D Circular O Other (describe): Interior stack diameter (inches):. O Upward with obstructing raincap TBD Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. 0 VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: TBD MMBtu/hr Make/Model: TBD 98 >99 % Waste Gas Heat Content: Constant Pilot Light: p Yes ❑ No Pilot burner Rating: 1,742 TBD Btu/scf MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 lin ALIV 4 I W !Ih£En imnn mU Permit Number: AIRS ID Number: 123 /9FF9/OO3 [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 lui LVnJUIlICui Pollutant t..VIIUMI. S_1,1..t, ...., ,,,,......._.._..,. Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECD 98 HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant ; Emission Factor Actual Annual Emissions Requested Annual Permit . . • • s Emission Limit(s) Uncontrolled Units Source (AP -42, Mfg., ., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions. tonsear) (/ y Controlled Emissions (tons/year) PM SOx NOx 0.068 Ib/MMBtu AP42 4.21 5.27 CO 0.31 lb/MMBtu AP42 19.21 24.01 VOC 52.181 ✓ lb/Mscf Eng. Est. 1,856.98 37.14 2,321.22 46.42 ve Non -Criteria Reportable Pollutant Emissions Inventory = Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 0.174 ‘e lb/Mscf Eng. Est. 12,381 248 Toluene 108883 0.218 V lb/Mscf Eng. Est. 15,500 310 Ethylbenzene 100414 0.033 ✓ lb/Mscf Eng. Est. 2,370 47 Xylene 1330207 0.135 ✓ lb/Mscf Eng. Est. 9,617 192 n -Hexane 110543 0.994 I lb/Mscf Eng. Est. 70,716 1,414 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 COLORADO 5 Ay x,:01 Palm Fr�tll� � F.noiron mml Permit Number: AIRS ID Number: 123 / 9FF9 / 003 [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. O -ii Signature of legally Authorized Person (not a vendor or consultant) Catie Nelson Name (please print) 1141 I Date Air Quality Engineer Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance ID Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Form APCD-211 Gas Venting APEN - Revision 7/2018 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd itmilcoLokADO 6 I tl`�°`" NW3YFIJYlt[�!nM 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Hergert Launer Production Facility AIRS ID 123/9FF9 Fri, Mar 8, 2019 at 10:00 AM Peter Knell <pknell@spiritenv.com> To: "james.ricci@state.co.us" <james.ricci@state.co.us> Cc: Catie Nelson <cnelson@extractionog.com>, Jason Browne <jbrowne@spiritenv.com> Hi James, We have addressed the remaining questions/comments' in blue text below. We have updated emissions estimates based on current actual production data for the Condensate TKs, Produced Water TKs, and VRT emission points. To avoid any additional back and forth with the Division in the future, we have decided to use AP42 values for NOx and CO emissions for the venting sources onsite. Please find all the necessary documentation attached and/or addressed below. Don't hesitate to let us know if you need any additional information. Thanks, Peter Knell Senior Project Manager pknell@spiritenv.com mobile: (303) 506-6417 SPIRIT f NYIROMMINIAL From: Jason Browne Sent: Tuesday, February 26, 2019 8:59 AM To: 'Ricci - CDPHE, James' <james.ricci@state.co.us> Cc: 'Catie Nelson' <cnelson@extractionog.com> Subject: RE: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi James, Thank you for your e ions are in the e internal QC this week and will beence on completed omp et d for you ae Hergert-Launer s soon mit as possible. In the m. As an eantime corrected addressed and handfulofyour questions in u red for text, below, to keep us moving forward. Again, thanks for your patience and please feel free to call me anytime with questions/concerns. Jason Browne, PMP Project Manager jbrowne@spiritenv.com k++nc•i!rnaiI nnnriI r•.nm/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 1/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 DIRECT 720-500-3714 MOBILE 480-329-2614 SPIRIT ENV.RONU(N14L From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, February 7, 2019 12:09 PM To: Kelli Cox <kcox@extractionog.com>; Jason Browne <jbrowne@spiritenv.com> Subject: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi Kelli, Jason, I started to review the APENs submitted for the Hergert - Launer Production Facility, below are my initial questions: I would appreciate it if you could provide a response by Feb 14th. Thanks! Thermal Oxidizer I believe there has already been some back and forth with the division regarding our definition of thermal oxidizer. Will a thermal oxidizer be used at this facility in the sense that the combustion chamber can be monitored for temperature? Or should I redline the APEN and call the combustion device an "Enclosed Combustor?" Yes. Temperature monitoring is available. Please update to ECD and we will comply with the appropriate O&M requirements. Condensate Tanks The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. Can you please also confirm how heat release was calculated (Or how ProMax estimates it)? Does this only include the heat release from the flash emissions or is the W&B heat release estimated as well? We updated our emission calculations to include W&B NOx and CO emissions for the condensate tanks. Please find attached the revised APEN and emission calculations capturing this update. The VRT looks modeled at 5psig in ProMax with the gas sample taken at 6psig. Is this small discrepancy due to variances in sample taking? The Promax model is set up according to expected normal operating parameters of the VRT. While the sample represents a snapshot in time, it is expected the VRT will operate at an average of 5 psig Produced Water • The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? • In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. • In section 3 of the APEN, it was noted that these tanks will contain <1% crude. Do these tanks fall under the categorical permit exemption? Or would Extraction like a permit regardless? We do not have a site specific liquid sample to verify this condition. We will correct check box on revised APEN • The front page of ProMax stated that the model was run based on 0.5 scf of flashed gas. The GWR on the lab analysis listed it at 0.6 scf of flashed gas. If this was just a typo, can you please provide the throughputs you assumed to go from 0.6 scf of flashed gas to 0.012 MSCFD (ProMax Input) Good catch, this was an error in the Promax Model. We updated the emission calculations (not using Promax) to fix this error. Please find attached the revised APEN and emission calculations capturing this update. • Can you please confirm how heat release was calculated? Heat release is calculated using the scf/bbl, btu/scf, and estimated throughput (bbls/yr). • Are W&B Losses from these tanks considered negligible? • Yes Compression Engine • How did you determine the BSFC to be 8203 BTU/hp-hr? Is there a Caterpillar spec sheet for this engine? Please see the USA Compression Emissions Report attached for the BSFC value. Venting hrrnc �hnai� nnnnle_com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 2/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 • Can you please provide documentation for the NOx and CO manufacturer emission factors? Will it be possible to revise to AP42 Chapter 13.5 NOx and CO emission factors? Please find the updated APENs (LP and VRT Venting) and emission calculations utilizing AP42 EFs for NOx and CO. Due to increased Condensate and PW throughput (captured in comments above), we revised the VRT Venting volume (decreased) to maintain the GP02 and continue to meet the <90tpy GP02 requirement. three cf measurements. How d ou se which to • I guess more for Our standard procedure dare touriosity, the select the lab LHV whicphany closelydreflectsBva values calculated in our template l ycalculation workbook select? • O&M Plans • Condensate & Separators: Can you please check the box in Section 3 and email me the new O&M plan? • Attached • Separators: Are the two gas flowmeters already installed and operational in the locations provided on the process diagram? • Yes Form 102 • The condensate tank emissions don't match the APEN. Can you please send an updated Form 102 with this update and any other updated the comments above cause? • In QC. Please find the updated Form -102 attached. Thanks, James Ricci Permit Engineer CDPH COLORADO Air Pollution Control Division Deoannent of Rubtic Health & Environment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/aped 3 attachments ▪ Pedigree_Extraction Oil & Gas, Inc2311Hergert.pdf 113K Hergert-Launer_Updated APENs_2019.03.07.pdf 352K ▪ Hergert-Launer_Updated Form -102 & Emission Calculations_2019.03.06.pdf 149K ., ____ 1..,,.11a,lnm.=cci77?dhRn&view=ot&search=all&permmsgid=msg-f%o3A1627457494089857032&simpl=msg-f%3A16274574940... 3/3 Sqtr Se)4 - Ste Ac,y Vea POE N N\AtAa‘,e1 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 informa' ' -- "nd requires re -submittal. emissions from gas/liquid separators, well head your emission unit does not fall into this mine sweetening unit, hydrocarbon liquid PEN (Form APCD-200) is available if the if all available APEN forms can be found on the /cdphe/apcd. This APEN is to be used for gas casing, pneumatic pumps, blow category, there may be a more loading, condensate storage t� specialty APEN options will nc Air Pollution Control Division This emission notice is valid of the five-year term, or wt new equipment, change in fuel type, Permit Number: used APEN is required 30 days prior to expiration ificant emissions increase, increase production, Part A, II.C. for revised APEN requirements. 18 VVE 1042 AIRS ID Number: IZ3 /qFF/ 00÷ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Hergert - Launer Production Facility Site Location: NENE Section 35 T7N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Kelli Cox Phone Number: (720) 354-4597 E -Mail Address2: KCox@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 388073 1I ;COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR - APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Emissions Vapor Recovery Tower ("VRT") Venting Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/23/2018 O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week 0 Yes ❑ Yes ❑✓ Yes TBD weeks/year ❑ No ❑✓ No ❑ No AT®nahepaatatesti of cotO&ADD. .tiit �i:i absr:rfrc 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 O Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ No Vent Gas Heating Value: 2 219 3 BTU/SCF Requested: 33,76 MMSCF/year Actual: 27.01 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 42.97 VOC (Weight %) 78.54 Benzene (Weight %) 0.12 Toluene (Weight %) 0.06 Ethylbenzene (Weight on 0.001 Xylene (Weight %) 0.01 n -Hexane (Weight %) 1.19 2,2,4-Trimethylpentane (Weight %) 0 00,E Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX 8 n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX lit n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. ........_. ©€040 RAD0. Form APCD-211 -• Gas Venting APEN - Revision 7/2018 3 I E31 ; Permit Number: AIRS ID Number: / / [Leave blank unless A?CD has already assigned a permit # and AIRS ID] Section 5 - Stack Information TO Geographical Coordinates (Latitude/longitude or 19TH) 40.535038, -104.855463 -30 Indicate the direction of the stack outlet: (check one) 0 Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular 0 Other (describe): Interior stack diameter (inches): TBD TBD 1 TBD ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: % ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD Thermal Oxidizer MMBtu/hr hr Make/Model: TBD Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: Minimum Temperature: TBD >99 Waste Gas Heat Content: Constant Pilot Light: 0 Yes 0 No Pilot burner Rating: 2,219 TBD Btu/scf. MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 Gas Venting APEN - Revision 7/2018 c.cr�vreAI U A. - 4 ) � ANY; Xn�iPratmrr4: Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit :` and AIRS ID] Section 7 - Emissions Inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM Overall Requested Control Efficiency %.reduction insemissions ...... _........._.. SOx NOx CO VOC Thermal Oxidizer 98 HAPs Thermal Oxidizer 98 Other: 2018 From what year is the following reported actual annual emissions data? riteria Po.11utant.Emissions Inventory Uncantrolle Emissions oils/year) PM 2.47 missions`^ tons/year) SOx NOx CO 0.066 lb/MMBtu Manf. 1.98 0.05 Ib/MMBtu Manf. 1.50 1.87 VOC 88.957 lb/Mscf Eng. Est. 1,201.37 24.027 1,501.71 30.03 lb/Mscf Eng. Est Benzene Toluene on -Criteria Reportable Pollutant Emi 71432 0.138 'jails"Inventory Actual Annual Emission Uncontrolled Emissions (pound's/ye'ar) 3,730.93 74.62 108883 0.053 lb/Mscf Eng. Est. 1,442.63 28.85 Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 1.349 lb/Mscf Eng. Est. 36,423.25 728.46 2, 2, 4- Trimethylpentane Other: 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 Gas Venting APEN - Revision 7/2018 5I COLORADO linp.ilraIMPWie Permit Number: AIRS ID Number: I / [Leave blank unless APCD has already assigned a permit # and AIRS I01 Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 09/21/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Kelli Cox Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: O✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.aov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6I A. COLORADO i tUtbavum+nt WVA 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: wt l �� AIRS ID Number: 123 /9FF9 /004 [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. Hergert - Launer Production Facility NENE Section 35 T7N R67W Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, Colorado 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Catie Nelson (720) 354-4579 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 will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 ®®ICOLORADO 1 I O „:�Ic ii 116.1.11nm.., Permit Number: AIRS ID Number: 123 / 9FF9 / 004 [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 O Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Emissions Vapor Recovery Tower ("VRT") Venting Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 6/23/2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week Yes O Yes Yes TBD weeks/year ❑ No O No ❑ No ,COLORADO 2 I AVr - t Rdlc 1.4.1:ylh F Envlron n¢nf Permit Number: AIRS ID Number: 123 / 9FF9 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: O Yes ❑✓ No Vent Gas Heating Value: 2,219 BTU /SCF Requested: 30.79 MMSCF/year Actual: 27.01 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 42.98 VOC (Weight %) 78.54 Benzene (Weight %) 0.12 Toluene (Weight %) 0.05 Ethylbenzene (Weight 0.0025 Xylene (Weight %) 0.01 n -Hexane (Weight %) 1.19 2,2,4-Trimethylpentane (Weight %) 0.001 Additional Required Information: ID Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 3 AvIe�,w�.kOfP.e Nca.f1, E Erelte..mec.l ❑✓ Upward ❑ Horizontal Permit Number: AIRS ID Number: 123 / 9FF9 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM 40.535038, -104.855463 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. CF ) Flow Rate (ACFM) Velocity (ft/sec) ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: MMBtu/hr Make/Model: TBD 98 >99 Minimum Temperature: TBD Waste Gas Heat Content: 2,219 Btu/scf MMBtu/hr hr Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN Revision 7/2018 cuwenuu 4 I AVar<nt d 7„, Kr�a4M a FiwtvvvmMl Permit Number: AIRS ID Number: 123 / 9FF9 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combi ontrol •efficiency (� reduction)• Pollutant PM SOX NO. CO VOC HAPs Other: lea) c • Description of Control Method(s) _ - Overall Requested Control Efficiency (% reduction in emissions) ECD 98 ECD 98 From what year is the following reported actual annual emissions data? Pollutant' PM SOX NO. CO VOC 2018 Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit s Emission Limit(s) Uncontrolled Basis ..,,,. Units Source _ (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6. (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) 0.068 lb/MMBtu AP42 2.04 2.32 0.31 lb/MMBtu AP42 9.28 10.58 88.957 / lb/Mscf Eng. Est. 1,201.37 24.03 1,369.56 27.39 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled . Emissions6 (pounds/year) Benzene 71432 0.138 ✓ Ib/Mscf Eng. Est. 3,731 75 Toluene 108883 0.053 V Ib/Mscf Eng. Est. 1,443 29 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 1.349 ✓ Ib/Mscf Eng. Est. 36,423 728 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 w iCOLORADO X It1:E En•fi.onmml Permit Number: AIRS ID Number: 123 /w9/004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson Name (please print) bate 6 Air Quality Engineer Title Check the appropriate box to request a copy of the: Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: httos://www.colorado.gov/cdphe/apcd Form APCD-211 Gas Venting APEN - Revision 7/2018 co.ORADO 6 I�!.mr H.L`II1�Fn.Mpen.T.1 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Peter Knell <pknell@spiritenv.com> To: "james.ricci@state.co.us" <james.ricci@state.co.us> Cc: Catie Nelson <cnelson@extractionog.com>, Jason Browne <jbrowne@spiritenv.com> Hi James, Fri, Mar 8, 2019 at 10:00 AM We have addressed the remaining questions/comments in blue text below. We have updated emissions estimates based on current actual production data for the Condensate TKs, Produced Water TKs, and VRT emission points. To avoid any additional back and forth with the Division in the future, we have decided to use AP42 values for NOx and CO emissions for the venting sources onsite. Please find all the necessary documentation attached and/or addressed below. Don't hesitate to let us know if you need any additional information. Thanks, Peter Knell Senior Project Manager pknell@spiritenv.com mobile: (303) 506-6417 SPIRIT C NvURONMCNtAC From: Jason Browne Sent: Tuesday, February 26, 2019 8:59 AM To: 'Ricci - CDPHE, James' <james.ricci@state.co.us> Cc: 'Catie Nelson' <cnelson@extractionog.com> Subject: RE: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi James, Thank you for your patience on the Hergert-Launer permit application. As an update, the corrected APENs and calculations are in the queue for internal QC this week and will be completed for you as soon as possible. In the meantime, I have addressed a handful of your questions in red text, below, to keep us moving forward. Again, thanks for your patience and please feel free to call me anytime with questions/concerns. Jason Browne, PMP Project Manager jbrowne@spiritenv.com httns://mail.000ale.com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 1/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 DIRECT 720-500-3714 MOBILE 480-329-2614 SPIRIT (NYtq ONMLNt Al From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, February 7, 2019 12:09 PM To: Kelli Cox <kcox@extractionog.com>; Jason Browne <jbrowne@spiritenv.com> Subject: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi Kelli, Jason, I started to review the APENs submitted for the Hergert - Launer Production Facility, below are my initial questions: I would appreciate it if you could provide a response by Feb 14th, Thanks! Thermal Oxidizer • I believe there has already been some back and forth with the division regarding our definition of thermal oxidizer. Will a thermal oxidizer be used at this facility in the sense that the combustion chamber can be monitored for temperature? Or should I redline the APEN and call the combustion device an "Enclosed Combustor?" • Yes. Temperature monitoring is available. Please update to ECD and we will comply with the appropriate O&M requirements. Condensate Tanks • The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? • In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. • Can you please also confirm how heat release was calculated (Or how ProMax estimates it)? Does this only include the heat release from the flash emissions or is the W&B heat release estimated as well? We updated our emission calculations to include W&B NOx and CO emissions for the condensate tanks. Please find attached the revised APEN and emission calculations capturing this update. • The VRT looks modeled at 5psig in ProMax with the gas sample taken at 6psig. Is this small discrepancy due to variances in sample taking? • The Promax model is set up according to expected normal operating parameters of the VRT. While the sample represents a snapshot in time, it is expected the VRT will operate at an average of 5 psig Produced Water The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. In section 3 of the APEN, it was noted that these tanks will contain <1% crude. Do these tanks fall under the categorical permit exemption? Or would Extraction like a permit regardless? We do not have a site specific liquid sample to verify this condition. We will correct check box on revised APEN The front page of ProMax stated that the model was run based on 0.5 scf of flashed gas. The GWR on the lab analysis listed it at 0.6 scf of flashed gas. If this was just a typo, can you please provide the throughputs you assumed to go from 0.6 scf of flashed gas to 0.012 MSCFD (ProMax Input) Good catch, this was an error in the Promax Model. We updated the emission calculations (not using Promax) to fix this error. Please find attached the revised APEN and emission calculations capturing this update. Can you please confirm how heat release was calculated? Heat release is calculated using the scf/bbl, btu/scf, and estimated throughput (bbls/yr). Are W&B Losses from these tanks considered negligible? Yes Compression Engine • How did you determine the BSFC to be 8203 BTU/hp-hr? Is there a Caterpillar spec sheet for this engine? Please see the USA Compression Emissions Report attached for the BSFC value. Venting ti««. �•ir., i ,..,,,,,io rnmrmaiiri i/n?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 2/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Can you please provide documentation for the NOx and CO manufacturer emission factors? Will it be possible to revise to AP42 Chapter 13.5 NOx and CO emission factors? Please find the updated APENs (LP and VRT Venting) and emission calculations utilizing AP42 EFs for NOx and CO. Due to increased Condensate and PW throughput (captured in comments above), we revised the VRT Venting volume (decreased) to maintain the GP02 and continue to meet the <90tpy GP02 requirement. I guess more for my own curiosity, the testing company listed three BTU/scf measurements. How did you choose which to select? Our standard procedure to select the lab LHV which closely reflects values calculated in our template calculation workbook O&M Plans • Condensate & Separators: Can you please check the box in Section 3 and email me the new O&M plan? • Attached • Separators: Are the two gas flowmeters already installed and operational in the locations provided on the process diagram? • Yes Form 102 • The condensate tank emissions don't match the APEN. Can you please send an updated Form 102 with this update and any other updated the comments above cause? • In QC. Please find the updated Form -102 attached. Thanks, James Ricci Permit Engineer CDPH COLORADO Air Pollution Control Division Department Cl Puba. Health b Er,woor,ent P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd 3 attachments ▪ Pedigree_Extraction Oil & Gas, Inc2311Hergert.pdf • 113K ▪ Hergert-Launer Updated APENs_2019.03.07.pdf • 352K Hergert-Launer Updated Form -102 & Emission Calculations_2019.03.06.pdf 149K i.... •ri.,n i rennin nnm/mail/ii/n?ik=5517734b80&view=pt&search=all&permmsgid=msg-fD/o3A1627457494089857032&simpl=msg-f%3A16274574940... 3/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Peter Knell <pknell@spiritenv.com> To: "james.ricci@state.co.us" <james.ricci@state.co.us> Cc: Catie Nelson <cnelson@extractionog.com>, Jason Browne <jbrowne@spiritenv.com> Hi James, Fri, Mar 8, 2019 at 10:00 AM We have addressed the remaining questions/comments in blue text below. We have updated emissions estimates based on current actual production data for the Condensate TKs, Produced Water TKs, and VRT emission points. To avoid any additional back and forth with the Division in the future, we have decided to use AP42 values for NOx and CO emissions for the venting sources onsite. Please find all the necessary documentation attached and/or addressed below. Don't hesitate to let us know if you need any additional information. Thanks, Peter Knell Senior Project Manager pknell@spiritenv.com mobile: (303) 506-6417 SPIRIT ENVIRONMENTAL From: Jason Browne Sent: Tuesday, February 26, 2019 8:59 AM To: 'Ricci - CDPHE, James' <james.ricci@state.co.us> Cc: 'Catie Nelson' <cnelson@extractionog.com> Subject: RE: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi James, Thank you for your patience on the Hergert-Launer permit application. As an update, the corrected APENs and calculations are in the queue for internal QC this week and will be completed for you as soon as possible. In the meantime, I have addressed a handful of your questions in red text, below, to keep us moving forward. Again, thanks for your patience and please feel free to call me anytime with questions/concerns. Jason Browne, PMP Project Manager jbrowne@spiritenv.com r,r+.,�•n�,a�i nnnnIA com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 1/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 DIRECT 720-500-3714 MOBILE 480-329-2614 SPIRIT CNVIWONMENI4E. From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, February 7, 2019 12:09 PM To: Kelli Cox <kcox@extractionog.com>; Jason Browne <jbrowne@spiritenv.com> Subject: APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 Hi Kelli, Jason, I started to review the APENs submitted for the Hergert - Launer Production Facility, below are my initial questions: I would appreciate it if you could provide a response by Feb 14th. Thanks! Thermal Oxidizer • I believe there has already been some back and forth with the division regarding our definition of thermal oxidizer. Will a thermal oxidizer be used at this facility in the sense that the combustion chamber can be monitored for temperature? Or should I redline the APEN and call the combustion device an "Enclosed Combustor?" • Yes. Temperature monitoring is available. Please update to ECD and we will comply with the appropriate O&M requirements. Condensate Tanks • The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? • In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. • Can you please also confirm how heat release was calculated (Or how ProMax estimates it)? Does this only include the heat release from the flash emissions or is the W&B heat release estimated as well? We updated our emission calculations to include W&B NOx and CO emissions for the condensate tanks. Please find attached the revised APEN and emission calculations capturing this update. • The VRT looks modeled at 5psig in ProMax with the gas sample taken at 6psig. Is this small discrepancy due to variances in sample taking? • The Promax model is set up according to expected normal operating parameters of the VRT. While the sample represents a snapshot in time, it is expected the VRT will operate at an average of 5 psig Produced Water The throughputs on the Calculations Sheet don't match the APEN. Can you please confirm which is correct and which needs revised? In QC. We updated throughput to account for actual production being higher than estimated in the original application. Please find attached the revised APEN and emission calculations capturing this update. • In section 3 of the APEN, it was noted that these tanks will contain <1% crude. Do these tanks fall under the categorical permit exemption? Or would Extraction like a permit regardless? We do not have a site specific liquid sample to verify this condition. We will correct check box on revised APEN The front page of ProMax stated that the model was run based on 0.5 scf of flashed gas. The GWR on the lab analysis listed it at 0.6 scf of flashed gas. If this was just a typo, can you please provide the throughputs you assumed to go from 0.6 scf of flashed gas to 0.012 MSCFD (ProMax Input) Good catch, this was an error in the Promax Model. We updated the emission calculations (not using Promax) to fix this error. Please find attached the revised APEN and emission calculations capturing this update. Can you please confirm how heat release was calculated? Heat release is calculated using the scf/bbl, btu/scf, and estimated throughput (bbls/yr). • Are W&B Losses from these tanks considered negligible? • Yes Compression Engine • How did you determine the BSFC tote 8203 BTU/hp-hr? Is there a Caterpillar spec sheet for this engine? Please see the USA Compression Emissions Report attached for the BSFC value. Venting /....,;;n rnmU=csirrlahRnRview=nmsearch=all&oermmsaid=mso-f%3A1627457494089857032&simpl=msg-f%3A16274574940... 2/3 3/11/2019 State.co.us Executive Branch Mail - APEN Review: Hergert - Launer Production Facility AIRS ID 123/9FF9 • Can you please provide documentation for the NOx and CO manufacturer emission factors? Will it be possible to revise to AP42 Chapter 13.5 NOx and CO emission factors? Please find the updated APENs (LP and VRT Venting) and emission calculations utilizing AP42 EFs for NOx and CO. Due to increased Condensate and PW throughput (captured in comments above), we revised the VRT Venting volume (decreased) to maintain the GP02 and continue to meet the <90tpy GP02 requirement. I guess more for my own curiosity, the testing company listed three BTU/scf measurements. How did you choose which to select? Our standard procedure to select the lab LHV which closely reflects values calculated in our template calculation workbook O&M Plans Condensate & Separators: Can you please check the box in Section 3 and email me the new O&M plan? Attached • Separators: Are the two gas flowmeters already installed and operational in the locations provided on the process diagram? • Yes Form 102 • The condensate tank emissions don't match the APEN. Can you please send an updated Form 102 with this update and any other updated the comments above cause? • In QC. Please find the updated Form -102 attached. Thanks, James Ricci Permit Engineer CDPH !COLORADO Air Pollution Control Division Deoa•meof of Public Health a Environment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd 3 attachments ▪ Pedigree_Extraction Oil & Gas, Inc2311Hergert.pdf 113K � ▪ Hergert-Launer_Updated APENs_2019.03.07.Pdf 352K ▪ Hergert-Launer_Updated Form -102 & Emission Calculations_2019.03.06.pdf 149K rnm/maii/li/n?ik=5517734b80&view=at&search=all&permmsgid=msg-fD/D3A1627457494089857032&simpl=msg-f%3A16274574940... 3/3 Hello