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Home My WebLink About20194120.tiff RECEIVED -1-1 COLORADO SEP 1 3 2019 `'' - Department of Public coa"E HealthfEnvironment WELD COUNTY COMMISSIONERS Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 September 11, 2019 Dear Sir or Madam: On September 12, 2019, the Air Pollution Control Division will begin a 30-day public notice period for Extraction Oil &t Gas, Inc. - Enright 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, I ) Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ` Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director # N1 i,r* Publ l c key .6 CC. PL(rP) HL(L.K) Pw(3 4/ER/cH/cw) 9/23/i9 OG(st-t) 2019-4120 MIM,,M Air Pollution Control Division cNotice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Extraction Oil Et Gas, Inc. - Enright Production Facility - Weld County Notice Period Begins: September 12, 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: Enright Production Facility EEtP Well Pad Site SWSE SEC 18 T4N R68W Weld County The proposed project or activity is as follows: The applicant proposes to permit a new oil and gas production facility located within the eight-hour (8-hr) Ozone Control Area of Weld County. Emission points with this facility include condensate tanks, produced water tanks, condensate loadout, and gas flaring. 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 19WE0087 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: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 ite(COLORADO Depi tment of Public 1 I Health b Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Christopher Kester Package #: 392506 Received Date: 1/23/201..9 Review Start Date: 5/21/2019 Section 01 - Facility Information Company Name: Extraction Oil & Gas inc . Quadrant Section Township Range County AIRS ID: 123 S >"' 68 Plant AIRS ID: Facility Name: Enright Production Facility R _ x .. , 11.4 e- y ex xrr Physical Address/Location: SWSE quadrant of Section 18, Township 4N, Range 68W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Carbon Monoxide (CO) ❑ Particulate Matter (PM) ./ Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert AIRs Point # Emissions Source Type Equipment Name Permit tt Issuance tt Action Engineering Remarks Control? Required? 001 Condensate Tank I K 001-008 Yes 19WE0087 Yes 002 Produced Water Tank PW 001-002 Yes 19WE0088 Yes 003 Separator Venting LP Yes 19WE0089 Yes ' 004 Separator Venting VRT Yes 19WE0090 Yes s initial Issuance 005 Liquid Loading LOAD Yes 19WE0091 Yes Point was cancelled before 006 Turbine TURB-001 No 19WE0092 Yes permit issued Section 03 - Description of Project New synthetic minor E&P facility with a turbine power generator. `j"T l.v.ie '<'P�^i(,;<. R9>,1��yy'",,•��t Zr f{ t °2` its ,tj'�Ma 'st \+ .s. > P-�r.1 < - r '(� ,��>r> '>F +^ •�"�wT&L�)�2'�1a��1 r'�• i �rb�'�ji�< .n sZ>` '`ra�o.'',T�-airs. 7'Fy�'+xr..ry+'otati l'`.> ' t ' .I. Ot" °�w.°el .q^eay, �>'G,c ^°t^ .,a• ?- l:. r. •... t czxS.i' l <. 4 s r ,oaf » a 3, a'£r +tak ,rAi'fpa�� »��a >as a.-a ..R 3' �.3,�'E`.Tl] .Se 1 '��fCl��y 4�•l.S Mi,•. '0'!�• � '.S d�.i°>`lY�. •�d�t e, ' illi tit.....4. <` 4 A.' t e ,' '3ll S$< �;. n �r„,.°j�'ib ir3'a'S.mP'y5.J1�•- k 1 ° << < .. - ..�' sjf .'dia�ij° N' e�.J��fr Pte^ >• <�(s�r >s rs-rP �'4 r< v. , < �s R. n < t� ��.. °�.�b'`� :a'• Z-�"N h.< � L ��4 „j<� •..'� .,i��,��y a��<8}! <��h , ^rte¢o � n�+^, � �y x :.. e ~ ` " ` i ai B> .a P `1 ide,1 o-Yi � :,T< .04)* d fitt`6+F.ir irRNC,�; '�'rY _..rs -'' ?. s &>' £i 4 h •• "k 6 �•it' r' ^�3:''b'�r h—�'rp '�r _ -: '�rx� ?'. "y%i xS: N.... .� +_ �,,.•p�..�. 4• _. ,� •= �°�>. '�°°P A �:`i.j�ia�`e�r�-s:" H.s° 'i<�.� �,xs N°aP F a'� � ': `' �.+.J'Y".> Ge.z �•.p ,� .r {� �;:. •7 i� 'a �p� ..r A. as r to � . c�4s ^x"k' Y" „P �' 4s9+ •::: 5� ^,'.. �rY .t - t t �f•r✓ ri aI 4. y '�. n. V t. o- � �. .,, .7A < . . , e�a� 3ss�'�z e4�.�r. . '� W' .Sa.9�'r..�.:�., ti'�'3t ..`� ♦:)-...M. 't�' '��%°�' .r..-'. C.�: > •A.<,..... s.,ga,�s.s�>,.�v^c>3i"i'uz:.e:{� ,� � •>E" . s "+"qs%•. ,r:,5i .s,�;��;� n�G C., '�krs" fi, s�q �..<: . � ': J� F ` ''.his«. r c. ..c�M: „:z N. Y'3 ,�. .i -. . oc. �., Y� s� -+..-Y>'.'-x`�:�T{e.�^.��a ,.pp��y' es: i �m' .{�p�...j•��tjj�� '•Y^_. v �s �t�� 2 n..•x' .n-bt fir ,q� : •< r —< .t' i : y-'r aa. W Q-..<r ti+'i,34. o£.3s:.H.r3Y.. .tit t .� a. /#2.' : ,` ".. ,Nucsa .2^. .• i €2*,.,t' . � �..'S. '52�s:<�.`S..I r ,I .... ..��n ... .�'a-'sr-�st'�r. .v�> , . . . r . . .. -. . . : . . : . ... .. . . ^ > . ... .�. . d!m� .k .,. Y>%?F> sF:.YdF,,Y ,..i't-. . . . i�- . . ..w�.rFw�a «^'c�7�.✓ � .>:�.,>..>M.,.>,,,>M..,~ .,..M....,....>..>...._ Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Re uestin 5 nthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? Y'. • If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) J (.../ ../ 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) Title V Operating Permits (OP) o O Colorado Air Permitting Project Non Attainment New Source Review(NANSR) — — u I ( - Condensate Storage Tank (s ) Emissions Inventory 001 Condensate Tank 123 A021 001 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Eight (8) 400 bbl fixed roof condensate storage tanks Description: Emission Control Device Enclosed Combustor Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 592,760 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 592,760 Barrels (bbl) per year Requested Permit Limit Throughput = 711,312 Barrels (bbl) per year Requested Monthly Throughput = 60.113 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = 711,312 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2.452 Btu/scf Volume of waste gas emitted per BBL of liquids produced = scf/bbl Actual heat content of waste gas routed to combustion device = 2,090 MMBTU per year Requested heat content of waste gas routed to combustion device = 2,990 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 2,99'0 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 0.19900 0.00995 Site Sy.>.' {, ;r:,:itiwr , iiash) Benzene 0.00040 0.00002 Site Specific E.P. (includes Hash) Toluene 0.00029 0.00001 Site Specific E.F. (includes flash) Ethylbenzene 0.00004 0.00000 Site Specific ES. (includes flash) Xylene 0.00008 0.00000 Site Specific E.F. (Includes flash) n-Hexane 0.00355 0.00018 Site Specific E.F. (includes flash) 224 IMP 0.00002 0.00000 Site Specific E.F. (includes flash) Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM 10 0.0075 0.0000 AP-4Z 1atme 1.4-2 (PM10/PM.2S) PM2.5 0.0075 0.0000 AP-42 Table 1,4-2 (PM10/PM,2.5) NOx 0.0680 0.0000 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 0.0000 AP-42 Chapter 13.5 Industrial flares (CO) Section 05 - Emissions Inventory Potential to Emit Actual Emissiors Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Cortrolled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tors/year) (tons/year) (tons/year) (lbs/month) VOC 70.8 59.0 2.9 70.8 3.5 601 PM10 0.0 0.0 0.0 0.0 0.0 2 PM2.5 0.0 0.0 0.0 0.0 0.0 2 NOx 0.1 0.1 0.1 0.1 0.1 17 CO 0.5 0.5 0.5 0.5 0.5 79 Potential to Emit Actual Emissiors Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Cortrolled Uncontrolled Controlled (lbs/year) (lbs/year) (lb;/year) (lbs/year) (lbs/year) Benzene 281 234 12 281 14 Toluene 208 173 9 208 10 Ethylbenzene 27 23 1 27 1 Xylene 56 47 2 56 3 n-Hexane 2522 2102 105 2522 126 224 TMP 15 13 1 15 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 3 of 22 K:\PA\2019\19WE0087.CP1 Condensate Storage Tank (s ) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate em ssions? No If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? No.` If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on 3 pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e-g-, no new wells brought on-line), then it may be appropriate to use an older site-specific sample. Yes 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. Does the company request a control device efficiency greater than 95% fcr a flare or combustion device? 4io'.fz.wxtl.�irsi.'�..:.ss:G:::: 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 I1 , Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process# SCC Code Pollutant Factor Control % Units 001 01 PM10 0.00 0 Ib/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 4.7 95 Ib/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 Ib/1,000 gallons condensate throughput Ethylbenzene 0.00 95 Ib/1,000 gallons condensate throughput Xylene 0.00 95 lb/1,000 gallons condensate throughput n-Hexane 0.08 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 Ib/1,000 gallons condensate throughput • 4 of 22 K:\PA\2019\19WE0087.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit R uirements Source is in the Non Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date(service date) prior to 12/30/2002 and not modif ed 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 11.113)? 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)? Yes Source Req 2. Is the construction date(service date) prior to 12/30/2002 and not modif ed after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? No Go to next 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 WY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section Il.D.2)? Yes Source Req 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? Yes Continue - ' 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? Yes Continue- ' 3. Is this storage tank located upstream of a natural gas processing plant? Yes Source is st Storage tank is subject to Regulation 7, Section XtLC•F Section XILC.1 -General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C2 - Emission Estimation Procedures Section XII.D - Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue - ' 2.. Is this storage tank located at a natural gas processing plant? NO Storage Tar 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? Storage Tank is not subject to Regulation 7, Section XII.G Section XII.G2 - Emissions Control Requirements Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C2 - Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? t . Continue - ' 2. Is this condensate storage tanks located at an oil and gas exploration and production operation , well production facility', natural gas compressor station'or natural gas processing plant? r Go to the n 3. Is this condensate storage tank a fixed roof storage tank? Yes Go to the n 4. Are uncontrolled actual emissions`of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is st 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 condensate storage tank contain only "stabilized" liquids? No Source is st Storage tank is subject to Regulation 7, Section XVIl.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 BBLS]? No Storage Tat 2. Does the storage vessel meet the following exemption in 60.111 b(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 transfer' as defined in 60.111b? 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 60.111b? 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 psi) and without emissions to the atmosphere(60.110b(d)(2))7; or b. The design capacity is greater than or equal to 151 m3 [-950 BBLI and stores a liquid with a maximum true vapor pressure' less than 33 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))? Storage Tank is not subject to NSPS Kb 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 0000, Standards of Performance for Crude Oil anc 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? Continue 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? Storage Tar 4. Does this condensate storage vessel meet the definition of "storage vessel per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per§60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(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: Continue - ' a. A facility that processes, upgrades or stores hydrocarbon liquids= (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user 3 (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? No Storage Tar 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subject to MACT HH Subpart A, General provisions per§63.764 (a)Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank it 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 tan, " 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 Produced Water Storage Tank( s ) Emissions Inventory 002 Produced Water Tank 123 A021 002 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Two (2) 400 bbl fixed roof produced water storage tanks Description: Emission Control Device Enclosed Combustor Description: Requested Overall VOC & HAP Control Efficiency %: 95 • Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 657,000.0 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 657,000 Requested Permit Limit Throughput = 788,400.0 Barrels (bbl) per year Requested Monthly Throughput = 66960 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = 788,400 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 1362 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 5.4 scf/bbl Actual heat content of waste gas routed to combustion device = 4,832 MMBTU per year Requested heat content of waste gas routed to combustion device = 5,799 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 5,799 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? _ . . Emission Factors Produced Water Tank Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source Pollutant (Produced (Produced Water Water Throughput) Throughput) VOC 0.20791. 0.010.10 Site Specific E.F. (incft, des flash) Benzene 0.00227 0.00011 Site Specific E.F. (Includes flash) Toluene 0.00140 0.00007 Site Specific E.F. (includes flash) Ethylbenzene 0.00012 0.00001 Site Specific E.F. (includes flash) Xylene 0.00029 0.00001 Site Specific E.F. (includes flash) n-Hexane 0.00266 0.00013 Site Specific E.F. (includes flash) .. 224 TMP 0.00000 0.00000 c-te 5pecifi+c ES. (includes flash) Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Produced (waste heat Water combusted) Throughput) PM10 0.0075 0.0001 AP-42 -.able 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 0.0001 AP-42 Table L4-2 (PM10/PM2.5) NOx 0.0680 0.0005 AP-42 Chapter 13.5 Industrial Flares (NOx} CO 0.3100 0.0023 AP-42 Chapter 13.5 Industrial Ftjr (CCfl Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) i (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) I VOC 82.0 68.3 3.4 82.0 4.1 696 PM10 0.0 0.0 0.0 0.0 0.0 4 PM2.5 0.0 0.0 0.0 0.0 0.0 4 NOx 0.2 0.2 0.2 0.2 0.2 33 CO 0.9 0.7 0.7 0.9 0.9 153 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 1793 1494 75 1793 90 Toluene 1107 923 46 1107 55 Ethylbenzene 95 80 4 95 5 Xylene 231 192 10 231 12 n-Hexane 2097 1748 87 2097 105 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO (See regulatory applicability worksheet for detailed analysis) 6 of 22 K:\PA\2019\19WE0087.CP1 Produced Water Storage Tank(s ) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate em ssions? Yes If yes and if there are flash emissions, are the emissions factors basec on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. • Does the company request a control device efficiency greater than 95% for a flare or combustion device? 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Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 002 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.01 0 lb/1,000 gallons liquid throughput VOC 5.0 95 lb/1,000 gallons liquid throughput CO 0.05 0 Ib/1,000 gallons liquid throughput Benzene 0.05 95 lb/1,000 gallons liquid throughput Toluene 0.03 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.01 95 lb/1,000 gallons liquid throughput n-Hexane 0.06 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 7 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Emissions Inventory 003 Separator Venting 123 A021 003 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Flash Liberation Analysis for PW tanks Detailed Emissions Unit Description: Enclosed Combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: ." Limited Process Parameter Liquid Throughput Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions Actual Throughput = 327,040.0 Barrels (bbl) per year Requested Permit Limit Throughput = 392,448.0 Barrels (bbl) per year Requested Monthly Throughput = 33331 MMscf per month Potential to Emit (PTE) Throughput = 392,448 Barrels (bbl) per year Process Control (Recycling) Equipped with a VRU: ; . . ..... . 4 Is VRU process equipment: Secondary Emissions - Combustion Device(s) for Air Pollution Control Gas Heating Value: Btu/scf Volume of waste gas emitted per BBL of liquids throughput: 5 scf/bbl Section 04 - Emissions Factors & Methodologies Description MW 33.2054 lb/lb-mot Displacement Equation Ex = Q * MW * Xx / C Weight % Helium 0.0000 CO2 9.45.33 N2 20.2258 methane 12.2318 ethane 14.1436 propane 22.7051 isobutane 2.8274 n-butane 10.0782 isopentane 1.8195 n-pentane 2.2869 cyclopentane 0.4276 n-Hexane 0.5623 cyclohexane 0.2727 Other hexanes 1.1500 heptanes 0.3467 methylcyclohexane 0.1973 224-TMP 0.0000 Benzene 0.4808 Toluene 0.2968 Ethylbenzene 0.0256 Xylenes 0.0618 C8+ Heavies 0.4068 Total 100.0000 VOC Wt % 43.9455 Emission Factors Separator Venting Uncontrolled Controlled (113/bbl) (lb/bbl) Emission Factor Source Pollutant (Liquid Throughput) (Liquid Throughput) VOC 0.2079 0.0104 Benzene 0.0023 0.0001 Toluene 0.0014 0.0001 Ethylbenzene 0.0001 0.0000 Xylene 0.0003 0.0000 n-Hexane 0.0027 0.0001 224 TMP 0.0000 0.0000 Primary Control Device Uncontrolled Uncontrolled Pollutant (16/MMBtu) lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 0.000 A <;.2101N1:::. ti PM2.5 0.0075 0.000 SOx 0.0006 0.000 NOx 0.0680 0.001 I 8 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Emissions Inventory co P��,RA ,MA 0.002 9 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Emissions Inventory Section OS - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.01 0.01 0.01 0.01 0.01 2 PM2.5 0.01 0.01 0.01 0.01 0.01 2 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 0.10 0.08 0.08 0.10 0.10 17 VOC 40.80 34.00 1.70 40.80 2.04 346 CO 0.45 0.37 0.37 0.45 0.45 76 I Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 893 744 37 893 45 Toluene 551 459 23 551 28 Ethylbenzene 48 40 2 48 2 Xylene 115 96 5 115 6 n-Hexane 1044 870 44 1044 52 224 TM P 0 0 0 0 0 10 of 22 K:\PA\2019\19WE0087.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Re ulation 3 Parts A and 8 - APEN and Permit Re uirements Source is in the Non-Attainment Area • ATTAINMENT Jyy 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.l.a)? E »l�; 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 e, Section II.D.1.M) �1:�'y 3. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 'A ;1 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)? Yes Source Req 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 8, Section II.D.1.M) No Go to next 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 Source Req Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? No Continue - 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor station3 or natural gas processing plant? Yes Continue - ' 3. Is this produced water storage tank a fixed roof storage tank? Yes Go to the n 4. Are uncontrolled actual emissions4 of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is st 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 provisions apply. No Source is si Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue - 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? No Storage Tar 3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tar 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? Storage Tank is not subject to NSPS OOOO 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] RAG Review RAG 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 descnbe 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 Separator Venting Emissions Inventory 003 Separator Venting 123 A021 003 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details LP separator emissions Detailed Emissions Unit Description: enclosed combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: 98 Limited Process Parameter Natural Gas Vented Gas meter Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 25.27 MMscf per year Requested Permit Limit Throughput = 30.33 MMscf per year Requested Monthly Throughput = 3 MMscf per month Potential to Emit (PTE) Throughput = 30. 33 MMscf per year Process Control (Recycling) Equipped with a VRU: Yes Is VRU process equipment: Yr.:", • Unccntrolled 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: 1864 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: • scf/bbl Section 04 - Emissions Factors & Methodologies Description MW 36.5665 lb/lb-mol Displacement Equation Ex = Q * MW * Xx / C Weight % Helium 0.0000 CO2 1.9338 N2 1.3523 methane 14.3395 ethane 16.1726 propane 28.7824 isobutane 4.4286 n-butane 14.1953 isopentane 3.6645 n-pentane 4.9766 cyclopentane 0.4969 n-Hexane 1,8690 cyclohexane 0.4911 Other hexanes 3.0567 heptanes 1.4905 methylcyclohexane 0.4943 224-TMP 0.0009 Benzene 0.2450 Toluene 0.2108 Ethylbenzene 0.0267 Xylenes 0.0809 C8+ Heavies 1.3488 Total ')9.6572 VOC Wt % 65.8590 Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 63541.77 1270.84 ixtended gas analysi: Benzene 236.38 4.73 Extended gas analysis Toluene 203.33 4.07 Extended gas analysis Ethylbenzene 25.76 0.52 Extended gas analysis Xylene 78.05 1.56 Extended gas analysis n-Hexane 1803.24 36.06 Extended gas analysis 224 TMP 0.8683 0.0174 Extended gas analysis Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 13.888 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 13.888 AP'-42 Table 1.4-2 (PM10/PM>2,5) SOx 0.0006 1.096 AP-42 Table 1.4-2 (SOx) NOx 0.0680 126.743 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 577.300 _ AP-42 Chapter 13.5 Industrial Flares (CO) 12 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.21 0.18 0.18 0.21 0.21 36 PM2.5 0.21 0.18 0.18 0.21 0.21 36 SOx 0.02 0.01 0.01 0.02 0.02 3 NOx 1.92 1.60 1.60 1.92 1.92 326 VOC 963.61 802.85 16.06 963.61 19.27 3274 CO 8.76 7.30 7.30 8.76 8.76 1488 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 7169 5973 119 7169 143 Toluene 6169 5139 103 6169 123 Ethylbenzene 781 651 13 781 16 Xylene 2367 1972 39 2367 47 n-Hexane 54692 45568 911 54692 1094 224 TM 26 22 0.4 26 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The :ontrol 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 Requiremeit" 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 t D 90 tons per year? Fr Ili If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site-specific as sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume cf 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? Yes 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. • • • • • 13 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emiss'ons Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 003 01 3-10-001 -60 Flares PM10 13.89 0 lb/MMSCF PM2.5 13.89 0 lb/MMSCF SOx 1.10 0 Ib/MMSCF NOx 126.74 0 Ib/MMSCF VOC 63541.77 98 lb/MMSCF CO 577.80 0 lb/MMSCF Benzene 236.38 98 lb/MMSCF Toluene 203.38 98 Ib/MMSCF Ethylbenzene 25.76 98 Ib/MMSCF Xylene 78.05 98 Ib/MMSCF n-Hexane 1803.24 98 lb/MMSCF 224 TMP 0.87 98 Ib/MMSCF 14 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirenents Source is in the Non-P-ttainment 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)? Yes Source Req 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 Req 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 st Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisons for Air Pollution Contro Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section' a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? No The contro The control device for this separator is not subject to Regulation 7, Section XVlI.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 cortains 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 otter 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 v41 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 Separator Venting Emissions Inventory 004 Separator Venting A021 004 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details One Vapor Recovery Tower Detailed Emissions Unit Description: £noosed Combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiercy %: 98 Limited Process Parameter Natural Gas Vented Gas meter Yes meter Is currently instated and operationa Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 3.85 MM5cf per year Requested Permit Limit Throughput = 4.62 MM5cf per year Requested Monthly Throughput = 0 MMscf per month Potential to Emit (PTE) Throughput = 4.62 MMscf per year Process Control (Recycling) Equipped with a VRU: Yes Is VRU process equipment: Yes Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Contr3I Separator Gas Heating Value: 246': Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/hbl Section 04 - Emissions Factors & Methodologies Description MW 48.3411 Ib/Ib-mol Displacement Equation Ex = O * MW * Xx / C Weight % Helium 0.0000 CO2 1.4556 N2 0.5737 methane 2.0829 ethane 9.0355 propane 34.1207 isobutane 6.9470 n-butane 23.5950 isopentane 5.7575 n-pentane 7.1789 cyclopentane 0.6003 n-Hexane 1.7727 cyclohexane 0.4181 Other hexanes 3.1551 heptanes 1.2545 methylcyclohexane 0.3837 224-TMP 0.0008 Benzene 0.2083 Toluene 0. 1441 Ethylbenzene 0.0186 Xylenes 0.0531 C8+ Heavies 1.0600 Total 99.8161 VOC Wt % 86.6684 Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 110544.74 2210.89 Extended gas analysis Benzene 265.68 5.31 Extended gas analysis Toluene 183.80 3.68 Extended gas analysis Ethylbenzene 23.72 0.47 Extended gas analysis Xylene 67.73 1.35 Extended gas analysis n-Hexane 2261.06 45.22 Extended gas analysis 224 TMP 1.02 0.02 Extended gas analysis Primary Cc ntrol Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 18.365 _ _ AP-42 Table 1.4-2 (PM10 PM.2.S) PM2.5 0.0075 18.365 AP-42 Table 1.4-2 (PM10f PM.2.S) SOx 0.0006 1.450 AP-42 Table 1.4-2 (S€lx) NOx 0.0680 _ 167.608 AP-42 Chapter 13,5 Industrial Flares (NOx} CO 0.3100 764.097 AP-42 Chapter 13.5 Industrial Flares (CC* 16 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.04 0.04 0.04 0.04 0.04 7 PM2.5 0.04 0.04 0.04 0.04 0.04 7 SOx 0.00 0.00 0.00 0.00 0.00 1 NOx 0.39 0.32 0.32 0.39 0.39 66 VOC 255. 36 212.80 4.26 255.36 5.11 863 CO 1.77 1 .47 1.47 1.77 1.77 300 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 1227 1023 20 1227 25 Toluene 849 708 14 849 17 Ethylbenzene 110 91 2 110 2 Xylene 313 261 5 313 6 n-Hexane 10446 3705 174 10446 209 224 TM P 5 4 0 5 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Not enough information Regulation 7, Section XVII.B, G Not enough information Regulation 7, Section XVII.B.2.e Not enough information (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? No If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? Yes 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. _• • 17 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 004 01 3-10-001 -60 Flares PM10 13.37 0 Ib/MMSCF PM2.5 18.37 0 lb/MMSCF SOx 1.45 0 Ib/MMSCF NOx 167.61 0 Ib/MMSCF VOC 110544.74 98 Ih/MMSCF CO 764.10 0 Ib/MMSCF Benzene 265.68 98 Ib/MMSCF Toluene 183.80 98 Ib/MMSCF Ethylbenzene 23.72 98 Ib/MMSCF Xylene 67.73 98 lb/MMSCF n-Hexane 2261.06 98 lb/MMSCF 224 TMP 1.02 98 Ib/MMSCF 18 of 22 K:\PA\2019\19WE0087.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 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 11.0.3)? 111111 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)? Not enough information Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Not enough information Section XVI1.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? Not enough information Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with detem;ining 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 aid 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 Hydrocarbon Loadout Emissions Inventory 005 liquid Loading 123 A021 005 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Condensate loading into trucks Description: Emission Control Device Enclosed Combustion Device Description: Is this loadout controlled? Yes Collection Efficiency: 100.0 Control Efficiency: 95 Requested Overall VOC & HAP Control Efficiency %: 95. 30 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 59,276 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 59,276 Barrels (bbl) per year Requested Permit Limit Throughput = 71,131 Barrels (bbl) per year Requested Monthly Throughput = 60-11 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 71,131 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2452 Btu/scf Volume of waste gas emitted per year = 93986 scf/year Actual heat content of waste gas routed to combustion device = 192 MMBTU per year Requested heat content of waste gas routed to combustion device = 230 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 2.30 MMBTU per year Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? No Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Yes The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Loading Loss Equation L = 12.46*S*P*M/T Factor Meaning Value Units Source S Saturation Factor C.6 P True Vapor Pressure 5.77 psia M Molecular Weight of Vapors 65 Ib/Ib-mol T Liquid Temperature 513.67 Rankine L Loading Losses 5.39548906 lb/1000 gallons 0.226610541 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.001985786 0.00045 lb/bbl Toluene 0.001469482 1000333 lb/bbl Ethylbenzene 0.000192842 0.0000437 lb/bbl Xylene 0.000398922 0.0000904 lb/bbl n-Hexane 0.01765143 0.004 lb/bbl 224 TMP 0.000108998 0.0000247 lb/bbl Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 0.2266 0.0113 = Specific - AP-42: Chapter 5.2, Equation 1 Benzene 0.0005 0.0000 z Specific - AP-42: Chapter 5.2, Equation 2 Toluene 0.0003 0.0000 c Specific- AP-42: Chapter 5.2, Equation 3 Ethylbenzene 0.0000 0.0000 Specific - AP-42: Chapter 5.2, Equation 4 Xylene 0.0001 0.0000 a Specific - AP-42: Chapter 5.2, Equation 5 n-Hexane 0.0040 0.0002 ? Specific - AP-42: Chapter 5.2, Equation 6 224 TMP 0.0000 0.0000 ? Specific-.AP-42: Chapter 5.2, Equation 7 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.0075 2.41E-05 AP-42 Table 1.4-2 (PM10/PM.2.5) PM 2.5 0.0075 2.41E-05 AP-42 Table 1.4-2 (PM10/PM.2.5) SOx 0.0006 1.91E-06 AP-42 Table 1.42 (SOx) NOx 0.0680 2.20E-04 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 1.00E-03 AP-42 Chapter 13.5 industrial Flares(CO) 20 of 22 K:\PA\2019\19WE0087.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM 10 0.00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 0.01 0.01 0.01 0.01 0.01 1 VOC 8.06 6.72 0.34 8.06 0.40 68 CO 0.04 0.03 0.03 0.04 0.04 6 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) (lbs/year) (Ibs/year) (lbs/year) Benzene 32 27 1 32 2 Toluene 24 20 1 24 1 Ethylbenzene 3 3 0 3 0 Xylene 6 5 0 6 0 n-Hexane 285 237 12 285 14 224 TMP 2 1 0 2 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must be operated with submerged fill to satisfy RAG. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes w�d�..A.r :..�..u.:wwr.+.-•.Vi4Lw �i4i .r ..f.:h-.. ... .... ..._ . .. .. ...:::_. .. ...-�..4uu� " :r��.-......-.:' e��C ..-.....-......-._..._............-...-....._......_.-. _.-.-._. ...._...._ . s -......�....w._..-..._... _.... _. .._ ...._................ _. _ _ ...... _..._ __.__ -.._.. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 005 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.4 95 lb/1,000 gallons transferred CO 0.02 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.01 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n-Hexane 0.10 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 21 of 22 K:\PA\2019\19WE0087.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? PI 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bols per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 obis per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 —PY, 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)? yes Go to next 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? yes Go to the n 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? no Go to next 4. Is the loadout operation loading less than 6,750 tbls per year of condensate via splash fill? no Go to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? no Go to next 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? yes The loadou Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? r.o The loadou The loadout must be operated with submerged fill to satisfy RACT. Disclaimer This document assists operators with determ ning 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 regtlations, but this document does not establish legally binding requirements in and of itself. cDPV COLORADO CO 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: 19WE0087 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Enright Production Facility Plant AIRS ID: 123/A021 Physical Location: SWSE SEC 18 T4N R68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID TK 001-008 001 Eight (8) 400 bbl fixed roof condensate Enclosed Combustion storage tanks Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 9 A CDPHE COLORADO CO 1. Air Pollution Control Division • Department of Pubbc Health t 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 AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type TK 001-008 001 --- 3.6 --- 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. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 9 CDPHE COLORADO 1 CO ,,, Air Pollution Control Division Department of Pubhc Heath El Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TK 001-008 001 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point TK 001-008 001 Condensate throughput 711,312 barrels The owner or operator shall monitor monthly process rates based on the calendar month. During the first twelve(12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: Page 3 of 9 CDPHE COLORADO CO � Air Pollution Control Division Department of Public Heath ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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) 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 approved by the Division, determine whether it is operating property. 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 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. 15. 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 16. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 9 CDPHE COLORADO CO ZIf Air Pollution Control Division Department of Pubic Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division 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 V0C or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 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. Page 5 of 9 A, COPHE COLORADO CO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Page 6 of 9 A `OPHE COLORADO CO Air Pollution Control Division Department of Public I fealth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. Page 7 of 9 HE COLORADO CO If Air Pollution Control Division Department or 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 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 Uncontrolled Controlled. Point Pollutant CAS # Emissions ! Emissions (lb/yr) (lb/yr) Benzene 71432 281 14 001 n-Hexane 110543 2522 126 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 0.19900 0.00995 71432 Benzene 0.00040 0.00002 Site Specific 110543 n-Hexane 0.00355 0.00018 Data 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 Page 8 of 9 4 COPHE COLORADO CO •i Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Status Requirement Operating Permit Synthetic Minor Source of: CO and VOC NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A- Appendix 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 9 of 9 CDPHE COLORADO CO % Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0089 Issuance: I Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Enright Production Facility Plant AIRS ID: 123/A021 Physical Location: SWSE SEC 18 T4N R68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment!Description ID Point Description EnLP 003 Low Pressure Separators vied Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit by submitting a Notice of Startup form to the Division for the equipment covered by ths permit. The Notice of Startup form may be downloaded online at www.colorado.�ov/cdphe/iair/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 must 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 Page 1 of 12 4CDPHE COLORADO 1/4 LI CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Upon issuance of this permit, the operator must install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. 5. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 6. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type LP 003 --- 2.0 19.3 8.8 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 must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must Page 2 of 12 CDPHE COLORADO CO Air Pollution Control Division Department of Pubiic Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 9. The emission points in the table below must 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.) Equipment AIRS Control Device Pollutants ID Point Controlled Enclosed Combustion Device (Make: LP 003 Questor, model: Q5000, serial number: VOC and HAP Q5000-17-195) PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actuajl processing rates must 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 Equipment ID AIRS Process Parameter Annual Limit Point LP 003 Natural Gas Venting 30.33 MMscf Compliance with the annual throughput limits must 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 must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. Upon issuance of this permit, the owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 12. The owner or operator shall continuously monitor the control device for the presence of a pilot light and an operational auto-igniter. These monitoring records shall be used to Page 3 of 12 ,A CLUE COLORADO CO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto-igniter, the owner or operator shall assume a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. 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 must 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. 16. 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 17. Upon startup of these points, the owner or operator must 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.) Page 4 of 12 A CDPHE COLORADO CO Air Pollution Control Division Department of Pubic Wealth&Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator must conduct an initial source compliance test to demonstrate compliance with the combined emissions limit ("Combined Limit" as specified in Condition 6 of this permit) for volatile organic compounds (VOC) and to demonstrate a minimum destruction efficiency of 98% for VOC. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Results of the initial compliance tests must be submitted to the Division as part of the self- certification. Periodic Testing Requirements 19. On an annual basis, the owner or operator must conduct a source compliance test to demonstrate compliance with the combined emissions limit ("Combined Limit" as specified in Condition 6 of this permit) for volatile organic compounds (VOC) specified in this permit and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; Page 5 of 12 A ` E COLORADO CO Ir Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with an annual emission limitation shall have the results projected up to the annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ALTERNATIVE OPERATING SCENARIOS 20. The control device may be replaced with a like-kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like-kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this construction permit. The owner or operator shall maintain a log on-site or at a local field office to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 21. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternate Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternate Operating Scenario and has replaced the control device. 22. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternate Operating Scenario provision, the owner or operator must conduct an initial source compliance test to demonstrate compliance with the combined emissions limit ("Combined Limit" as specified in Condition 6 of this permit) for volatile organic compounds (VOC) and to demonstrate a minimum destruction efficiency of 98%for VOC. During the test, the owner or operator must measure: Page 6 of 12 CDPHE COLORADO CO yi Air Pollution Control Division " Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • mass emission rates of VOC at the inlet of the control device (Mi) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)Mi The test protpcol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30)days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ADDITIONAL REQUIREMENTS 23. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or Page 7 of 12 * `DP1HE COLORADO CO If Air Pollution Control Division • Department of Public Health f&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 24. 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. 25. 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. 26. 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. 27. 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 8 of 12 ` tDPHE COLORADO CO �� Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 28. 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must 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. 29. 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. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. Page 9 of 12 CDPHE COLORADO CO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must 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 must 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 sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 7,169 143 Toluene 108883 6,169 123 LP 003 Ethylbenzene 100414 781 16 Xylenes 1330207 2,367 47 n-Hexane 110543 54,692 1,094 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (ib/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 10 of 12 CDPHE COLORADO co Air Pollution Control Division Department of Public Health Er 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: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMscf) (lb/MMscf) N0x 0.0680 lb/MMBtu 0.0680 lb/MMBtu AP 42 CO 0.3100 lb/MMBtu 0.3100 lb/MMBtu V0C 63,541.77 1,270.84 71432 Benzene 236.38 4.73 108883 Toluene 203.38 4.07 Site Specific Gas 100414 Ethylbenzene 25.76 0.52 Sample 1330207 Xylene 78.05 1.56 110543 n-Hexane 1,803.24 36.06 Note: The controlled emissions factors for this point are based on a control efficiency of 98%. 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 must 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 Status Requirement Operating Permit Synthetic Minor Source of: CO and V0C NANSR Synthetic Minor Source of: V0C 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU 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 Page 11 of 12 CDPHE COLORADO CO Air Pollution Control Division • Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 12 of 12 CDPHE COLORADO CO Air Pollution Control Division Department of Pubiic Heakh b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE0090 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Enright Production Facility Plant AIRS ID: 123/A021 Physical Location: SWSE SEC 18 T4N R68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description VRT 004 One Vapor Recovery Tower (VRT) Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must 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 Page 1 of 12 CDPHE COLORADO CO J Air Pollution Control Division Department of Pub'tic Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Upon issuance of this permit, the operator must install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. 5. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 6. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type VRT 004 --- --- 5.1 --- Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve Page 2 of 12 ttFHE COLORADO CO 'f` Air Pollution Control Division a Department of Public 1 leatth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 9. The emission points in the table below must 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.) Equipment AIRS Control Device Pollutants ID Point Controlled Enclosed Combustion Device (Make: VRT 004 Questor, model: Q5000, serial number: VOC and HAP Q5000-17-195) PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Process Limits Equipment ID AIRS Process Parameter Annual Limit Point VRT 004 Natural Gas Venting 4.62 MMscf Compliance with the annual throughput limits must 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 must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. Upon issuance of this permit, the owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. Page 3 of 12 cDPHE COLORADO CO Air Pollution Control Division Department of Public Health El Enrironment Dedicated to protecting and improving the health and environment of the people of Colorado 12. The owner or operator shall continuously monitor the control device for the presence of a pilot light and an operational auto-igniter. These monitoring records shall be used to calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto-igniter, the owner or operator shall assume a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. 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 must 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. 16. 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 17. Upon startup of these points, the owner or operator must 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 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 12 CD‘PHE COLORADO CO 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 TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator must conduct an initial source compliance test to demonstrate compliance with the combined emissions limit ("Combined Limit" as specified in Condition 6 of this permit) for volatile organic compounds (VOC) and to demonstrate a minimum destruction efficiency of 98% for VOC. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30)days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Results of the initial compliance tests must be submitted to the Division as part of the self- certification. Periodic Testing Requirements 19. On an annual basis, the owner or operator must conduct a source compliance test to demonstrate compliance with the combined emissions limit ("Combined Limit" as specified in Condition 6 of this permit) for volatile organic compounds (VOC) specified in this permit and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; Page 5 of 12 41/4 CD?HE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with an annual emission limitation shall have the results projected up to the annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ALTERNATIVE OPERATING SCENARIOS 20. The control device may be replaced with a like-kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like-kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this construction permit. The owner or operator shall maintain a log on-site or at a local field office to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 21. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternate Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternate Operating Scenario and has replaced the control device. 22. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternate Operating Scenario provision, the owner or operator must conduct an initial source compliance test to demonstrate compliance with the combined emissions limit ("Combined Limit" as specified in Condition 6 of this permit) for volatile organic compounds (VOC) and to demonstrate a minimum destruction efficiency of 98% for VOC. During the test, the owner or operator must measure: Page 6 of 12 * CD°HE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • mass emission rates of VOC at the inlet of the control device (Mi) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results,projected up to the monthly or annual averaging time by multiplying the test results by the Process Limits)for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Records of the annual compliance tests must be maintained by the owner or operator and made available to the Division for inspection upon request. ADDITIONAL REQUIREMENTS 23. A revised Air Pollutant Emission Notice (APEN) must 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,) in ozone nonattainment areas emitting less than 100 tons of V0C or N0X per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or Page 7 of 12 CcoHE COLORADO CO 4.1 Air Pollution Control Division Department of Public f-feaith b Environment Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. • GENERAL TERMS AND CONDITIONS 24. 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. 25. 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. 26. 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. 27. 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 8 of 12 A cDP COLORADO Air Pollution Control Division CO Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 28. 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must 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. 29. 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. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description • Issuance 1 This Issuance Issued to Extraction Oil £t Gas, Inc. Page 9 of 12 4, COHE COLORADO CO 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 must 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 must 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 sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) • Benzene 71432 1,227 25 Toluene 108883 849 17 VRT 004 Xylenes 1330207 313 6 n-Hexane 110543 10,446 209 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 10 of 12 ¢PHE COLORADO CO „f` Air Pollution Control Division Department of Pubic Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMscf) (lb/MMscf) N0x 0.06801b/MMBtu 0.0680 lb/MMBtu AP-42 CO 0.3100 lb/MMBtu 0.3100 lb/MMBtu V0C 110,544.74 2,210.89 _ 71432 Benzene 265.68 5.31 108883 Toluene 183.80 3.68 Site Specific Gas 1330207 Xylene 67.73 1.35 Sample 110543 n-Hexane 2,261.06 45.22 Note; The controlled emissions factors for this point are based on a control efficiency of 98%. 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 must 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 Status Requirement Operating Permit Synthetic Minor Source of: CO and V0C NANSR Synthetic Minor Source of: V0C 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY Page 11 of 12 cop COLORADO CO Air Pollution Control Division "' Department of Pubiic t{ealth&Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 12 of 12 cHe COLORADO Irk CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0091 Issuance: 1 Date issued: Issued to: Extraction Oil a Gas, Inc. Facility Name: Enright Production Facility Plant AIRS ID: 123/A021 Physical Location: SWSE SEC 18 T4N R68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID LOAD 005 Truck loadout of condensate by Enclosed Combustion submerged fill Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.Qov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 9 ,* cDPHE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type LOAD 005 --- --- 0.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 9 ,^ CDPHE COLORADO CO If Air Pollution Control Division Department of Pubiic Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Equipment Point Control Device Pollutants Controlled ID LOAD 005 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point" LOAD 005 Condensate Loaded 71,131 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 13. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. Page 3 of 9 A, CCPHE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 14. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 15. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance ((NtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your OEtM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) Page 4 of 9 A CDPHE COLORADO CO If Air Pollution Control Division Department of Public HeatthEr Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 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 Page 5 of 9 A CDPHE COLORADO CO . Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 shalt be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Page 6 of 9 * CDPHE COLORADO CO L� Air Pollution Control Division Department of Pub?ic Health Ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Page 7 of 9 ,* cCPHE COLORADO CO If Air Pollution Control Division • Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) 005 n-Hexane 110543 285 14 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled Pollutant CAS # Emission Emission Factors Factors lb/bbl lb/bbl VOC 0.2266 0.0113 n-Hexane 110543 0.0040 0.0002 The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.77 psia M (vapor molecular weight) = 65 lb/lb-mol T (temperature of liquid loaded) = 519.67 °R Page 8 of 9 ,;, CDZPHHE COLORADO CO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. 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 Status Requirement Operating Permit Synthetic Minor Source of: CO and VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 JAN 232019 CDPHE Condensate Storage Tank(s) APEN 41 Form APCD-205 CO w� 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: q Weeog7 AIRS ID Number: 123 A�2 J / 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: Enright Production Facility Site Location: Site Location SWSE Section 18 T4N R68W County: Weld NAILS or SIC Code: 211111 Mating Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Contact Person: Catie Nelson Phone Number: (720) 354-4579 E-Mail Address2: 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. 392437 COLORADO Form APCD-205 - Condensate Storage Tank(s) lAPEN- Revision 7/2018 1 J - Hruth 6flWro�enl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source 0 Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 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): TK 001-008 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 10/25/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑✓ Exploration Et Production (EEtP)site O Midstream or Downstream (non EEtP)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? 0 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) 0 Yes ❑ No 805 series rules? If so, submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual 0 Yes ❑ No emissions≥6 ton/yr(per storage tank)? isr,COLORADO Form APCD-205- Condensate Storage Tank(s) APEN - Revision 7/2018 2 I xaatmacnmro+ex° Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Condensate Throughput: 592,760 711,312 From what year is the actual annual amount? Projected Average API gravity of sales oil: 43 degrees RVP of sales oil: 10.6 Tank design: ❑✓ Fixed roof 0 Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) TK 001-008 8 3200 10/2018 10/2018 Wells Serviced by this Storage Tank or Tank Batten!(E&P Sites Only) API Number Name of Well Newly Reported Well SEE ATTACHED FORM APCD-212 O - ❑ O O s Requested values will become permit limitations. Requested limit(s)should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.307193, -105.04486 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) ECDs —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) D Upward ❑Downward 0 Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): TBD ❑Square/rectangle Interior stack width(inches): Interior stack depth (inches): ❑Other(describe): Mgr COLORADO Form APCD-205- Condensate Storage Tank(s) APEN - Revision 7/2018 3 I AV Hama , Permit Number: AIRS ID Number: [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. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit (VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECDs Make/Model:TBD ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: >95 Minimum Temperature: TBD Waste Gas Heat Content: 2,452 Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: TBD MMBtu/hr Description of the closed loop system: O Closed Loop System Pollutants Controlled: O Other: 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 COLORADO Form APCD-205- Condensate Storage Tank(s) APEN - Revision 7/2018 4 I A_ �%niGh b er.1 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): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) VOC ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions8 Emissions Emissions Basis Mfg.etc)) (Tons/year) (Tons/year) (Tons/year) (Tons/year) VOC 0.199 lb/bbl Promax/Tanks409d 58.90 2.94 70.68 - 3.53 NOx 0.068 - Ib/MMBtu AP-42 0.02 0.03 CO 0.31 - lb/MMBtu AP-42 0.11 0.13,• Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Units (AP-42, Emissions Emissions5 Number Basis Mfg.etc) (Pounds/year) (Pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.004 ' lb/bbl Promax/Tanks409d 2,102 - 105 -- 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 7 Attach condensate liquid laboratory analysis,stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. COLORADO Form APCD-205- Condensate Storage Tank(s)APEN - Revision 7/2018 5 I A� ° `11.`g`"""`x rms�,:.+rorunenr 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 GPO8, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. r .In 1 122 7 L l Sign re of Legally Authori ed Person(not a vendor or consultant) ! ate Catie Nelson Air Quality Engineer Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd coLaeioo Form APCD 205 Condensate Storage Tank(s)APEN Revision 7/2018 6 `Ca ( :E.`... m 1.0 CDPHE Produced Water Storage Tank(s) A APEN - Form APCD-207 CO '� 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. AIRS ID Permit Number: /of wE019)$g Number: )23 1A3ZJ / a Q Z [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name: Extraction Oil & Gas, Inc. Site Name: Enright Production Facility Site Location Site Location: SWSE Section 18 T4N R68W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Contact Person: Catie Nelson Phone Number: (720) 354-4579 E-Mail Address2: cnelson@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 39249 COLORADO Form APCD-207- Produced Water Storage Tank(s)APEN - Revision 7/2018 1 I AV '°`°3"^=^`°'""`1G[thb EnvlxonmGnl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment ❑ Change company name3 ❑ Change permit limit O Transfer of ownership' ❑ Other(describe below) -OR- O APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ▪ APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: 3 For company name change,a completed Company Name Change Certification Form (Form APCD-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: Two (2) -400 bbl Produced Water Storage Vessels Company equipment Identification No. (optional): PW 001-002 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 10/25/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑✓ Exploration&Production (E&P)site ❑ Midstream or Downstream (non E&P)site Will this equipment be operated in any NAAQS nonattainment area? El Yes O No Are Flash Emissions anticipated from these storage tanks? Q Yes O No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes Q No wastewater for processing? Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ✓❑ Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes ❑ No 805 series rules? If so, submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual ❑ Yes ❑ No emissions ≥6 ton/yr(per storage tank)? COLORADO Form APCD-207- Produced Water Storage Tank(s)APEN - Revision 7/2018 2 I A� HaaUhb6eu ounenl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits C. Keikr (bbl/year) (bbl/year) Pv- Produced Water Throughput: 6S (x o 32 4'` �8 4O3 392,148 Projected T � � From what year is the actual annual amount? (p lt`)/2vr q Tank design: p Fixed roof ❑ Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bb() Storage Tank (month/year) (month/year) Pw 001-002 2 800 10/2018 10/2018 Wells Serviced by this Storage Tank or Tank Battery6(CRP Sites Only) API Number Name of Well Newly Reported Well SEE ATTACHED FORM APCD-212 0 0 0 0 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) 40.307193, -105.04486 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level (feet) (°F) (ACFM) (ft/sec) ECDs -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Downward 0 Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) ['Circular Interior stack diameter(inches): TBD ['Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): COLORADO Form APCD-207- Produced Water Storage Tank(s)APEN - Revision 7/2018 3 I . k°r'm°"`°'"""`xaairnscnmaoa�roar.. 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 Size: Make/Model: O Recovery Unit (VRU): Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECDs Make/Model:TB D Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 1362 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: 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)? —45 psig Describe the separation process between the well and the storage tanks: HLP Separator, Produced Water Storage Tanks AVCOLORADO Form APCD-207- Produced Water Storage Tank(s)APEN - Revision 7/2018 4 I 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): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) V0C ECDs 95 NOx CO HAPs ECDs 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP-42, Emissions Emissions Emissions Emissions. Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 0.208 lb/bbl Analysis 4'.l 3'3r'9e 3.4 ..1-r7tr N.1 -2102r- C-C040- .. NOx 0.068 lb/MMBtu AP-42 Co.IS•ele'r O•If.A•elf' rr CO 0.31 Ib/MMBtu AP-42 o.4y D32r- D.rt.(}iY Non-Criteria Reportable Pollutant Emissions Inventory 0/10) )Q Chemical Emission Factors Actual Annual Emissions Abstract Chemical Name Service CAS( Source Uncontrolled Controlled a ) Basis Uncontrolled Units (AP-42, Emissions Emissions Number Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.002 lb/bbl Analysis 1(f$3 r �38� Toluene 108883 0.001 lb/bbl Analysis q?,A l , ...22' Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.003 lb/bbl Analysis t1 (..88 -3" 2,2,4- 540841 Trimethylpentane 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. A (COLORADO Form APCD-207- Produced Water Storage Tank(s)APEN - Revision 7/2018 5 I - Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Sign ''o l 1 Si na Le all Authorized r n not a vendor or consultant) Dalte Catie Nelson Air Quality Engineer Name(print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) 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 For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd �p COLORADO Form APCD-2O7 Produced Water Storage Tank(s)APEN - Revision 7/2018 6 I .'J' i5,1",==,, E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: Extraction Oil&Gas,Inc. Source Name: Enright Production Facility Emissions Source AIRS ID2: TBD 125/A4b2a (662- Wells Serviced by this Storage Tank or Tank Batter(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-46582 Enright 1N ■ 05-123-46867 Enright 6N ■ 05-123-46579 Enright 7N ■ 05-123-46861 Enright 8C ■ 05-123-46581 Enright 9N ■ 05-123-46870 Enright l0N ■ 05-123-46585 Enright 11N ■ 05-123-46580 Enright 13C ■ 05-123-46866 Enright 14N ■ 05-123-46584 Enright 15N ■ 05-123-46865 Enright 16C ■ O O 0 O O 0 O O O Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD,enter NA Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver.7-29-2014 SO 151( CDDPHE Gas Venting APEN - Form APCD-211 CO ',, Air Pollutant Emission Notice (APEN) and ' Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /9 t4)E 0C6 g 5 AIRS ID Number: 12,3 /A?)2..(/0 G3 [leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name1: Extraction Oil & Gas, Inc. Site Name: Enright Production Facility Site Location Site Location: SWSE Section 18 T4N R68W Weld County: NAICS or SIC Code: 211111 Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, Colorado 80202 Contact Person: Catie Nelson Phone Number: (720) 354-4579 E-Mail Address2: cnelson@extractionog.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 392498 ,=was COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I ��IHe,��„bE„m�„�„� Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Low Pressure ("LP") Separator Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 1 0I25/201 8 ❑Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: TBD hours/day TBD days/week TBD weeks/year Will this equipment be operated in any NAAQS ❑✓ Yes O No nonattainment area? Is this equipment located at a stationary source that is Yes 0 No considered a Major Source of(HAP) Emissions? ❑ Is this equipment subject to Colorado Regulation No. 7, ❑✓ Yes No Section XVII.G? ❑ ACOLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I . N a{h6EulMmmnl 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: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: 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 ❑ No Vent Gas 2055 BTU/SCF Gas Venting Heating Value: Process Parameters5: q 30.33 y 25.27 MMSCF/year Requested: MMSCF/year Actual: MMSCF/ ear -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5 Molecular Weight: 36.57 VOC (Weight%) 65.80 Benzene (Weight%) 0.24 Vented Gas Toluene (Weight%) 0.21 Properties: Ethylbenzene (Weight 0.03 Xylene (Weight%) 0.08 n-Hexane (Weight%) 1.87 2,2,4-Trimethylpentane O o0 (Weight%) Additional Required Information: ✓❑ Attach a representative gas analysis (including BTEX Et n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis (including BTEX Et n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. COLORADO_ Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I H^allhbEnvlr°^m^rl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.307193, -105.04486 ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): TBD ❑Other (describe): 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: Size: Make/Model: ❑ VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: % Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model: TBD rA Combustion L1-1Device: Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: >99 % Minimum Temperature: TBD Waste Gas Heat Content: 2055 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: ItULV Auv Form APCD-211 - Gas Venting APEN - Revision 7/2018 4 I A �KeahhbE"Wonm[nl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) 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? Projected Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOX NO. 0.068 Ib/MMBtu AP-42 1.60 1.92 CO 0.31 Ib/MMBtu AP-42 7.30 8.76 VOC 63.462 Ib/Mscf Eng. Est. 801.91 16.04 962.29 ' 19.25 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Basis (pounds/ ear Number Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.236 Ib/Mscf Eng. Est. 5,967 119 ' Toluene 108883 0.203 Ib/Mscf Eng.Est. 5,129 i 103 / Ethylbenzene 100414 0.026 Ib/Mscf Eng. Est. 650 - 13 Xylene 1330207 0.078 Ib/Mscf Eng. Est. 1,972 - 39 ' n-Hexane 110543 1.801 Ib/Mscf Eng. Est. 45,512 s 910 - 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. Ay COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 I. my Ot.L "°°' {Ih bEnafrarunenl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 8 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. (2/7 P011 Cnth VIY\ Si nature of Legally Authorize P Sig � Yerson (not a vendor or consultant) Da e Catie Nelson - Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd COLORADO Form APCD-211 Gas Venting APEN - Revision 7/2018 6 1 AV JAW 1 3 2019 ,+, C° E Gas Venting APEN - Form APCD-211 CO Air Pollutant Emission Notice (APEN) and ,.� Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /q JEO'9 0 AIRS ID Number: MZ3/,4 Z1 /05(1, [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Enright Production Facility Site Location Site Location: SWSE Section 18 T4N R68W Weld County: NAICS or SIC Code: 211111 Mailing Address: 370 17th Street, Suite 5300 (Include Zip Code) Denver, Colorado 80202 Contact Person: Catie Nelson Phone Number: (720) 354-4579 E-Mail Address2: cnelson@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. I COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I �� `w Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership' O 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: Vapor Recovery Tower ("VRT") Venting Emissions Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 10/25/2018 ❑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 No nonattainment area? ❑ Is this equipment located at a stationary source that is ❑ Yes • 0 No considered a Major Source of(HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, 0 Yes No Section XVII.G? ❑ COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I AV 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: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: 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 ❑ No Vent Gas 2 734 BTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: 4.62 MMSCF/year Actual: 3.85 MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5: Molecular Weight: 48.3411 VOC (Weight%) 86.63 Benzene(Weight%) 0.21 Vented Gas Toluene (Weight%) 0.14 Properties: Ethylbenzene (Weight 0.02 Xylene (Weight%) 0.05 n-Hexane (Weight%) 1.77 2,2,4-Trimethylpentane 0 0007 (Weight%) Additional Required Information: • Attach a representative gas analysis (including BTEX It n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX>t 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 3 I k�ie�a �t°` }teat hb E1V1Y°Nllenl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.307193, -105.04486 rz1IUUUMi -`z.r ECD -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑Downward D Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): TBD O Other(describe): 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: Size: Make/Model: ❑ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model: TBD Combustion ❑ Device: Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: >99 Minimum Temperature: TBD Waste Gas Heat Content: 2,734 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: TBD MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: (3 LUKA VV :°:; _;;PuLUc Form APCD-211 - Gas Venting APEN - Revision 7/2018 4 I _ H,.��„b�n��mn~n�n� Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) 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? Projected Criteria Pollutant Emissions inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Units (AP-42, Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/year) tons/ ear (tons/year) (tons/year) (tons/year) ) PM SOx NO. 0.068 lb/MMBtu AP-42 0.32 0.39 i CO 0.31 lb/MMBtu AP-42 1.47 1.77 VOC 110.407 lb/Mscf Eng. Est. 212.64 4.25 255.17 5.10 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions° Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.265 Ib/Mscf Eng. Est. 1022 20 Toluene 108883. 0.184 Ib/Mscf Eng. Est. 707 - 14 Ethylbenzene 100414 Xylene 1330207 0.068 Ib/Mscf Eng. Est. 261 ' 5 ' n-Hexane 110543 2.258 Ib/Mscf Eng. Est. 8,699 - 174 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. i COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 I Al-gl. I°`"'°c°`°`"�`�Hgllhb F�snrOamenl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. C16-.1.? Al\4) /Ten V/ 710 Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name(please print) Title Check the appropriate box to request a copy of the: Q 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: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd COLORADO Form APCD-211 Gas Venting APEN- Revision 7/2018 6 I A•i°` n" • JAN 232019 C©PHE Hydrocarbon Liquid Loading APEN A° � ► Form APCD-208 CO •' Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission Unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: l'1WEec9/ AIRS ID Number: J Z3 /A /X05 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Enright Production Facility Site Location Site Location: SWSE Section 18 T4N R68W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Contact Person: Catie Nelson Phone Number: (720) 354-4579 E-Mail Address2: cnelson@extractionog.com • I Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 352503 COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I AV Krwlth& row, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action O NEW permit OR newly-reported emission source Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 O Change permit limit O Transfer of ownership' ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and,purpose: Condensate loading into tanker trucks Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 10/25/2018 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes 0 No emissions? Does this source load gasoline into transport vehicles? O Yes 0 No Is this source located at an oil and gas exploration and production site? 0 Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual O Yes 0 No average? Does this source splash fill less than 6750 bbl of condensate per year? ❑ Yes El No Does this source submerge fill less than 16308 bbl of condensate per year? O Yes 0 No COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN- Revision 7/2018 2 I Av HUM&E`�"�"` K��„h�a�,�a ' e Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 4 - Process Equipment Information Product Loaded: Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 71 131 bbl/year Actual Volume Loaded: 59 276 bbl/year This product is loaded from tanks at this facility into: tank trucks (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of GO F �.6 bulk liquid loading: V True Vapor Pressure: Psia®60 °F Molecular weight of 65 lb/lb-mol 5.77 displaced vapors: V If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested timit(s)should consider future process growth. COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I A-'°'°_'�"`^`°e,,c �i(eailhb FrulrownCnl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.307193, -105.04486 ECD —20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) El Upward O Downward ❑ Upward with obstructing raincap o Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): TBD ❑Other(describe): • Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. o Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: VOC/HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model:TBD 0 Combustion Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: >98 % Minimum Temperature: TBD -F Waste Gas Heat Content: 2,452 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: COLORADO HH i. :oft ti?, Form APCD-208- Hydrocarbon Liquid Loading APEN- Revision 7/2018 4 e� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SOX NO. CO VOC ECDs 95 HAPs ECDs 95 Other: O Using State Emission Factors (Required for GP07) V0C Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NOx 0.068 Ib/MMBtu AP-42 0.01 0.01 CO 0.31 lb/MMBtu AP-42 0.06 0.07 VOC 0.227 lb/bbl AP-42 6.72 0.34 8.06 - 0.40 - Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Number Basis Mf g.,etc.) (pounds/year) (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.004 lb/bbl AP-42/Eng.Est. 240 - 12 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. COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 7/2018 5 I �. ° l. "=�" Permit Number: AIRS ID Number: ! / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. zo i zo- Signature of Legally Authorized P))leris��/on (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name(print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) 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 For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd p COLORADO Form APCD-2O8-Hydrocarbon Liquid Loading APEN Revision 7/2018 6 I �. I "M;J Hello