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Home My WebLink About20181772.tiffCOLORADO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 75$ Greeley, CO 80632 May 29, 2018 Dear Sir or Madam: RECEIVED JUN 01 2018 WELD COUNTY COMMISSIONERS On May 31, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil >:t Gas, Inc. - Burroughs 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 it Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 0lo-►1-18 4300 Cherry Creek Drive S. John W. Hickenlooper, Governor cc: PL (MtsktrP), HL(2T), pWCERotoI5K) �. , Denver, CO 80246-1530 P 303-692-cw0 www.colorado.gov/cdphe Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer 2018-1772 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil a Gas, Inc. - Burroughs Production Facility - Weld County Notice Period Begins: May 31, 2018 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Extraction Oil a Gas, Inc. Facility: Burroughs Production Facility Well Production Facility NESE of Section 14, Township 7N, Range 65W Weld County The proposed project or activity is as follows: The operator is requesting permit coverage for the following sources at a new synthetic minor oil and gas well production facility located in the ozone non -attainment area: (i) Low pressure gas venting from six (6) three-phase, high -low pressure (HLP) separators, (ii) low pressure gas venting from one (1) vapor recovery tower (VRT) and one (1) gas buster, (iii) condensate loadout, (iv) eight (8) 400 barrel condensate storage vessels, and (v) two (2) 400 barrel produced water storage vessels. 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 17WE1076, 17WE1077, 18WE0357, 18WE0358, and 18WE0359 have been filed with the Weld County Clerk's office. A copy of the draft permits and the Division's analyses 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. Any such comment must be submitted in writing to the following addressee: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us ftAP Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package It: Received Date: Review Start Date: tarrison Slaughter .^'. 370103 10/10/2017 2/15/2018 Section 01 - Facility Information Company Name: County AIRS ID: 123 Plant AIRS ID: 9F59 = Facility Name: Burroughs Production Facility Physical Address/Locatio NESE quadrant of Section 14, Township 7N, Range 65W, in Weld County, Colorado Type of Facility: Exploratio0,& Production Well Pad What industry segment? Oiil-&Natural Gas Prexiuctton & Pracessinj Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ®,on Monoxide (Co) Extraction Oil &.Gad. Inc. Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NESE 14 7N 65 mute Matter (PM) Ene (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit B Issuance N Self Cert Required? Action Engineering Remarks 002 SepafatorVeviting Produced, Gas Venting Yes 17WE1076 1 Yes PeInitial. Issuance Section 03 - Description of Project Extraction (Extraction) pplication requesting permit coverage far lowpressure sep p - venting at a new,synthetic oil and gas well'. arat r g production facility. This source is APEN.required quired because uncontrolled actual VOC emissions are greater than 1 tpy (Colorado Regulation -3 Part A Section II.B.3.a), Additionally, this source is permit required because uncontrolled -actual VOC emissions from all APEN required sources at this facility ggeaterthan 2 tpy (Colorado Regulation Part B Section Ii.D,2.a). This permit will require public comment because the operator is requestingnew synthetic minor limits to avoid other requirements. Section 04- Public Comment Requirements 3s If yes, why? RequesCingSyntheticMlnor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No:; Is this stationary source a major source? If yes, explain what programs and which pollutants herr SO2 NOx Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.S PM1O TSP HAPs J No CO J VOC PM2.5 PM10 TSP ❑ ❑J HAPs ❑ ❑ Separator Venting Emissions Inventory Section 01-AdmimstraeM Information 'Facility Allis ID: 52108002- Eouhammd Description Detain ty Conrmlledbyan Emission Control Device Demnption: Gas meMr Primary Emissions. Seal rotor Actual Throughput Requested Permit Limit Throughput Plant Section 03 -Processing Rate informations Emission Estimates 453 MMsci per year 6d: MMscf per year Patent 1 to Emit IPTE) Throughput= 6.8 MMscf per year Process [patrol (Recycling) Equipped with a VRM Is VRU Proems equipment • Poin // Uncontrolled and controlled emissions used to establish requested pefmit Omits are based onV/26 when Um VRU is bypassed (i.e. waste gas volume Nat is routed to the flare) Secondary Emsdom -Combustion Oevice(s) for Air PalluMon Control ...for Gas Heating Value: Volume of waste gas emitted per eel of liquids throughput Section. -Emissions Factors& Methodologies cf/bbl alp2on A gas sample we, obm,ned from Nor.outlet of Ile low,:pr urn ode at he 1L 08/08/20131M1e sa 8606 Fand2 64.3 mepemvaiV. Pto26.4 v919,919401v93 run based 411.419317 . 4.115159 Ito/2860773 11 rates from dm low ar12818pa 4802 he lb/hi-rates and separa forges fl Angvalue were obtained front the P341axsmfilmdom The vent mad of Me sepaamrvaste ga0,0222,44 basedob enenglneemlg estimate. The" - I6, 4344 430 eftare contained 1he 1031 unsfmmm..4007 089 44 nthatleere seat. esmbll4M1pecmrttri emissions. Thee Doan 1359 mom III tlemm0 ates below tadtlorcl metlmdolvlgdaNns Ise vre lmm52ixoure These values andcalculationsare cemaluMtl in this adahs mr mmparativl pumoses, erse athe tltsc2sslvn tdmparmg the mz is of the Lwaadalgs(sme. tlz n efuahloe bebw. " Displacement Equation EX=Ct•MW•105/C Vapor Volumetric Flowrate MW MMs4f/day ...222390 Ito/0-3141 Hydrogen Sulfide cos 92 25 78 thane eMane pro e isolvmne n-bubne isopentane 120620 9.23 30 540 cyclopenane it -Hexane 444)0haane Other haanes he9565 meth...hexane 22YTMP 58 4:44 626 Toluene Ethylbenzene 1-]5 C8e Heavies 280 Total vac Stl]304 1334.10 Emission Factors Pollutant Separator Venting Uncontnelled ntrolled (Ito/MMscf) (0/MMscf) (255312929hpad) (Gas Throughput) Emission FactorsouR MSC 13390.9989 66/.Oa99 1.4396 0,8241 0.0560 Toluene 2661. 17481.5 1.1191 Hhylhemene Xyle e mNmmne 229 TMP 115.8190 5.7907 0.0090 Emission Factor Source Pollutant Prima Uncontrolled (Ib/MMBW) Ito/MMscf (Waste Heat combusted) Control Device Uncontrolled (0506812272801) 0.800 PM2,5 5 co 0.3100 397.277 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Acgtal Emb ions Uncontrolled Controlled Cons/year( Cons/year) Requested Permit Limits Uncontrolled Controlled (inns/yea/ (tons/year( PM30 PM25 50e NOa CO 0.00 0.00 0.00 0,00 0.00 0,00 0,00 0.00 0.00 000 0.30 0.20 0.20 0.2963 0.29. 1.35 0:89 0.89 1535 L35 Hazardous Air Pollutants Potential to Emit Uncontrolled (01/year) Actual Emissions Uncontrolled Controlled 69/yearl pbyreerl Requested PermitUmits Uncontrolled Controlled 11101612,1 111643ar) Benzene Toluene ENrylbemene Xylene nHeXane 224 TMP ]9456 126.38 6.4 1945E 9.23 1 77 .61 5.02 0.25 _ _ _ 26.63 12.52 0.88 26,63 133 287.54 519.. 25.98 282.x1 39.38 0.00 0.00 0.00 0.. 0.00 12689226-02P08881131310833822510451$ Regulation 3, Parts A, B Regulation ',Section %811.8, Regulation 2, Section %VII.9.2e (see 0egulatnryappiicabillry worksheet for detailed analysts) 401,144 requires a Kra, Source is zub(e3 to Regulation 7,515520 4811.0.2, The ...device for this separator 8 net subject to Regulation 2, Section 0811,8.2.5 Displacement Equation EA=O• MW• Xc/C MW 22.2819/Ito-cool weight% Helium coo 92 methane ethane propane Isobutane mbutane isopentane 0.63 .74 20.55 14 45 092 0.05 0I Dos 0:25 cyclopemmne n -Hexane dohexane other hexanes hepmnn meNYlcycloheeane 224-TMP Benzene Toluene Ethylbenzene Xylenes ®a Heavies a. o. 0.05 a. 000 T4ml VOC Wt. 005 CO 22.73 Fators SePam.r Ve Uncontrolktl Control Ito/MMscf) (Ib/MMscf) 557 9Benz n 1 e 268053 1.49.031 1767 IyinnIxmerc e 41150 0205: Emission Fedor Source D.. P06.00 Potential. Emit Uncontrolled (tons/year) Ac.al m Uncontrolled Controlled (tons/rear) (mns/Yea1) Requested Permit Limits Uncontrolled Controlled (.n2/7.511 )tons/year) PM10 SOa NOx VOC CO 0.60 0.30 0.00 0.00 0.00 _ _ 0.0_0 0.00 0.00 OM DAD 0.00 0.00 0.00 0.00 0.00 0.. 0:20 0.20 0. 0.30 1.35 0,89 0.09 1.35 1,35 Hazardous Mr Pollutants P ,[ Potential to Em Uncontrolled (Ins/year) o Actual m 204130rdk0 613614led (Ibs/year) (fns/1ea0) Requested Permit Limits Uncontrolled Controlled (112/0527) (16s/year) Benzene Toluene Etirylbemem Xylene mHegane 224 TIM 1..9 129.2 6.5 195,9 46 119.0 29.1 288 185 25.0 1.9 287.5 519.6 76.0 282,5 39.4 0.0 0.0 0.0 0.0 00 2of 4 01/PA1201T17W482788P1.xbm Separator Venting Emissions Inventory Section W - InNal and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on fimplemm.o. emissions) F'ya lhis sample should represent the gas outlet of the equipment red under this Allis 10, nd should have been collected whhinn< facilityh sn tbeen modified(e.g., no new wells brought on-liel,Oen it maybe appropriate muse an older site -specific sample� of the applicatmn received date. However, If the 11 no, the permit wilt contain an "Initial Testing Requirement" to collect a site -specific 0555505p105000 the equipment heimg permitted and conduc[an ems5105 factor analysis to demonstrate that the emission factors are less than a equal to the emissions tors stahlished with this appikatmn. Are facility -wide permitted emissions of VOC greater than or equal to 90 tom per year? daag..sa'op Oyes, the permit will contain: -An "Initial Testlsg Nequlremants to collect site-spacifc gas sample from the equipment being permMed and conduct an emission factor analyse to demonstrate that the emission factors are Iss than or equal to the emissions factors atabAshed with this application. "Periodic Teadsge.qubemem" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analyse to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Mg the operator have a meter installed and opentienal upon startup oft. point? Yes dna, the permits). contain a condition that requires the operator to calculate gas throughput using the liquid throughput until 005500e meters installed and operational (not to issued= days). This condition will use the 'Volume of waste gas emitted per BBL of lisp. throughput" (scf/IMS value in section 03. Wes the company request a controldev're efficiency greater than 9533 for a flare or combustion device? .' .N lIyes, Me permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on Inlet and outlet concentration sampling Sortion Ong Technical nal, s Notes Tm emotions awn sec -ambers ere caicuated dsrng this clisp4,-,naendequatipr, from tim 4 F sawnlnvenmry p,00005errtaro,am publications Volt, all, Chap 10- Displacement genetion(1o43I Ifs =Q. SSW s%a![}: Th scocuWton methdo.ogy.0110 dto the refit, bon D1of and isintend to housed for com ave0urpocs- Theoperator calculated tressar0 us, aProfiles smuaeonosed onzSe s,c ,analyesobtnined from tire low peesums'�oF the IP separ,torson08108117. The opatator used the mole 3 vaiues ham the gas analysts to spea00 a gas -stream uitn Mau srrnisla Mat TheRrigalausirimlation was Men toed to determine the Itth rates of<oh component in the gas stream based on standard volunsotrin aoseram of OMM f/day, TI-y..1,1gemi.sions from calculation toohodlogl are ae0hie 1R Section OS grove, The reossoins resulting horn thedupslightly more non 10 an One tr.1 pore, m from thei,olvlaK srmulation However, the df(eren.c trtOle awesssmall end,h.o bewmderednegl g'hle. Assresult, .was derermr.-0he values estima[edus rag the PmM1Sx ornsgatninwere acceprahle for pemrnngpurpoars xodIng to III, °pct., flow Meter W35.,Illed at. arJtv10measu< entirety of the mw preessire sa ented from e-1,1the viz low pressure ssparatoss- Ths 0,1,01 ,, metroseted downstream of Me mpor sec yu,eci mmores, low F esas anorcu to the saesype e flow -mete -rig.. Lsedto measure topreszure separatorys M.x rs routed to theenclosed flare durng_(l miens Pa.:.ou th Sete meter location. or viii net need to trail VIM downmccvrc.rrcol rnonu M Itori MOW data to dernonstredeomosnce kH, prmtzlr5 the flov, m:asredblte Row mete Ilbe. _encfoE ,m,;conpl 6. ne,therinit,II teethed 220pantytests wme inctudeun.ie pnmc tas.ansc in,°nse.,st go,cd t@do weedy viS...h4ceatissinitsohessenes the operating ensimainienasce piers ntpI tenet sesa,,rin,ss Isis ob gsningi,ti opera egpved Berths sh1 ifi ,,,,Mnrtimmed,s ly and vanduct ',pads or conshietn to real method 02 meat ty test In theevent.=hiepm onn sir neiselesed through dm method 00, 1/casein. is reqiiiredm rem_tl _..I, fonds,rnal, 7.u. ethd ent if repairs 0nautb cancluttedimr,I.43.,y Sincefirs sa rnorerol,r,con going cimpilrrte demamtratlore[hideerme rur[hed 2Y,.h .dcal cmpt needemanstraono not necessaiyn the perm_. h di and subseq ntrequry cn10 01sdkomisslons are observed a suffice-otos-ageing compliance doon so periodic metimB 2E op.,arytspngi Iregnred ,the perm.[ Me pel.;tantsesed tedwithihs source meVCC and n-Hcnane. As n result, em1ssmn hctorsa a .uoed,sthese n the notes to pc,. holder sects,, of thepermlt. educed the regaester, throughout train 7l MNtscf/year re 8 sisseh yr.nd a coral Mmughputffdm4.S suit aninlCar[mpilance testa,. be required to confirm the used to?.tlmatesI s f siot gooseryative. _ O, h aCOntent ed Le Ca1001ates ob., v Ih heatramoF t duced1assa p ml4NIOi 11 }h II, 0drd: lumenk produ e 1011,, L aa:.thnt LI 7.t/MMietl (128,113,IIll,,,3;W If/InM.tfllir) 61:5 MMseu)MMxt Pr..dedw Mad redline to review. pribtP.rb'e s Section 09- Inventorv5CC Coding and Emissions Facto, AIRS002 PoImg Process. SCC Code 01 3-10-001-80 Flares for wed bath den _rr .,rduprr- Pollutont PAILS Na k VOC z0 iene ToluEthylbenzene Xylene olimmne 224 SUP Uncontrolled Emissions factor 0.03 0.00 37.14 13341.00 97,23 33.33 17.43 113 3.32 115.1 000 Control 96 SS SS Units b/MMSCF b/MMSCF b/MMSCF b/MMSCF b/MMSCF b/MMSCF biltriVISCS b/MMSCF h/MM5CF b/MMSCF 3of4 K:\PA 2017\ 17WE1o76.CP1.ssm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN nd Permit Requrements ',mace 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 10TPY or CO emissions greater than OOTPY (Regulation 3, Part B, Section 1.0.3)? tutu 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 2. Ara total facility uncontrolled VOC emissions from the greater than 2 TPY, Not greater than 5 TPA or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? (Source requites a Permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, orrecompleted on or after August 1,20107 (source is sublectte Reguladon'7, Suction XVIt.B.2, Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional 3ectlonl a. Is this separator controlled by a back-up or alternate combustion device (I.e., not the primary control device) that is not enclosed? ITfro motel device fur 5bb separator is not subject., Regulation 7, Section XVII. i.2.e Section XVII.B.2.e — Ahemative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, Os implementing regulations, and Air Qua/Ay Contro/ Commission reguations. This document is not a rule or regulation, and the analysis d contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or subotalde 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 AG„ 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 es °recommend," "may," °should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe confroldng requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, boo' this document does not establish legally binding requirements in and of itself Ye4 'Source Requires an APES. Go to the neat question Ye%..... : Source Requires a permit Permit number: Date issued: Issued to: ADO ntr Heal CONSTRUCTION PERMIT 17WE1076 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Burroughs Production Facility 123/9F59 NESE SEC 14 T7N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Produced Gas Venting 002 Low pressure gas vented from six (6) three- phase, High -Low Pressure (HLP) separators. Low pressure gas is routed to and controlled by an enclosed flare during vapor recovery unit (VRU) downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the COLORADO Air Pollution Control Division Capert,kr t .a h. a9 Heti . e Environment Page 1 of 8 ditions. F mit. A self s permit ific._:. e complia and guida online Par 180 da to self -c rado. • o ;ult in revo y ',t pliance a acific/cd•he/air on of the quired by rmit-self- 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.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Produced Gas Venting 002 --- --- 2.3 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Produced Gas Venting 002 Emissions from the low pressure separators are routed to an enclosed flare during vapor recovery unit (VRU) downtime VOC and HAP COLORADO Air Pollution Control Division Deparemint cx Puiiihe Yiz tri & Environment Page 2 of 8 8. ""'"" all bto taxi e -s as listed onthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Produced Gas Venting OO2 Natural Gas Venting 6.8 MMSCF The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of low- pressure natural gas vented from the separator(s) and routed to the enclosed flare using a continuous operational flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 'COLORADO Air Pollution Control. Division pert/ or Pubtr tier,}:n Er Environment Page 3 of 8 14. this M) plia on a are sub t to D ection III. eroro ecord kee going b na with t val prior all folio t approv equire m . lem u t recent o y e Division, is of this permit. ation. (Regulatio ating and order to visions to umber 3, COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from the low pressure separators in order to verify the VOC and n -hexane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO),) in ozone nonattainment areas emitting less than 100 tons of VOC or 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 COLORADO Air Pollution Control Division Dembiem ;it }'ubbt t 4Ed n s {';1U`orme,C Page 4 of 8 'ed; or expires. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Mr Pollution Control Division "sAyz?�r: €nt of Pub i HeuY.h , t^yironnert Page 5 of 8 Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. Permit for low pressure separator venting at a synthetic minor oil and gas well production facility. =COLORADO Air Pollution Control Division Page 6 of 8 Notes t 1) The fee (Regulation Number 3, Part A, Section VI.B.) permit iss ees for th ssued. time fo s pe it. An invo for these lder sh •ay the invoice n 30 days evocation ermit. 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) Produced Gas Venting 002 Benzene 71432 195 10 Toluene 108883 119 6 Ethylbenzene 100414 8 1 Xylenes 1330207 27 2 n -Hexane 110543 788 40 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source VOC 13,341 667.05 ProMax 110543 n -Hexane 115.81 5.79 ProMax Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. The emission factors listed above are based on a ProMax simulation that utilizes a site specific low pressure separator gas sample obtained on 08/08/2017. The sample temperature and pressure are 86°F and 263 psi respectively. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to (COLORADO Air Pollution Control Division rvpamor.rz of ablic Heoith u E}irormea Page 7 of 8 the ass at 7) T determin questions r assifie expirati specific r each emi ins point date call Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, and n -Hexane NANSR Synthetic Minor Source of: VOC and NOx PSD True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart• Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division ;� i�{;ate u ETrR'J1'Y?i�t:E Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Harrison: Slaughter -- 370103 10/10/2017" 1/26/2018 Section 01 - Facility Information Company Name: County AIRS ID: 123 Plant AIRS ID: 9F59 Facility Name: Burroughs Production Facility_ Physical Address/Locatio NESE quadrant of Section 14, Township 7N, Range 65W, in Weld County, Colorado Type of Facility: Exploration & productaphStVell Pad What industry segment? 0 -if & tea ural'Gas P oduction &Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ,on Monoxide (CO) Pa iculate Matter (PM) ve (NOx & VOC) ion Oil EL Gas, Inc. Weld Quadrant Section Township Range NESE 14; 65 Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 003 SeparatarP oting VRT Venting Yes 17WE1077 1 ° Yes Permit initial Issuance Section 03 - Description of Project isILH3.a):'Additionally, thissource 't db (Colorado Regulation Part B Section This permit will require public comment because the operator is requesting new synthetic minor limits to avoid other requirements. Extraction Oil &Gas Inc. (Extraction) submitted an application requesting permit coverage for vapor recovery tower(VRT) and gas buster venting at a synthetic minor oil and gas well production facility. This source is APEN'required because uncontrolled actual VOC emissions are greater than 1 tpy (Colorado Regulation 3 Part ASec tion perm) require ecause uncontrolled actual VOC emissions firom all APEN required sources at this facility are greater than 2 tpy ILB.2.a). Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting syntheticMlnorPe Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? <No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants here: SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No NOx CO VOC ❑ ❑ PM2.5 PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory Emission Factors Section 01 -Administrative Information �Farl A63ID. Section 02-Eaulymem Description 0eblls Detailed Emissions Unit Description Emission Control Device Oescnptbm limited Process Parameter sm meter 2✓% Yesimemr3¢m *K. '114 Session 03- Processing Pate InMenatlon for Emissions Estimates Primaryfmrssiom XparaNr Actual Throughput 2033, MMscf peryea q ted Pt Lmrt TM1roughpu[ ,.-: 2,3MMscf per,Poon1€INEmerroitIPTEIThroughput= 2.3 MMscf per Ka Process Conbol(Hess aingl Equipped with a VRU: VRU Moor's equipment Uncontrolled and controlled 0211000 used to esdblhh requested penny! limits are based only on when Me VRU 6 bypassed / 8 w. fool Btu/cal scf/bbl They ..ndgasb s(6) ,h a rs.Apm d qsame. out °Mom loo Emraa31712AO b1_ 012223 sad mttius mpiam /his r.. Toe.reques.e7 perm ted.. s'' 0102 Mscf/day I2/16-021 h I2/hrm a; vap2 Separator Veer115 Unrormvlkd (10/6AMscy) (Gas Throu BMM Controlled (12/MMsct) (Gas Throughput( Emission Factor Source VOC 897299965 261.8935 372.1.2 27.6133 972912 1422.3365 146.4660 4486.2998 13.0987 13.6411 Benzene Toluene Xylem ellemne 224TMP 4.8746 71.1168 Pollutant Pammy Control Ui0<Mro bulled (I0/MM603) b/MMMS (Waste Heat combos-at((GasThrou5M1pN) 0.000 0.000 0000 167,109 761.822 PM3.5 Hoz co Seedon OS- Emissions Inventory Emission Factor Source [ PollutantsUncontrolled Potential. Emit (tons/year) AcnalEmhsionz Uncontrolled Controlled Irons/year) (tons/year) Permi Request.Request.120112Criteria Uncontrolled Controlled (tons/year) Imps/year) PM26 SOa NOa VIX CO 0.00 0.00 0,00 0. W 000 0,00 0.00 0.00 0, W 0.12 0.12 010 0.19 103:18 66.44 3.32 200,10 2.13 4 0.36 0.88 0.88 Hazardous Air Pollutants Potential to Emit U (lbs/year) trolled602.35 teal Emosionz trolled Con[mlled 001114022,1 11bs/Kerl Pequested Permit Timm Umontrolkd Controlled Ilbs/yearl Ilbyrearl Benzene Toluene Ethylbenzene6381 %Stone n-Heune 224 TMP 85],:19 552.>D 2].61 85].49 42.8] 40.80 1443] 7.22 224:2311.21 2106.31 105.32 1635] 334sI 21490 10.ea m6.8] 1694 Section 06 - Regulatory Summary Analvsi Regulation 3, Pam A, Regulation ',Section %VII.9 e321322n 7, Secibn 19018.2.2 (See regulatory applicability w,rloheet for detailed analysis) Sours requires a permit 6022203211200783122302,332232001132,2is The centre! device }orthls separator is not suhl0ct to Regulation], Section 21/11.6.2.6 routed to the ]are! 2014 %:\PA\2017\1TV/E1o77.CPlalsm Separator Venting Emissions Inventory Section 0]- Mittel and Periodic Sampling aed Testing Requirements Using Gas Throughput. Monlmr Compliance Does Me company use site specific emission factors based on a 079010011 to estimate emissions? This ample should represent the gas outlet of the equipment covered under this AIRS ID, 00 should have been collected within one yearof the application received dal. However, if the facility has not been modified (e.g, no new wells brought on lnel, then it may ppropate m use an older site -specific sample. tine, the permit will contain an "Initial Testing Requirement" to collect site -specific gas sample from the equipment beingpennitted and conduct an emission hcmr analysis to demonstrate that the emsson factors are less than or equal to the emissuns factors es5blished with Misapplication. Am fcility-wide permitted emissions of VOC greater than or equal to 90 tons peryeari 't:! L Ifyea, the permit cast con,. An "Initial Testing Requhemertg' to collet e-specificgas sample from tile equipment being coed and conduct an emssio,0facmr analysis to demonstrate Mat the emission factors are less than or equal tithe emissions factors CstabMhed with thls application. m "Period.Teating Requirem. to collect a site -speak gas ample from the equipment being permitted and conduct anrnission factor analyse to demonstrate Mat the emission factors are less than or equal to the emissions factors established with the application on an annual basis. Win Me operator have a meter in.. and operational upon startup of this point] yes If no, Me permit will contain a condition that requires the operator to miculate gas throughput using the liquid throughput until the meter is Installed and operational (norm earned 1130 days). This conditon will use the"Volume of waste gas emittedper BBL of liquids throughput"(sof/bbl).10 in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? @Ma urw,y. :; yes, Me permit will con. and in. compliance testcondhlon to demonstrate the destruction efficiency of the combcoedn device e based on inlet and outlet concentration sampling Section 09- Technical Analysis Notes �, g 1 d yh tip nN h F p mm u0. f CHp I fa... Fq p(.431 (Rz O.M Cland-gazmplepbtalh dhomihc outleG:oNM v we/gasbuzM.'fnthk nsta z, Me op mtorddnot 6avi eaflNONz;ample fromthe ouH@to t eV FINN. baste As esuft, Me op iedalo p religlTdsimo b'sdfromthe ectry upsaeano"M npha ns tram the VRT sod oss tooter. xb/r .,each compee simulation .t vnos6nd,rd you e.t flow ate Q.M@ R gas steam were a qd to IONove op e ernosron factors for theiVRT and sass,? 1.,/MMsnf}iThse emosson hoc os ere then Ib/the rsoio.teol torotighoutto determine -the pem e em=<oo As scu.vG`a ,[4.V roastiu calculated rapt... zings w ea sitespeofic..,00son,..o to sum ratetnot e emosomfactorsore.les than or equal to 4o ons. fat, sestablohed , Nog mat opo..ator, flow root, wosinstalleclatthis roc., yof the,ss n very ants VNUT 110,5 111111 NI. press low 'pressure and rnu -rho tens no,roth ,,s os Ma.s er locaro.Me p trazk VRU dawncl e cad,n eol*nclgsnM now m@ter todetsoossoore thc porno Ploflow r by -ti, ha sof f n Banco, process Igo, ATh oper,tori d tithe flow:.e nand, I ?this n. 5, Net herannih rodr method 22 opacity testswerencledwln the y tbecauzebeb e0:zo do ecriy .':ne- ,atAn x. plbn.n tvrsrtl:eemssoz boerved,ihe. pu operator Is reeur o- .net:nut, .n,a,aw,y and condue p saf conduct formal nosthod 22 opacity testn,,s sOffemsons ore da,reeOthuohmcthoo 22, opsratorsre re Col etl atlymnocv'C r shut ndoe eq P p t .odusterstimrsetliotsly Since aB Js a more robust b a minpilancedemons..unlhanz.nr—Ilme method 22thv ininalcornpltance durionztration n/i per rAddnipnelly Me'i 2.3MM:d/v Me ft II e3linPro,.1,1 updated to -reflect Qnren usetlto<aku/{esecondary emsNNNN shheat ra, of to ORT Oas, gas stream OLO,Biv(m10 HeatConten{MM 1Msefl (532]SMMRtu/hrl/10:g0 6z7U2i Mlisc;/n) Sd9h 0ti/,i1 Mzcr d ra.iew ea don,.M p oeprovided on updated facIlitywole flow diagram: Thk diagram oullos1,0slia are cooedO themanner as ih !Yard the -Holy o accounted faros. ti' flow meter drat es totales-ten SeNon 09- Inventory See Coding and Emissions Fa<mrs AIR 003 Pa dA Process g KC Code 01 2,0401-0 Flares n According ni h_ theeper Uncontrolled Emissions Po ttmn[ eaaor PNI10 0.00 VOS PS@ 0.00 NR 167.11 VOC 89]26.00 CO Benzene 261,. Toluene 3)2.02 EthyVenzene 2].61 Xylem 9289 n-Nssane 022.3e 724 TMP IG6.f] Control% 0 9s 95 95 95 95 gs 95 U. NMS. btag MOTE b/MMSCF NASKY ININISCF b/MM b/MMSOF /MALOOF /nnmscF b/000500 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B- OPEN and Permit Requirements ruurca 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 Il.O.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10TPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.0.31? 'You have indicated than source is in Oho Noh.Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section lI 0.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 5TPY (Regulation 3, Part B, Section 11.0.2)7 ISource requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 20147 I5eurca is suhfect tc Rp motion 7, Section x011.8.2, 0 Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Sectionl a. Is this separator controlled by a backup or alternate combustion device (i.e., not the primary control device) that Is not enclosed? IThe control devirx for thesepereter is not subo,i to Regulation 7, Section nuiuu.2.t SectionXVl1.8.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply toe particular situation based upon the individual facts and circumstances. This document does not change or subsfdhie for any law, regulation, or any other legally binding requirement and is not lege/4/ enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, end Air Quality Control Commission regulations, the language Mitre statute orregulation 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" end "required" are intended to describe controlling requirements under the terms of the Clean Air Act end Air Quality Control Commission regulations, bud this document does not establish 10001(1 binding requirements in and of itself S urce Requires an OPEN. Go to the next question Source Requires a permit tdo, /„.; V9 The control device for this separators not subject to Regulation 7, Section XVII.B.2.e CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1077 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Burroughs Production Facility 123/9F59 NESE SEC 14 T7N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT Venting 003 One (1) vapor recovery tower (VRT) and one (1) gas buster. Low pressure gas is routed to and controlled by an enclosed flare during vapor recovery unit (VRU) downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the COLORADO 1 Air elution Control Division "_aY..p;rtme7t :5i WEydth Envird,ment Page 1 of 8 ditions. F mit. A self s permit ific. .; e complia n 180 day and guida to self -c online rado.•o Pa Section ult in revo y •` pliance a acific/cd.he/air on of the quired by rmit-self- 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO VRT Venting 003 --- --- 5.2 --- Point ote: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT Venting 003 Emissions from the VRT and gas buster are routed to an enclosed flare during vapor recovery unit (VRU) downtime VOC and HAP COLORADO Air Pollution Control Division epartmenf Pub(ie i ecn.'v Er.,4 xne^t Page 2 of 8 8. be li ctual the D, II.A.4.) Process Limits followi tes sh ate `=: s listed be . Monthly owner or operat 4 nd made umber 3, ection Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT Venting 003 Natural Gas Venting 2.3 MMSCF The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the vapor recovery tower (VRT) and gas buster that is routed to the enclosed flare using a continuous operational flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (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 COLORADO Mr Pollution Control Division DL,.+3 i"zrt;•z ci 3th ti:-lnJrortrrit Page 3 of 8 to implem m ;• (Regulatio ; umber 3, ni` is esting Requiremens 15. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from the VRT and gas buster in order to verify the VOC, benzene, toluene, n -hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II .C. ) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. COLORADO Air Pollution Control Division Page 4 of 8 18. requirem s of , �� , ` gulation N - b- Part D s • t at such ti that any or m` i . becomes .= ionary so a or ajor modifi ion solely axati an ?forceabl imitati• at was ablished after Au t 7, 1980, of th-> '` urce o •dific.: on to othe e emi • •ollutant such as .`estriction rs of operati • - i atio r , Part i, - • n GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer COLORADO Air Pollution Control. Division P b4 feeitn & Er:r"vorvnert Page 5 of 8 This I COLORADO Air Pollution Control Division fepotrr_rt of 3Yub€ e Heah E-ii,nrsnert cnp ssued to ction £t Gas, Inc. ermit for '' an• gas .uster venting a a synthetic minor oil and gas well production facility. Page 6 of 8 Notes t 1) The fee permit iss ees for th... time fo ''_'s p- it. An invo. ', for these slued.. e'e permi Ider sh. gay the invoice n 30 days e inv.' ure invoi -. evocation ermit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) VRT Venting 003 Benzene 71432 603 31 Toluene 108883 858 43 Ethylbenzene 100414 64 4 Xylenes 1330207 225 12 n -Hexane 110543 3,272 164 2,2,4- Trimethylpentane 540841 337 17 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source V0C 89,726 4,486.3 ProMax 71432 Benzene 261.89 13.09 ProMax 108883 Toluene 372.82 18.64 ProMax 110543 n -Hexane 1,422.34 71.12 ProMax 540841 2'2'4 Trimethylpentane 146.47 7.32 ProMax Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. 'COLORADO Air Pollution Control Division "t)epol.l rIt C,.t Pu64i_ 3 fe,ith. & Envno, 1e,tt Page 7 of 8 liste •ove - eased on a P ' ulation tha ihze site specific pressure ple a om the out HLP sepa : 08/08/2017 he sample re an essu e 100°F a F 43 psi r tively. 6) I . C R .. -114. lluta 'o• .' - (APEN) ass• th this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO and n -Hexane NANSR Synthetic Minor Source of: VOC and NOx PSD True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Department or Vublif,f }ieei i, 6 L* rirorrner:t Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Harrison Slaughter 370108 3/30/2028 4/24/2"018 Section 01- Facility Information Company Name: Extraction Oil"& Gas., Inc. County AIRS ID: 123 Plant AIRS ID: 9x-59 Facility Name: Burroughs Production Facility Physical Address/Locatio NESE quadrant of Section 14, Township 7N, Range 65W, in Weld County, Colorado Type of Facility: Exploration & Production Welt Pad What industry segment? 06 & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? YeS If yes, for what pollutant? c❑a oon Monoxide (Co) PE iculate Matter (PM) E3ne (N0x & v0C) Weld Quadrant Section Township Range NESE • 14 7N 65 Section 02 - Emissions Units In Permit Application AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 007 Hydrocarbon Liquid"Load`ing'' Liquid Loading Yes 18WE0357 1 Yes Permit Initial Issuance Section 03 - Description of Project Extraction Oil & Gas Inc, (Extraction)'submitted an application requesting permit coverage for hydrocarbon loadoutat a new synthetic minor oil and gaswell production facility, This source is APEN required because uncontrolled: actual VOC emissions are greater than 1 tpy (Colorado - Regulation 3 Part A Section II„g',3.a), Additionally, €his"source-is permit required„ because uncontrolled actual VOC emissions from all APEN required sources at this -facility are greater than. 2 tpy (Colorado Regulation Part B Section 1I.17.2.4, The operator initially requested -0P07 coverage for this source. However, the operator requested to change', the GP07 to. traditional,permit coverage during review of the GP07.:-- This permit will require public commentbecause the operator is requesting new synthetic minor limits to avoid other requirements . and the change in VOC emissions as a result of the project are greaterthan 25 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Greater than 25 tons per year in 14 Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? No; If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes n Went Area Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NAN5R) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx J CO PM2.5 VOC PM10 TSP ❑ O HAPs ❑ ❑ Hydrocarbon Loadout Emissions Inventory Section 01- Administrative Information Facility Al Rs ID: 123 9F59 907 Plant Point Section 02 - Equipment Description' Details Detailed Emissions Unit Loadoutof'condensate'. Description: m storage vsels to tank Srl Emission Control Device Emissions from this source are controlled by an enclosed flare. Description: Is this loadout controlled? YOU Collection Efficiency: 100.0 Control Efficiency: 95. Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput = Potential to Emit (PTE) Volume Loaded = 95.00 Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 362,39.. Barrels (hbl) per year 434,782; Barrels (bbl) per year 434,782.: Barrels (bbl) per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? A Actual Volume Loaded While Emissions Controls Operating = 2,082 MMBTU per year 2,499 MMBTU per year 2,499 MMBTU per year The state default emissions factors may be used to estimate emissions. Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (Ib/bbl) 0b/bbl) (Volume Loaded) (Volume Loaded) 1.18E-02 2.05E-05 0.00E+00 0.00E+00 D OPEr00 1.80E-04 0.00E+00 Emission Factor Source VOC 2 Benzene Toluene 0E-04'. Ethylbenzene Xylene n -Hexane 224 TMP 3.60E-03 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/bbl) (waste heat combusted) (Volume Loaded) 0.00E+00 0.00E+00 0.00E+00 3.91E-04 1.78E-03 PM10 PM2.5 SOx 905 CO a 2 of 4 K:\PA\2018\ 18WE0357.CP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory - Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.07 0.07 0.08 0.08 51.30 42.75 2.14 51.30 2.57 0.39 0.32 0.32 0.39 0.39 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) - Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 178.26 148.55 7.43 178.26 8.91 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 . 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1565.22 1304.35 65.22 1565.22 78.26 0.00 0.00 0.00 0.00 0.00 Section 06 - Regulatory Summary An�sis Regulation 3, Parts A, B RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) Source requires a permit The loadout must operate with submerged fill and Ioadout emissions must be routed to Bare to satisfy RACT. Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes 1. In theoriginai application submitted for this feciiay, the operator_ requested G P07 coverage. for .h s oursource Duringrev,_l'v eie CP07, the operator decided to switch from GF07 totradrtonalper. operator submc-ed an updated OPEN tosupport this request, 4r, Ic the updated APEN the opoiator depressed.,_ requested throughput from529,389Ishii-year to 434,782 bbl/Year. COV age 2. 5nc,.: this mur_e is located in the osone nomattainment Laren, to no source is required satisfy PACT. Uncontrolled VOC err or e.rom. this source are =reater than 20.n, ,t a r.: uIt, ti= -our.s rcqu red control elotss ons using a flare and conduct loading ope at ons u inrsubrr eror d fill order to satisfy RAC fhe op. ,.tor ha ll d ceteo emissions from nixoRec by an enclosed flare and the ,Dolma sou c_ar_c operation is conducted using submerged `ill. 3. Sine ttie ,tc to detauS ern no , factors aro usea t0 calculate primary node s;.c0 nlcst t omissions tvo old typically be cat cola t_.[ as follows: () Volume (scf/ye< Ib/ton)/lMol ular Weighs (Ib/Ib mol)lf[370 sof non = (5.1.3042S -,/year) (200016/o.,?rh51a/f5mol)*(379scf/lb tool) .= 598,28,_cr/) () JSlntr the calcula Btu/so`the heat input is balculatec as follu1,.. s eo Input N4r,B,u/,e r = (S92.7.37 r/e )'(2,255 LI:.i/scf)*(1MMBtu/1,000000 Bt.- 1,349 itTVIf,u,`yeor. Usingf emission factorsforii0x:and CO, requested erniss,ris.avould: be calcufated at 0.05 Nty J ,d 0.21 toy CO. rn.,.ee„, f using the : bove desci iltedper m„ology, the operator obtained parameters from the lit u d loading stream III the Pi o ex ,, , Iei on to calculate flOg and CO e niss.,ns. l b' „a.arneters obtained fs:c P o'tn_,.and usedn the calculations a,_m`ollowO Vapor volumetric nowt 000272679viyscf/day,pt) Energy -Content:: 0.22 2-22 072ABtu/hr. These parameters were used to rt:emne the heat content of the gas as (17.28523.WW2 Btu/Ir)/((0002726/Ifi Iscf/day)/(24hrs/day)j 2510468MM8tu/MMscP Using the heat content in.conjunction with the annual: vapor volumetric flow `anc: AP -42 Chapter is emission factors, i equ bred l`. .. and. CO orIliSSi01, were calculated to be 0.08 toy and 0.39 tpy respec,vely. This result is more conservative can pared to the recommended methodology and is therefore acceptable for permitting rh y are Alow APEN reporting: threshoids. [Uncontrolled 000 (ton/yea:i}'[2000 vent me and a'de.ault heat content of 2,255 mfo r<t.cn along with AP -42 Chapter 13 S. Based on Lo p,.Ityda rcicdcdn the applicaton,the enclosed flare used to control emisscns from the loadoct operation also control emissions Irons the produced ✓_ter sto 6. The operator was provided a sin a draft permit and APEN redline to review prior to public comment -The operator ev ewed both documents and expressed they had: no comments; Section 09 - Inventory SCC Coding and Emissions Faders AIRS Point # 007 Process# SCC Code 01 4-06-00132 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NO0 9.30E-03 0 lb/1,000 gallons transferred VOC 5.62 95 1b/1,000 gallons transferred CO 4.24E-02 0 lb/1,000 gallons transferred Benzene 9.76E-03 95 lb/1,000 gallons transferred Toluene 0.00E+00 95 lb/1,000 gallons transferred Ethylbenzene 0.00E+00 95 lb/1,000 gallons transferred Xylene 0.00E+00 95 lb/1,000 gallons transferred n -Hexane 8.57E-02 95 lb/1,000 gallons transferred 224 IMP 0.00E+00 - 95 lb/1,000 gallons transferred 3 of 4 K:\PA\2018\18W E0357.CP1.xlsm Hydrocarbon Loadout Pel;ulatary Analysts Worksheet Colored...laden, Peres A end ADEN end Parra Imams it isiM,.,mMia.,men...me ATTAINMENT 1. Me uncontrolled meal emissions p PY IMpuletion 3. Part A, section nn.oi aH to maredaran eeb.don and productions. Mt,.pad) Megwadon 3. Pert l3, Section ll.o.t.IH 3. is loadmiocemtlon ...less Men 10.000 s lx3.MA of nude all per Mee an anima average.esi, a. a Me IMOLA Opel.. loadinciess tan 6,75D ['Meier mar of modem. sla rola. 5. is Me loadouroperedon MOIng less Men 16,338 Mis screamer condensate vle submersed lie procedure, E. "...Di, . VO0 emis I a 0 ...Man 10 TM era. emission, rea.r taMODI Pe Melon 3 Par. Jon eiciesaeliaMMENT 1. Me unconerolled emissions 'romans criteria polio.. Mem Mir individual source Man Pv tae Pert wn nln.I.eli to 1 le.R essdl elem.. Perte.5eaian 18,1.i1Pn3 mimosas. maMIDI of crude oil cmelav on en annual ammo brad, le Me loadoutoperatem loading less Man SY. bale pelMer iMi is S. Is Me loMoutoperaCon 104..11rIg MYI 16.308 1.15 aer ymr of =Menem vie misters. procedure, s. Are meal as ne an o v lonetraMilian 3i m me an , NOI purer Men 51?? 000 emissions 0. TP r then 5Y I5egubmn 3, Pan. Section 310.31? i. Rein Are unconuoeed 8033m.aons 00303 loeclout operation Dearer men in.v15egulaten3, Parr .,sectors lil,p.z,al'i Disclaimer TMs document assiva operators MP determining applimliklyof cartale regaireames of the Clean aired. its anplemenil!I regulations, and Air oaality Control Cammissbn regulation TOM damn,. Is not a Me mropulalbn, and the analysis ',contains may Rol apply Ms partbular MusDoc based upon the Dressiest facts and circumstances. DM document does not charge orsabslilule for any bw, rryulanee. of my olhar Wally hlndlrp remiremanl and ¢nd Mealy enr°meal. In the avant of any coNIM helms. the hnguage of this document and Me lane. ow el Pe Clean AU AG, its vnplemamrne raIulalbns. am/ Air Quality 34900amrv313( regulations.ma lar3uaDe orlhas0100orregrrNfmn cull wnrrrd. ma use al^sm.enda,Dri0uapesurin asrecommend, -rrey. 'shoutl,'ant roan:is'Needed to describe AP.CO infarpreta4ans and recommendations. Mandatory ternmoby such 'require, am Mended to describe controlling requires.. under lha terms o Ma Clean Air AG and Air Oualny Control Comutisbn reputations. hul this docurr ntdoes rot establish legally binning requirements m and o emit Go to rim nosequesCien Go to next poss.,' Go se nesmuestion Theimaaeutmmn opera. IMO SUbrilel.ed fill end mam,emissions must barmen! to control m aeMlyPACT. fnot dontreled.a Rein analysis Is required and proof. discussion Sisermna. CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0357 Issuance: 1 Extraction Oil &t Gas, Inc. Facility Name: Burroughs Production Facility Plant AIRS ID: 123/9F59 Physical Location: NESE SEC 14 T7N R65W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Liquid Loading 007 Loadout of condensate from storage vessels to tank trucks using submerged fill. Enclosed Flare 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/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) [COLORADO }}� Air Pollution Control Division ^.2pr rAmt fit. $A4t tc Hea, n & E°^.rtrar Atnt Page 1 of 8 3. This permit shall expire if th .caner opal+= .f the •. for w . h his per was issued: (i) does not commence cons ctio odi ati . or • erati • ` oft source wi in 18 months after either, the date of • . " ce of VV on "' +` * n pe dat- ' hich 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. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Liquid Loading 007 --- --- 2.6 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Liquid Loading 007 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits COLORADO Air Pollution Control Division "ep&rr-m+lt ut kg)€i Ne.a;n.n Er7ororr Page 2 of 8 Facility Equipment ID AIRS Point rotes ar• et Ann I Li Liquid Loading 007 Condensate Loaded 434,782 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Regulation Number 3, Part B, Section III.D.2) 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B, Section III.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 routed to the control device under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 13. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B, Section III.D.2): COLORADO Air Pciiution Control Division Page 3 of 8 a. Install and operate t loading of tank corn apors during 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 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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 COLORADO Air Pollution Control Division Page 4 of 8 • Whenever new cont ! equips nt� t °,.fled, t.' a ever di`ferent ape of control equipment replaces • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Control Division 0 Page 5 of 8 By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil & Gas, Inc. Permit for condensate loadout at a new synthetic minor well production facility. COLORADO Air Pollution Control Division 'ells` rers d Pub € Heeuh s E Mn)nrnent Page 6 of 8 Notes to Permit Holder at the time o 1) The permit holder is required ti t _ or o �� ' �'me ≥ s� it. Ane for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria' reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 007 Benzene ' 71432 179 9 n -Hexane 110543 1,566 79 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 007: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 2.36x10-1 1.18x10-2 CDPHE PS Memo 14-02 Benzene 71432 4.1x10-4 2.05x10-5 CDPHE PS Memo 14-02 n -Hexane 110543 3.6x10-3 1.8x10-4 Note: Controlled emission factors are based on an enclosed flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status COLORADO Air Pollution Control Division ci2 +rntni,d f eu;.n & ru: e t Page 7 of 8 Operating Permit Synttic Mif S•, ce • VO NOx, s0 any .n -Hexane NANSR Synthetic Minor Source of: VOC and NOx PSD True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX !COLORADO AirPoiiution Control Division } ,4, -vv ent'3t l } e 'tU e`»rrarsriz+t Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Harrison Slaughter - Package #: 3701051:. Received Date: 3/30/2018 Review Start Date: 4/25/2018 Section 01 - Facility Information Company Name: Extraction. Oil & Gas, Inc: County AIRS ID: 123 Plant AIRS ID: 9F59 Facility Name: Burroughs Production Facility Physical Address/Locatio NESE quadrant of Section 14, Township 7N, Range 65W, in Weld County, Colorado Type of Facility: Exploration & Production Well Pad What industry segment?oil & Natura€ Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes, , If yes, for what pollutant? Don Monoxide (CO) 0culate Matter (PM) Else (Nox & VOC) Weld Quadrant Section Township Range NESE 4 75 Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 008 Condensate Tartic. 001 Yes 18WE0358 1 Yes Perini ]nitiaf Ius€iancw - - Section 03 - Description of Project Extraction Oil & Gas Inc.(Extraction) submitted art application requesting permit coverage for condensate storage vessels at a new synthetic minor oil and gas well production facility,,'-? This source is APEN required because uncontrolled actual, VOC emissions are greater than 1 tpy (Colorado. Regulation 3- Part. A Section 1€ B3.a).Additionaly, this source is. permit required because uncontrolled: actual VOCemissidns from all AP EN required sources at this facility are greater than 2 tpy (Colorado Regulation Part B Section .D. .a), The operator initially requested GPO1 coverage For this source. However, the operator requested to change the GP01 to traditional permit coverage during review of the GP01. This permit will require public. comment because the operator s requesting new synthetic minor limits, to avoid other requirements and the change in VOC emissions as -a- result of the project are greaterthan 25 tpy:: , . Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? ttequestingSynthetic MlaorPe Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) of SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No, NOx CO VOC PM2.5 PM10 TSP ❑ ❑J HAPs LI ❑ Condensate Storage Tank(s) Emissions Inventory Section 01- Administrative Information 'Facility AIRS ID: P 9;. Plan Poin Section 02- Equipment Description Details Detailed Emissions Unit Eight (8) 400 batte( Fix•• Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput= Requested Permit Limit Throughput = 362,319 Barrels (obi) per year Actual Condensate Throughput While Emissions Controls Operating = 434,782 Barrels (bbi) per year Potential to Emit (PTE) Condensate Throughput ..434,782. Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced= 10.506.. scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 2550.4 Btu/sct Potential to Emit (PTE) heat content of waste gas routed to combustion device= Section 04 - Emissions Factors & Methodologies Pollutant Uncontrolled (lb/hr) VOC 90.38535194 Benzene Toluene Ethylbenzene Xyleee 0,80984448., 0.03458819'-' n -Hex n 224 TMP 0.0638654:. 0.663918 W III this storage tank emit flash emissions? 9,708 MMBTU per year 11,649 MMBTU per year 11,649 MMBTU per year Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) 21:1 EICHZEIIIMIIMEEIMIN. cam' 8iF IiUCIlidec9as1O � y s ®' ' 1.130E-04 6.969E-04 3.484E 05 ZIEEEZIONIIMIEFECM 6.434E 05 Pollutant Emission Factor Source (waste heat combusted) (Condensate Throughput) ® 0.0000MINIZEMMII Itl 0.0000 (, •: 9t(� (csyr�i'CFa,ma,,, ,59 ` Y 0.0680. 0.0018 ilMEMI' , .. 0.3100 0.0003 Section 05- Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Umits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 220.69 183.91 9.20 220,69 11.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.40 0.33 0.33 0.40 0.40 1.81 1.50 1.50 1.81 1.81 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 982.52 818.77 40.94 982.52 49.13 1270.57 1058.81 52.94 1270.57 63.53 86.24 71.86 3.59 86.24 4.31 302.99 252.49 12.62 302.99 15.15 5815.92 4846.61 242.33 5815.92 290.80 559.46 466.22 23.31 559.46 27.97 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XII.C, D, E, F Regulation 7, Section 511.0, C Regulation 7, Section MI.B, C.1, C3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NIPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 NSPS 0000a Regulation 8, Part E, MACE Subpart HH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Storage tank is subject to Regulation 7, Section XII.C-F Storage Tank is not subject to Regulation 7, Section XII.5 Storage tank Is subject to Regulation 7, Section XV II, 0, C.1 & C.3 Storage tank Is subject to Regulation 7, Section XVII.C.2 Storage Tank is not subject to NSPS Kb Storage Tank is not subject to NSPS 0000 Storage Tank Is not subject to NSPS 0000a Storage Tank is not subject to MAR HN Barrels (bbl) per year 2 of 5 K:\PA\2018\18WE0358.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated tq be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requitement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. N/A - operator developed site -specific emission factors Does the company request a control device efficiency greater than 95% fore flare mbustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes 1 In theoriginal apphcatton subm tied for the racity, tneopeator requested GPOoverag for this source_Durng renew of the GPO?, the operator decided to switch from SPOT totraditiona€permit erage the operator submitted an upoated APED: to support th s request,. With the updated APEV, the °praetor decreased the requested throughputfrom 629,389bbi/yearto434,7876bIJyear. The operator provided en updated Pro Mac simulation based onthis request. 2 to the original applca.o=, the upe.Eaton used flashemissions edicted lay the tank loss stencil int ProMex to esimate emiss ions. During re w,i ras determined that the nk lossstencil resuted in flash e.mhNons were less Ponsewetvethen the fla_h emissions estimated for the Tank Vapor" stream n the modelAsa result., t wasproposed touse the :flash emissions from the "Tank Vapor stream in the model rather than the flash emissions from the tank loss 0tenc Ito estimate emissions. The or atoagreed with this proposal and updated the calculaI onsecoord nnly. 3. Emi_sions 4om she cnntlen Ce storage v estmated ,m ng nro"Vax he Protiax smula Ilan s based o0site-specific prz ur tea condensate sample are m the low. pressure outlet of yt:P. e 'es a s separator associated with the Burroughs North 4 wall. This sample was obt)ned on 08/08/2017 The wmpaature and pressure of the sample are 100"F and 4., ps„ respectively. Iculaaonsare asfollow: ;)Neat Content (MMBtuNPIscf) (?3298 MMBtu/hr(/(( .0 2514MMsef/nay)/(24hrs/day/] 2550-3596 M€k8tu/MMsct (,) 00R (sct/biEJ (0.012514 NIMacf/day).'(365 day/year( (1.000,000scf/MMscr)/(434,782 bb /peer) = 10.5055 sefboil The operator was prowd.::d with a draft permit andAPEN mane to review P, o .., public comment The opera,. reviewed both doc,irnents:. Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # Process# 5CC Code 008 01 pressed hhey had no. comments.. Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 b/1,000 gallons condensate throughput PM2.5 0.00 0 b/1,000 gallons condensate throughput NOx 4.34E-02 0 b/1,000 gallons condensate throughput VOC 24.17 95 b/1,000 gallons condensate throughput CO 1.98E-01 0 b/1,000 gallons condensate throughput Benzene 5.38E-02 95 b/1,000 gallons condensate throughput Toluene 6.96E-02 95 b/1,000 gallons condensate throughput Ethylbenzene 4.72E-03 95 b/1,000 gallons condensate throughput Xylene 1.66E-02 95 6/1,000 gallons condensate throughput n -Hexane 3.18E-01 95 b/1,000 gallons condensate throughput 224 TMP 3.06E-02 95 b/1,000 gallons condensate throughput 3 of 5 K/PA\2018\18W E0358.CP1xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Pane A and B -OPEN and Paring Requirements how, is into grin-Alxamrnant Alvin ATTAINMENT Ar e re uncontrolled actual emissions from any criteria pallutantsfrom this Individual source greater than 2 TPY (Regulation 3, Part A, Section llRLa)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (Sae PS Memo 05-01 Definl[Ipns 1.11 and1.14 and Section 3 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOL emissions greater than 5 TPV, NOR greater than 10 TM or CO emissions greater than 10 TIM (Regulation 3, Part B, Section 11.0.3)? 1100 butt Milos-. NM source Is ht tiw Non,Anaimnrtt Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Pan A, Section 11.0.1.1)? 2. Is the coneOuctlon date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 'for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions horn the greater than 2 TM, NOx greater than 5 TPY or CO emissions greater than 5 MY (Regulation 3, Part0, Section 11.0.21? ISourro ronoiree a Ixnr'mit Colorado Regulation?, Section KILL -F 1. Is this storage tank located in the g -hr ozone control area or any ozone non -attainment area or etainment/maintenance area? 2. Is this storage tank located et an oll and gas exploration and production operation', natural gas compressor station or natural gas drip stenon? 3. Is this storage tank located upstream of a natural gas processing plant? !Stowe tank is sobiect to Begula[eon ➢, Session 011 CT, Section XII.C1 —General Requirements for Air Pollution Control Equipment —Prevention of leakage Section XII.C.2— Emission Estimation Procedures action XII.O— Emissions Control Requirements Section NILE — Monitoring Section XII.F—Recordkeeping and Reporting Colorado Regulation 7. Section XII,5 1, Is this storage tank located In the B -hr ozone control area or any atone non -attainment area or attainment/maintenance area? 2. Is Nis storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit"Flash"(e.g.storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOCr Itrr,m002 Ion moonsnidest ro prrgula:lon 7. SestionVITO Section 011.0.2 - Emissions Control Requirements Section 011.0.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section XII.C2— Emission Estimation Procedures Colorado Regulation 7, Section Melt 1. Is this tank located at a transmrsslon/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production faclliry', natural gas compressor nations or natural gas processing plant? S. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions]] of this storage tank equal to or greater than 6 tons per year 00C? ^arccaga. tail: t subact to Regulation 1, Seeion XVII, B C.1 d C.3 Section 1(VII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section %011.0.1- Emissions Control and Monitoring Provisions Section X011.0.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? litorage Zinkis suWoo . ioyoqu::;tionl.Sts?io:x 1ln1^e Section X011.0.2 -Capture and Monitoring for Storage Tanks fitted with Alr Pollution Control Equipment 40 CFR, Part 60. Selman Kb, Standards of Performance for Volatile Oceanic Noted Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to ?5 cubic meters Imo) p-4?2 BBLsi? 2. Does the storage vessel meet the following exemption In 60.1116(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 ma ["10,000 BBL] used for petroleum. oondensate stored,processed, or healed prior to custody transfer' as defined In 60.11162 3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of 'storage vesseloe in 00.111b? 5. Does the storage vessel store a "volatile organic liquid (VOrra as defined In 6o.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 'n excess 01204.9 kPe N29.2 eel] and without emissions to the atmosphere (60110b(d)(2l)t; or b. The design rapacity Is greater than or equal to 151 ma( -950 BBL) and Aortae liquid with a maximum true vapor pressures lea tlan35 kPe (60.110b(b)l?;or c. The design capacity Is greater than or equal to 75 M' N4?2 BBL) but less than 151 ms ['950 BBL] and stores a liquid with a maximum true vapor pressure° less than 15.0 kPa(60.110b[b)l? ISiaroge T.4 1, bind sgblaci to NIPS Cb Subpart A, General Provisions 360.112b - Emissions Control Standards for V0C 360.1136 -Testing and Procedures 46o.115b - Reporting and Recordkeeping Requirements 360.116h - Monitoring of Operations NA - Source Requires an OPEN. Go to the next question Go to next question Source Requires a permit Con0nue - You havelndicated the site attainment status on the project summary sheet. Continue - You have Indicated the facility type on the project summary sheet. Source is subject Continue- You have determined facility attainment on the Project Summary sheet. Storage Tank is not subject to Regulation 7,Section XII.G S You have Indicated facility type on project summary sheet. Continue • You have Indicated the source category on the Project Summary sheet. Go to the next question -You have indicated facility type on project summary sheet. Go to the next question Source Is subject to parts of Regulation 7, Sections XVI I.B&C. Go to the next question Source is subject to all provisions of Regulation?, Sections 0 g C Storage Tank is not subject NIPS Kb - The storage vessel capacity Is below the applicable threshold. fly , NR...:::..... 40 CPR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distrihutian I. Is this condensate storage vessel located at a facility In the onshore call and natural gas production segment natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tens per year? 4. Does this condensate storage vessel meet the definition of "storage vessel' per 80.5430? 5. Is the storage vessel subject to and controlled in accordance with re ulrements for store a vessels In 40 CFR Part 60 Sub art Kb or 40 CFR Part 63 Sub art HFI? (Storage Tank is nrtsuhjer.f Pu NSPS 0000 Subpart A, General Provisions per 460.5425 Table 3 460.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures 460.5395(g) - Notification, Reporting and Recordkeeping Requirements see.s416(c) -Cover and Closed Vent System Monitoring Requirements 460.5417 -Control Device Monitoring RequiremPMSd (Note: Ha storage vessel Is previously determined to be subject to MPS 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(02) even if Potential VOC emissions drop below 6 tans per year] 40 CFR, Part R0, Subpart 0000a, Standards of Performance for Crude Oil and Natural Gas Facilities for which Constmction. ModIfiratiom, or Reconstruction Commenced After September 18. 2015 1. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CPR, 60.2) after -September 18, 2015? 2. Does this condensate storage vessel meet the definition cif "storage vessel' per 60.5430a? 3. Is this condensate storage vessel located at a facility in the crude chard natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 4. Are potential VOL emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Is the storage vessel subject to and controlled in accordance with requirements for stora a vessels in 40 CFR Part 60 Sub art Kb or 40 CFR Part 63 Subpart HH? tuP strhlect IV NSP400000 40 CPR. Pert 63, Subpart MAR HH. 011 and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(al(ell; OR b. A facility that processes, upgrades or Acres 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' (63.760(ah3))? 2. Is the tank located at a faculty that is major for HAPs? 3. Does the tank meet the definition of 'storage vessel"' In 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions' per 63.761? 5. Is the tank sublett re control requlremente under 40 CFR Part 60, Sub art Kb or Sub art 0000? Continue - You have indicated the source category on the Project Summary sheet. Storage Tank is not subject NSPS 0000 -This tank was constructed prior to or after the applicablllw date. Go to the next question Go to the next question Go to the next question Storage Tank is not subject NSPS 0000a. (Continue -You have Indicated the source category on the Project Summary sheet. NA Subpart A, General provisions per 063.764 (a) Table 2 463.766- Emissions Control Standards §63.773 -Monitoring §63.774 - Remrdkeeping §63.775 -Reporting RAU Review PAR review Is required if Regulation 7 does not apply Mao If the tank is in the non -attainment area. If the tank meets bath criteria, then review RACT requirements. Disclaimer This document assists operators woo deteminIng applicability of certain requirements of the Clean Air Act, ifs Implementing regulations, and Air Quality Control Comnission regulations. This document Is not a rule or regulation, and the analysis It contains may not apply to a particularsltuagon based upon the Indleduel facts and circumstances. This document does not change orsubstlfute for any law, regulation, or any other legally binding requirement end is not legally enlomeable. In the event of any conflict between the language of this document and the language of the Clean Air Acf„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute orregWatlon will control. The use of non -mandatory language such as "recommend," 'may,' 'Should,' and"can,"Is intended to describe APCD interpretations and recomrrendatlons. Mandatory teminology such as "must' and "required"ere Intended to descdge controlling requirements under the terms of the Clean AlrAct and Alr Quality Control Cam isslon regulations, but this document does not establish legally binding requirements in and et Itself Storage Tank Is not subject MAO' HH -There are no MALT WI requirements for tanks at area sources CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0358 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Burroughs Production Facility 123/9F59 NESE SEC 14 T7N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description 001 008 Eight (8) 400 barrel fixed roof condensate storage vessels connected via liquid manifold. Enclosed Flare(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division xpcaa«.-,t of PubF;t Heath 1, E^vvar:ment Page 1 of 8 3. ce o edule oc ated wi i per -1 ," 1 discon source. peration ruction per ence as set u -s • ruction f which this permit was issued: this source within 18 months or the date on which such rth in the permit application riod 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.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO 001 008 --- --- 11.1 --- 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 shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled 001 008 Enclosed Flare(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made COLORADO } Ail Pollution Control Division OeWirtt;VrIt fea r» e &wir 9rrnent Page 2 of 8 upon r - -,. (Regul. .n Number 3, Part B, Section Facility Equipment ID AIR Point Process Parameter Annual Limit 001 008 Condensate throughput 434,782 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III. E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered . by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to ;COLORADO Air'Polktttiort Control. Division avartmeAt Cif Out*.: 13e th & E^.Yit'nrneet Page 3 of 8 14. ect to the ve ation N ithin 90 days of the date that ng and Storage Tank Emission , Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO),) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or 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. !COLORADO Air PoUutiori Control Division c �_r Pbuiiu hedth U E kooment Page 4 of 8 19. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter (COLORADO I Air Pollution Control Division Depetr,lcr.f of PubiA Necicn G Lfwir6ru +reff Page 5 of 8 Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. Permit for condensate storage vessels at a new synthetic minor oil and gas well production facility. COLORADO Air Pollution Control Division .itr€?_lie9tth L..rvnnment Page 6 of 8 1) Th , rvermit h. =n° -r is qu:.. to pay ; •The pro �_ -ssitime for is permit. An invoice for these fee ill be ed a -r th errni issue. i he p: it holder sh - pay the invoice within 30 days the. pa - will rerevocation 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 uponrequest of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 008 Benzene 71432 983 50 Toluene 108883 1,271 64 Ethylbenzene 100414 87 5 Xylenes 1330207 303 16 n -Hexane 110543 5,816 291 2,2,4- Trimethylpentane 540841 560 28 Note: All non -criteria reportable pot utants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 008: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 1.02 5.08x10-2 ProMax 71432 Benzene 2.26x10-3 1.13x10-4 ProMax 108883 Toluene 2.92x1O3 1.46x104 ProMax 1330207 Xylene 6.97x10-4 3.48x10-5 ProMax 110543 n -Hexane 1.338x10-2 6.69x10-4 ProMax 540841 2'2'4 Trimethylpentane 1.29x10-3 6.43x10-5 ProMax Note: The controlled emissions factors for this point are based on the endosed flare control efficiency of 95%. The uncontrolled emission factors were established using ProMax and a site -specific COLORADO Air Pollution Control Division Depa,tm e;t Cd Putili l;ec₹th 5 En*.Orune.;t Page 7 of 8 ssure separator for the Burroughs 6) In . ordanc ��' ith �'.S. ,3; 7 114 `, each Poll <;nt Emission dice (APEN) associated with t • - , . � vali e., ,ter _ . -,_, �- ears,.... ..� << it was r .• by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting thestorage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, and n -Hexane NANSR Synthetic Minor Source of: VOC and NOx PSD True Minor Source MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX 'COLORADO Air Pollution Control Division _P=Jti"dtt EYtirr_onnset;t Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Harrison Slaugnte 370103 3/20/2018 4/26/2018 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Extraction Oil & Gas, Inc'. 123 9F59 Burroughs Production Facility Physical Address/Locatie NESE quadrant of Section 14, Township 7N, Range 65W, in Weld County, Colorado 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? on Monoxide (CO) t' -'riculate Matter (PM) Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NESE 14 7 65 ®ne (NOx & VOC) AIRS Point it Emissions Source Type Equipment Name Emissions Control? Permit If Issuance ri Self Cert Required? Action Engineering Remarks 009 Produced Water Tank Produced Water Tank Yes 18WE0359 1 - - Yes Permit Initial Issuance Section 03 - Description of Project Extraction Oil & Gas Inc. (Extraction) submitted an application requesting permit coverage for produced water storage vessels at a new synthetic minor oil and gas well production facility. This source is AMEN required because uncontrolled actual VOC emissions are greater than 1 tpy (Colorado Regulation 3 Part A' Section li.B.3.a). Additionally, this source is permit required because uncontrolled actual VOC emissions from all APEN required sources at this facility are greater than 2 tpy (Colorado Regulation Part B Section II.D.2.a). The operator initially requested GP05 coverage for this source. However, the operator requested to change the GP05 to traditional permit coverage during review of the GP05. This permit will require public comment because the operator is requesting new synthetic minor limits to avoid other requirements and the change in VOC emissions as a result of th project are greater than 25 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greater than 25 tons per year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) o Is this stationary source a major source? If yes, explain what programs and which pollutants hers 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 No Yes NOx CO 1 J NOx VOC PM25 J CO VOC PM2.5 PM10 TSP HAPs ❑ ❑J PM10 TSP HAPs E ❑ Produced Water Storage Tank(s) Emissions Inventory Description: Section 01- Administrative Information Facility AIRs ID: 123 9F59 Plant 009 Point Section 02 - Equipment Description Details Detailed Emissions Unit Two (2) 400 barrel fixed roof produced water storage vessels connected via liquid manifold. Emission Control Device Emi55ions from thr. Description: Requested Overall VOC& HAP Control Efficiency %: source are controlled by enclosed flare(s). Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput= Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = .36 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 453,678 Barrels (bbl) per year 44,414 Barrels (bbl) per year 544,414', Barrels (bbl) per year 496 Btu/scf Actual Produced Water Throughput While Emissions Controls Operating = 453.678'; 24,433 MMBTU per year 29,320 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 29,320 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (lb/13b1) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 2.62E-01. 7.00E-03 1.310E-02 3.500E-04 0.000E+00 0.000E+00 0.000E+90 1.100E-03 0.000E+00 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2.20E -0Z'.......... Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) Emission Factor Source PM10 PM2.5 0.0000 0.0000 NOx CO 0.0680 0.3100 3.662E-03 1.670E-02 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 71.32 59,43 2.97 71.32 3,57 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.00 0.83 0.83 1.00 1.00 4.54 3.79 3.79 4.54 4.54 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/yeerl (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 3810.90 3175.75 158.79 3810.90 190.54 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 11977.11 9980.92 499.05 11977.11 598.86 - 0.00 0.00 0.00 0.00 0.00 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 0000 Storage Tank is not subject to NSPS 0000 N5PS 0000a Storage Tank is not subject to NSPS 00000 2 of 4 K:\PA\2018\ 18WE0359.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory (See regulatory applicability worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and colected 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 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 N/A - emissions are calculated using the state default emission factors. 5.9 and 5.12 for additional guidance on testing. zt> : _A6w Section 08 - Technical Analysis Notes 1. In the original application submitted for this facility, the operator requested GPOS coverage for this source During review ofthe GP05, the operator deddedtwvwitch from SPOT to traditional permit coverage. The operator submitted an updated APEN to support this request. With the updated APEN, the operator decreased the requested throughpatfiom63fi 211bbl/year to 544,414 bbl/year. 2..:Combustionemissions were calculated using the state provided GOB and heat content for produced water storage vessels using he state defaulternissionfactbrs₹o estimate primary emissions. The heat content and GDR values maybe referenced in the secondary emissions portion of Section 03 of this analysis 3. The operator waprdvided'with a draft permit and APES redline to review prior to public comment.The operator reviewed both docu AIRS Point If 009 Process 8 5CC Code 01 4-04-003-I5 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Section 09 - Inventory 5CC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 8.72E-02 0 lb/1,000 gallons liquid throughput VOC 6.24 95 lb/1,000 gallons liquid throughput CO 3.98E-01 0 lb/1,000 gallons liquid throughput Benzene 1.67E-01 95 1b/1,000 gallons liquid throughput Toluene 0.00E+00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00E+00 95 lb/1,000 gallons liquid throughput Xylene 0.00E+00 95 lb/1,000 gallons liquid throughput n -Hexane 5.24E-01 95 lb/1,000 gallons liquid throughput 224 TMP 0.00E+00 • 95 lb/1,000 gallons liquid throughput 3 of 4 K:\PA\2018\ 18WE0359.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and Injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Color -ado ee ulatlan3 PartnA and R-APEN and Permit Requirements Source is in the Non'Aoolnmons Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 0.0.1,5)? 2. Is the operator claiming less than 1% crude ail and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part 0, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPy or CO emissions greater than Wiry (Regulation 3, Part B, Section 11.0.3)? you have inditased that source is :n the Non.Attub:ment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulatlon 3, Part A, Section l I.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part 8, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, rude greater than 5 TPy or CO emissions greater than 5 TPY (Regulation 3, Part Section 11.0.2)? (Source requires a permit Colorado Regulation T. Section )(VII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions"' of this storage tank equal to or greater than 6 tons per year VDC? IStpra,;c unit is s,d:jecs to 4er,uiuY en T, Section 0011, R, C.1 & C.1 Section ICVII.B-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section KVI I.C.1- Emissions Control and Monitoring Provisions Section IMI.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. IS:orag< ink Is sobleo to 3eoalaHan 7, Section XUH.C.2 Section IMI.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment levels. Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. 2. 3. 4. 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? Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? Oct potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year? Does this produced water storage vessel meet the definition of "store evessel"' or 60.5430? I Storage Tank 14 not subject to NSPS 0000 Subpart A, General Provisions per 460.5425 Table 3 §60.5395 - Emissions Control Standards for VOC 460.5413 - Testing and Procedures 660.5395(g) -Notification, Reporting and Recordkeeping Requirements 460.5416(c)- Cover and Closed Vent System Monitoring Requirements 460.541? -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 applicablllry 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 60, Subpart e000a, Standards of Performance for Crude 011 and Natural Gas Facilities for which Construction. Modification, or Reconstruction Commenced After September 18, 2015 1. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 16, 2015? 2. Does this produced water storage vessel meet the definition of storage vessel"' per 60.5430a? 3. Is this produced water storage vessel located ate facility in the crude oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Is the storage vessel subject to and controlled in accordance with requirements for store a vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HH? 'Storage Tank in Nett to NSPS 0000a RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, end Alr Qualify Control Commission regulations. This document is not a rule or regulation, and the analysis if contains may not apply toe particular situation based upon the individual facts end 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 Acf„ its • implementing regulations, end Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recormmend,""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 ferns of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in end of itself. YO.M61, Yes Yes Wp,,,,,,,,,,,,, Yes Vas.,,:,,,.,: Source Requires an APEN. Go to the next question Go to next question Source Requires a permit Continue - You have indicated the source category on the Project Summary sheet. Continue- You have indicated the faculty type on the Project Summary sheet. Go to the next question Source is subject to parts of Regulatlon 0, Sections KVII.B&C. Go to the next question Continue - You have indicated the source category on the Project Summary sheet. Storage Tank is not subject NSPS 0000 - This tank was constructed prior to or after the applicability date. Go to the next question Go to the next question Go to the next question Storage Tank is not subject NSPS 0000a. CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0359 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil &t Gas, Inc. Burroughs Production Facility 12319F59 NESE SEC 14 T7N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Produced Water Tank 009 Two (2) 400 barrel fixed roof produced water storage vessels connected via liquid manifold. Enclosed Flare(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division eR^ mnen.t of PubEt Heath t^vi�r*v nt Page 1 of 7 3. eduled coated wi is permi ," disco 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: source peration ruction per ence as set -s • ruction f which this permit was issued: this source within 18 months or the date on which such rth in the permit application eriod of eighteen months or Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Produced Water Tank 009 --- 1.0 3.6 4.6 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 emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Produced Water Tank 009 Enclosed Flare(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made 'COLORADO Air Pollution Control Division Ji?.piir' rent+fit Ptbkc I;eei'rt s :,.tt.�nr�ree Page 2 of 7 for ins • upon Number 3, Part B, Section Facility Equipment ID AIR Point Process Parameter Annual Limit Produced Water Tank 009 Produced Water Throughput 544,414 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following scheduler • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COLORADO Air Pollution Control Division paKt rrof'PantieHeu by ^vrcurrnent Page 3 of 7 ME - 15. 1111W '- is n. e. ui to duct in unless oth 'se directed by the Division or o er state or e• eral requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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)s°ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not 'COLORADO Air Pollution Control Division f this so e. Final authorization of the g 1 accorda - with the provisions of 25-7- 3, Part B, S ion III.G. Final authorization grant unti =:, a o• 'ation o tivit ommences a has been verified by the APCD conformin• ` . ` res•- z ^'`'h th- • "•i f the pe nce self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. Permit for produced water storage vessels at a new synthetic minor oil and gas well production facility. COLORADO Air Pollution Control Division ? y!,*7rent W Putil _ lieetthv E vonr: n Page 5 of 7 1) Th time for is permit. An invoice for these fee ill be M ed a : r the-° ,ermi issue•' ,, he p= it holder sh. _spay the invoice within 30 days the - e. • pa i will re revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 009 Benzene 71432 3,811 191 n -Hexane 110543 11,978 599 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 009: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.66x10-3 3.66x10-3 AP 42 Chapter 13.5 CO 1.67x10-2 1.67x10-2 AP 42 Chapter 13.5 V0C 2.62x10-1 1.31x10-2 CDPHE PS Memo 14-03 71432 Benzene 7.0x10-3 3.5x10.4 CDPHE PS Memo 14-03 110543 n -Hexane 2.2x10-2 1.1x10-3 CDPHE PS Memo 14-03 Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. The AP -42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) were converted to units of lb/bbl using a heat content of 1,496 Btu/scf and a gas -to - water (GWR) ratio of 36 scf/bbl. 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 'COLORADO 1 Air Pollution Control Division r..ak ox 4ubtc l' ea s Ehvw rrnei:t Page 6 of 7 AP th ost rece . ann ass 'ated wi this rmi - or an ;z•uesti at 13 • • 50. 7) p mit fulfills "=" �' p- =qul • hol.�a v: .. -°'"' � `t reflects 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: m expires. Please refer to date for each emissions point 'ration date call the Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO and n -Hexane NANSR Synthetic Minor Source of: VOC and NOx PSD True Minor Source 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division ,.` Atutment of PutA ; He ?^ s LLtin'7nrnellf Page 7 of 7 CEIVED (O 1'3 2011 /\pCD Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: l -w 8 tO 9-(o AIRS ID Number: 123 /q c5q ao2 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Burroughs Production Facility Produced Gas Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Burroughs Production Facility Site Location: NESE Sec.14 T7N R65W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, CO 80202 E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 370097 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 ®V COLORADO 1 j �e Permit Number: 11 -WE ►olko AIRS ID Number: 123 /959 /cot [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action I NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 OR- ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ Add point to existing permit ❑ Other (describe below) Additional Info Et Notes: Requesting permit for produced gas venting. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Produced gas from separators will be combusted by an ECD when it cannot be compressed for sales. Volumes are monitored via flowmeter. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 07 / 13 / 2017 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year ❑✓ Yes O No O Yes O No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 ®.COLORADO . ===, Permit Number: Cnko AIRS ID Number: 123 /9 .sci /002_ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information rj Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: El No Maximum Vent Rate: 1 00 ,000 SCF/hr Vent Gas Heating Value: 1 281.5 BTU/SCF Requested: 7772. Q).s MMSCF/year Actual: 478 .A.5 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 22.2796 • VOC (mole %) 10.22 • VOC (Weight %) 22.72 • Benzene (mole %) 0.0139 . Benzene (Weight %) 0.048733 • Toluene (mole %) 0.0072' Toluene (Weight %) 0.029776 • Ethylbenzene (mole %) 0.0oo y Ethylbenzene (Weight %) 0.001906 - Xylene (mole %) 0.0014. Xylene (Weight %) 0.00667115 n -Hexane (mole %) 0.051 ' n -Hexane (Weight %) 0.19726 2,2,4-Trimethylpentane (mole %) 0 2,2,4-Trimethylpentane (Weight %) 0 . Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Ft n -Hexane, temperature, and pressure) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 hips osp [ k ®WCOLORADO 3 I vo" r Permit Number: I�LAX I D1kp AIRS ID Number: 123 /9 F5ct / Q 7 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.570636, -104.621414 Operator ."" Stack ID No. Discharge Height A bove Ground Level (Feet) Temp .:, ("F) Flow Rate "' (ACFM) Velocity (ft/set) Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) O Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 2 Circular Interior stack diameter (inches): ❑ Other (describe): 0 Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: Type: MMBtu/hr Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency 98 Minimum Temperature: Constant Pilot Light: ❑✓ Yes 0 No Pilot burner Rating Waste Gas Heat Content Btu /scf MMBtu/hr hr ❑ Other: Pollutants Controlled: Description: Control Efficiency. Requested 0/0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 to ©5 03 to 1 it `b 4I AY • •COLORADO orp, Hu.� �Enn,onmeN Permit Number: AIRS ID Number: 1 23 /��S`l / 007 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NOx VOC ECD 95% CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? 2017/2018 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant ' Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions , ; ` Requested -Annual Permit;' ,,,.. , Emission Lulu s)s s . Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO„ 0.068 Ib/MMBtu AP -42 -- O.Z -- O.3 VOC 13,341 Ibly,-,,,sc.f ProMax 32.8 2i,g3 4-6. (.5 z2-4 '1'3 48.e ys.9 CO 0.31 Ib/MMBtu AP -42 -- O•%S`\ • -- 1.x-1 Benzene Toluene Ethylbenzene Xylenes n -Hexane 115.1;1 1�,,.,,..,x.c ProMax O. ZD 0.c.)11 3 o. 3 q 0.02 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. NoS US II ILI (18- Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 5 1 �� =7,71:.77 H,sYT b FnWvnnmt Permit Number: «u9C IOW AIRS ID Number: 123 /9F59/ oo2. [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. SignatUi-e of Lega llyy Authorized Person (not a vendor or consultant) Kathy Steerman COO (16 a Date Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd ®V.=7,1RADO Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: (-k (A) �0 � AIRS ID Number: 123 /9F51 / c0� [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Burroughs Production Facility VRT Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Burroughs Production Facility Site Location: NESE Sec.14 T7N R65W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, CO 80202 E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 377433 1' COLORADO n"a+.edtnwe R•au‘ GMgn1MN Permit Number: uoF Ind AIRS ID Number: 123 /9F -5c/ c3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ▪ NEW permit OR newly -reported emission source - OR - O MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name ❑ Add point to existing permit ❑ Change permit limit 0 Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: Requesting permit for VRT gas venting. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Gas from VRT will be combusted by an ECD when the VRU is non -operational. Volumes are monitored via flowmeter. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 07 / 13 / 2017 O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year O Yes O Yes ❑ No 0 No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I COLORADO my emmmvINuc MOM, EmlloMwM Permit Number: ►-A-0C- lo -1 - AIRS ID Number: [Leave blank unless APCD has already assigned a permit N and AIRS ID] 123fl-FS1/co Section 4 - Process Equipment Information O Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: O Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑✓ No Maximum Vent Rate: 2 68 SCF/hr Vent Gas Heating Value: 2 457.5 , • BTU/SCF Requested: 2.3 • MMSCF/year Actual: 1 .481 • MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 43.615 • VOC (mole %) 65.06 • VOC (Weight %) 78.07 Benzene (mole %) 0.12723 Benzene (Weight %) 0.22787 Toluene (mole %) 0.15355 Toluene (Weight %) 0.32438 Ethylbenzene (mole %) 0.0098703 Ethylbenzene (Weight %) 0.024026 Xylene (mole %) O. o3y'd`-lc4 Xylene (Weight %) 0.084825 I n -Hexane (mole %) 0.62635 n -Hexane (Weight %) 1.237i, 2,2,4-Trimethylpentane (mole %)(Weight 0.048658 2,2,4-Trimethylpentane %) 0.12744 Additional Required Information: O 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) \k S clot lit Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 31 COLORADO neveamm at Adak Heath. GW1CnFMN Permit Number: 1� L0E\Q-+ AIRS ID Number: 123 /9F5c / co\ [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 5 - Stack Information 40.570636, -104.621414 -„, \ a �A i er #t ice\ L\ ��1' �. ,,v i � O. L4' F.i `\- ��\. mp � �� In a /' \ \` "'„` ` S �\. \tea s 4.--,----- �; elo .- --{�\� `,\ \ Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) E Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ✓❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOCs, HAPs L�17 MMBtu/hr Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency 98 Minimum Temperature: Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating Waste Gas Heat Content Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-205 -Natural Gas Venting APEN - Rev C i/2017 4I COLORADO a. « Rmgthb Fm+roratan rc Permit Number: Il-c0l✓ ic)--4;q7- AIRS ID Number: 123 /cF-I /CCU [Leave blank unless APCD has already assigned a permit # and AIDS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): PM Requested Control Efficiency reduction iri emissions),: SO), NO„ VOC ECD 95% CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? 2017/2018 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor` Em2ss�on Factor Units Factor Source SAP 42, Mfg.... etc), .. >� � s'o a�, R�� ss3o 1 Uncontrolled , _(Tnns/yenr C-,ontroRedb ,: ('Tons/year) . Uncontrolled _ , (Tons/year) , _ Controlled ., Tonslyear} PM SO. NO 0.068 Ib/MMBtu AP -42 -- 0.124- -- 0.192. VOC Wii--{Zk, 1y -n sue- ProMax 66.43• 3.32 ' 103.18 ' 5.16' CO 0.31 Ib/MMBtu AP -42 -- 0.564 ° -- 0.876° Benzene av( 7,e\ lb(vev' S1 ProMax 0.194 • 0.01 • 0.301 ° 0.015 • Toluene 3--2 . $Z lbiv-,\,,,`4- ProMax 0.276 • • 0.014 0.429 • 0.021 • Ethylbenzene Z}.bI ‘311,x,,,v-cc ProMax 0.02 ° 0.001 • 0.032 • 0.002 - Xylenes cr1-,'-1) \ I.,N,,,,5e..JT ProMax 0.072 • 0.004 ' 0.112 • 0.006° n -Hexane I,i-t72.39 Ib1,-,,, nx-' ProMax 1.053 • 0.053` 1T63' [..t 0.082 Trimethylpentane l-ho'y�- `"'� s4 ProMax 0.108 ° 0.005 , 0.168. 0.008 . Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-%05 -Natural Gas Venting APEN - Rev 03/2017 5 I COLOR ADO De, .t. momco Permit Number: AIRS ID Number: 123 /c1F31/ [Leave blank unless APCD has already assigned a permit " and MRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. ck(2.6 7,6 Signature of Lega ly Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.cotorado.gov/cdphe/apcd Form APCD-205 -Natural Gas Venting APEN Rev 03/2017 6 A COLORADO Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. 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: wgi 35% AIRS ID Number: 123 /9F59 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Burroughs Production Facility Liquid Loading [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. Burroughs Production Facility Site Location: NESE Sec.14 T7N R65W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, CO 80202 E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 377432 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 11 i COLORADO b. flmtofPohtle Nw1U tr FiwMumme,I Permit Number: AIRS ID Number. 123 /9F59 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action E NEW permit OR newly -reported emission source ❑✓ Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment 0 Change company name O Change permit limit 0 Transfer of ownership3 ❑ Other (describe below) - OR ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Loading of condensate into tanker trucks. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 07/ 13 /2017 Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 2 ❑ Yes ❑ No ❑ Yes 2 No ❑ Yes 2 No p Yes 0 No ❑ Yes ❑✓ No ❑ Yes ❑✓ No ❑ Yes ❑Q No COLORADO H,p..mimc ofpbhuc xp un uFnmranmnr0 Permit Number: 8t.JE 03S� AIRS ID Number. 123/9F59/007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 434,782 Bbl/yr Actual Volume Loaded: 362,319 Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") Tank Trucks If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: N/A Average temperature of bulk liquid loading: N/A °F True Vapor Pressure N/A Psia 60 °F Molecular weight of displaced vapors N/A Lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A Bbt/yr Actual Volume Loaded: N/A Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Load Line Volume: N/A N/A Lb/ft3 ft3/truckload Vapor Recovery Line Volume N/A ft3/truckload Form APCD-208 -(-Hydrocarbon Liquid Loading APEN - Rev 02/2017 3 I COLORADO Leyvtmmt of Nrbtic Fiw1MbanVIMIntMr Permit Number: �AIRS ID Number: 123/9F59/007 [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 5 - Geographical Information [cal Coo ina Ltd or U,1 40.570636, -104.621414 Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ✓❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system: Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOCs, HAPs Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr Make/Model: 95 98 Waste Gas Heat Content Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 u�S osi ►SItS Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 4I COLORADO bcpmtment of Public Hmiln a a.v!.omneta Permit Number: AIRS ID Number: 123/9F59/007 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Poffutat . _, , . �, C%trol Equip entbescrtptroi� z � , __,_,_. orerat RequestedContro[„ �� `Eff .---,,,,,;,e,,,,, ncy _, %re itc₹ro u emrssfons PM SOx NO„ CO VOC ECD 95% HAPs ECD 95% Other: ❑✓ Using State Emission Factors (Required for GP07) VOC ✓❑ Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2017/201E Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) 4-4 zz � utant �� -� lY con lte Emisston Eacti �� t .,,� _. ,�� R� , , p E tss�or Factor ~ Cnrts �� .�� Emission Factor Sob e (x-42 M�efcf � m u a �,4 ,,� Unccontro11eci „ �i�sns/ye�s'�_ �Contro fe€ ��Tonsfyear� Uncantr lied , ��'onsl�ear�: z �ontr�olied �i'�nsTyear�,= PM SOX NOx 0.068 . Ib/sMMBtu AP -42 -- 0.07 - -- 0.08 - VOC 0.236 - Ibs/bbl APCD 42.8 . 2.1 - 51.3 - 2.6 .. CO 0.31 . Ibs/MMBtu AP -42 -- 0.32 - -- 0.39. Benzene 0.00041' Ibs/bbl APCD 0.07 • 0.004 . 0.09 . 0.004 • Toluene Ethylbenzene Xylenes n -Hexane 0.0036 . Ibs/bbl APCD 0.652 • 0.033 ` 0.783 ' 0.039. 2,2,4- Trimethylpentane Other: a Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Anrual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 51 1:Heal:mama at COLORADO Health 4 Enteto�nmenl Permit Number. AIRS ID Number: l 23 - I F5ci / co+ [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 the applicable General Permit. 71-Iw1)( Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-81 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN Rev 02/2017 6 I V COLORADO ,N\O Condensate Storage Tank(s) APEN' lo Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loadings, 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: f 8W E q)35 ' AIRS ID Number: 123 / 9F59 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Burroughs Production Facility Site Location: NESE Sec.14 T7N R65W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E -Mail Address2: ksteerman@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 APCD via e-mail to the address provided. 377430 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 NMtlh6r'RADO Permit Number: 1Sk.,Dtco3s8 AIRS ID Number: 123 / 9F59 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ 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 Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Storage of condensate at E&P facility. For new or reconstructed sources, the projected start-up date is: 07/13/2017 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑✓ Exploration a Production (EEtP) site O Midstream or Downstream (non EaP) site Will this equipment be operated in any NAAQS nonattainment area? O Yes ■ No Are Flash Emissions anticipated from these storage tanks? HI Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? • Yes • No If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 • Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 21 COLORADO Depart..otlhbU Hetlih6 EnoMemn.M Permit Number: (EtLEO3SS AIRS ID Number: 123 / 9F59 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information 362,319 434,782 From what year is the actual annual amount? Average API gravity of sales oil: 53.40 degrees ❑ Internal floating roof 2017/2018 Tank design: ❑r Fixed roof RVP of sales oil: 10.94 O External floating roof 001 8 x 400 bbl 3,200 bbl 05/2017 07/2017 0 See Addendum 0 0 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 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 40.570636, -104.621414 Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) 0 Upward 0 Downward 0 Horizontal 0 Other (describe): Indicate the stack opening and size: (check one) ❑r Circular o Square/rectangle ❑ Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): Unknown Interior stack width (inches): Interior stack depth (inches): Form APCD-205 -- Condensate Storage Tank(s) APEN - Revision 02/2017 3 I Deporimau al Public I COLORADO 1i.WbbEnNro'uwM Permit Number: 1cbCOE0 S$ AIRS ID Number: 123 [Leave blank unless APCD has already assigned a permit # and AIRS ID] 19F59 / 008 Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: Type: EW Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr Make/Model: 95 % 98 Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes 0 No Pilot Burner Rating: Btu /scf MMBtu/hr hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (EaP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 9 psig Describe the separation process between the welt and the storage tanks: Wellhead to 3 -phase HVLP separators, to vapor recovery tower, to storage tanks. (4 DS o5ityl�c� Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017 4 I COLORADO newnm®t atPabbc Permit Number: AIRS ID Number: 123 / 9F59 / 008 [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 form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall Pollutant z z�� - Descn tlon� Contrat ethod(s �� u_ _ . - -.� . ��Q_ __v _� . �_.� __ , ,_ _ : � OvR erall eyu eged ontrof Efficiency (91re8uc 1017Yn emmssrons VOC ECD 95% NOx CO HAPs ECD 95% Other: 2017/2018 From what year is the following reported actual annual emissions data? Criteria Pollutant Emtsssons lnventary = of ut n1 Emission Factor �� Actuai Annua missrons L - e, : ttciAr ual Permit � 4 Ernlssion itm�t(s� , ,- ° nro s basis nif� Dine �AP iz � etc � -__� Uncontrolled �3 missions 7o�s13-04 �_� .. ,- Controlled Efnissions (T�ii gar �,� Unconeci � 1 misssor s ons/yea ontrolied 1≤rntssib 7vns7year VOC 1.0150 " lb/bbl ProMax 183.88 . 9.19 " 220.65 • 11.03 • NOx 0.068 - Ib/MMBtu AP -42 -- 0.33 " -- 0.40 . CO 0.31 - Ib/MMBtu AP -42 -- 1.5 • -- 1.81 , Non Cla t p Re ortable_ Pollutant Er ons� invrenta S s � � Chernaca mission 4C -C Act aiAnnuai missions aemlcat at v „„ . Abstract Sernce (CASE Jncontro ed Uri tln�ts Source 1Jncontroltec# Cmssior> ,, Cantroile � Ernissip Numbe Basis iJlf etc Imo. ) iot�>�ss eor .. _ nu enr Y Benzene 71432 0.00226 • lb/bbl ProMax 819 - 41 - Toluene 108883 0.002923 - lb/bbl ProMax 1,059 ' 53- Ethylbenzene 100414 D.0001984 - lb/bbl ProMax 72 • 4 • Xylene 1330207 0.000697- lb/bbl ProMax 253. 13- n -Hexane 110543 0.01338 ' lb/bbl ProMax 4,848 ' 242. 2,2,4- Trimethylpentane 540841 0.001287 • lb/bbl ProMax 466 - 23 ' 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidabice in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 5 I COLORADO atawsuc 1&ettt•b&mr+rtmetu Permit Number: I(TpcibEczs AIRS ID Number: 123 ra�cj 5d [Leave blank unless APCD has already assigned a permit " and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legalzed Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A,, I I.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 6 AY COLORADO E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Extraction Oil & Gas, Inc. Source Name: Burroughs Production Facility Emissions Source AIRS ID2: 123 / -- /00g Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 40459 Burroughs North 1 ►/ 05 - 123 - 40462 Burroughs North 4 /1 05 - 123 - 40737 Burroughs South 10 O 05 - 123 - 40740 Burroughs South 11 /1 05 - 123 - 40736 Burroughs South 12 /1 05 - 123 - 40739 Burroughs South 13 L - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 Burroughs_AP_FormAPCD-212-EP-StorageTank-APEN-Addendum 2017-07-18 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ( gWE. 0359 AIRS ID Number. 123 / 9F59 / 009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Burroughs Production Facility Site Location: NESE Sec.14 T7N R65W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E -Mail Address2: ksteerman@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 APCD via e-mail to the address provided. 377431 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 1 Depsrimmi of Public ;COLORADO Nam 6FmnroMwN Permit Number: l5L6-o3s9 AIRS ID Number: 123 / 9F59 / 009 [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit 0 GP05 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment 0 Change company name ❑ Change permit limit 0 Transfer of ownership3 0 Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Storage of produced water at E&P facility. For new or reconstructed sources, the projected start-up date is: 07/13/2017 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 0 Exploration a Production (E&P) site weeks/year 0 Midstream or Downstream (non EaP) site Will this equipment be operated in any NAAQS nonattainment area? O Yes ■ No Are Flash Emissions anticipated from these storage tanks? O Yes • No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • SI Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? O Yes ■ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No Ti Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No Ti • •r= Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 2I COLORADO o.y nmua of Pub& Had%Y EmlrovroM Permit Number: Vbt�E,a3ci AIRS ID Number: 123 / 9F59/ 009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information uestetl Artnua -m ucec(Yate�Tirati 453,678 544,414 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof 2017/2018 ❑ Internal floating roof ❑ External floating roof fora ark ID ;fltal oafs Manifold Sto a e ;— s rn Stow a Tdrll( - .,,. 1(o1ue of � Mora e Tank s�z Instaitation Date oillst�atos Recent Storage lfess atrrocuclo Storage Tan �mor�fi eat otitt7 of N/A 2 x 400 bbl 800 bbl 05/2017 07/2017 /ells SeTced ley #h sStrage an or;Task BatteEftP Slte3q} w zAPlnm�er ��G �� dame of W �leepor3e�Veli See Addnedum ■ ■ - III 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information 40.570636, -104.621414 E3pea, tortack =�schar�ee9raa+ep IR o,.. -�rou l, �elaet , 7� a se 1,-Y,.--,.. -a: Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) El Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Unknown Interior stack width (inches): Interior stack depth (inches): Form APCD-207 - Produced V/titer Storage Tank(s) APEN - Revision 02/2017 3 ;COLORADO Deyartmmnl a[ Pul.c MAIM ae,..a.e.nnenl Permit Number: EO33c1 AIRS ID Number: 123 / 9F59 / 009 [Leave blank unless APCD has already assigned a permit ft 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 ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: Type: ECG Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr hr Make/Model: 95 98 Waste Gas Heat Content: Constant Pilot Light: El Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 43 psig Describe the separation process between the well and the storage tanks: Wellhead to 3 phase VHLP separators to storage tanks ;COLORADO NWIh6En=, Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 4 I Permit Number: c (c)E OS -9, AIRS ID Number: 123 9F59 / 009 [Leave blank unless APCD has already assigned a permit r 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 Pollutant Description of Control Aethod(s) overall Regtiesteci Control Efficlenc (% reduction m emissions) ' , .. VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? 2017/2018 iteCrria Pollutant Emisstonsln4-entory pollutant Emission Factor - Actual Annual EmiSilo ns � Iles it a Pernsi EI11tt-sin - L(s 4 lfncontrolled Units source AP�4 f etc 1 con -o E ssions;� onsl enr yen � Controlled Emissions tTons7y�gr� 1lncoatro1l cf Emissions ons7 ear l� y � Contro> ed Errl2ssions �ns7 ear ; � Y_. VOC 0.262 ' Ibs/bbl PS Memo 14-03 59.43 • 2.97° 71.32 • 3.57 • NOx 0.068- Ib/MMBtu PS Memo 14-03 -- 0.83- -- 1.00. CO 0.31• lb/MMBtu PS Memo 14-03 -- 3.79 • — 4.54 . ldon Crrtena IteportakPallutant Emissions h,ventur Ciaemtcat Name z . _ . Ctiemtcal Ai�st t Ser ace ASj Number __. Et145190-Factors' Actual Annual Emissions , T)�conir0 ed -?,„ Basis Units Source (AP 4 , Mfg tc� l nc�ontroiled n mss ns - ( o[ ntfs enr _,, Coi roiled Errs ionsa� tPor nds year Benzene 71432 0.007 . Ibs/bbl PS Memo 14-03 3,175.75 • 158.79 • Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 • Ibs/bbl PS Memo 14-03 9,980.92 • 499.05 • 2,2,4- Trimethylpentane 540841 4 Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 5 COLORADO of Public Hadt t•cnwro.nmartt Permit Number: E -05C\ AIRS ID Number: 123 /9'(-1/ onql [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. V!, Signature of Legally Authorized Person (not a vendor or consultant) C6426(11 Date Kathy Steerman Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/aped Colorado Department of Public Health and Environment Telephone: (303) 692-3150 COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 0212017 6 I Hello