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Home My WebLink About20181771.tiffCOLORADO Department of Public Health & 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 758 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 EL Gas, Inc. - Triple Creek Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Public, Re -10,w ec•. PL-(IR(C P), cLL.jST), Ob-11-I$ 1,v4(5 RICH! 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer 2018-1771 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Triple Creek 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 Et Gas, Inc. Facility: Triple Creek Production Facility Well Production Facility SENE of Section 8, Township 5N, Range 66W 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 twenty-two (22) three-phase, high -low pressure (HLP) separators, (ii) low pressure gas venting from two (2) vapor recovery towers (VRT) and one (1) gas buster, (iii) ten (10) 400 barrel condensate storage vessels, and (iv) four (4) 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 18WE0046, 18WE0047, 18WE0048, and 18WE0049 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 1 ff A D O Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Harrison Slaughter Package #i: 373392'. Received Date: 1/1/2018 Review Start Date: 3/1/2013 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Triple Creek Production Facility Physical Address/Locatio SENE quadrant of Section 8, Township SN, Range 66W, in Weld County, Colorado Extractioh Oil &'Gas„ Inc:. - 9F8CI.. 'Weld Type of Facility: Exploration & Production Well Pa What industry segment? Oil &Natural Gas Produ>on.&Prbeeg Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? en Mnnnzlde (cr Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SENE '1 8 5N 66 Pa iculate Matter (PM) gne (NOx & VOC) AIRS Point H Emissions Source Type Equipment Name Emissions Control? Permit S Issuance N Self Cert Required? Action Engineering Remarks 001 -GontiensateTank Condensate Tank Ye5., • 18WE0046 - 1 Yes ' Permit • initial . Issuance Section 03 - Description of Project Extraction Oil & Gas Inc. (Extraction( submitted an application requesting and '. gas welt produc₹ioneqgvessels �facility b g permit ,dondensatestora a at a new synthetic minor oil located in the ozone non-attainnentarea, This source is APEN required because uncontrolled actual VOC emissions are greaterthen 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 are greater than 2 tpy (Colorado Regulation Part B Section tl.D,2,a), This permit will require public commentbecause the operator is requesting new synthetic minor limits to avoid other iequirementsand the change in VOC emissions as a result of the projectaregreaterthan2Stpy..'i - _ -__-- - -- -_-- Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? "Requesting Synthetic Minar,PerJ 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. Ye 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? " "f 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) 111 CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory Section 01- Administrative Information 'Facility AIRS ID: 123 9F8C 001 Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description) Emission Control Device Description: Ten (10) 400barr�,e1$zed roof condense.. Emisatonsfrorrr Thissource are controlled by enclosed flare(s). Requested Overall VOC & HAP Control Efficiency %) 9 Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput Requested Permit Limit Throughput = 4,201,346'; Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 5:041,615: Barrels (bbl) per year Potential to Emit (PTE) Condensate Throughput = 041615 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 247&.1 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 1.470 scf/bbl Actual heat content of waste gas routed to combustion device= Requested heat content of waste gas routed to combustion device = 15,308 MMBTU per year 18,369 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device= 18,369 MMBTU per year Section 04 - Emissions Factors & Methodologies Pollutant Uncontrolled (lb/hr) VOC 73.44452153 Benzene Toluene 0.328378'. 0 2575151 Ethylbenzene 0.00745244 Xylene 117094 , n-liexane 224 IMP 0.0582161_._ _.. Will this storage tank emit flash emissions? Pollutant Uncontrolled Controlled (16/661) (Ib/bbl) (Condensate Throughput) (Condensate Throughput) Emission Factor Source SMIIIIM:31a. - ®- MOE= • .liCE ... 5.706E-04 4.474E-04 2.03455E-04 Pollutant 1.012E-04 (Ib/MM Eta) (waste heat combusted) (Ib/bbl) (Condensate Throughput) 0.0000 0.0000 04680tt- 2.478E-0 MIDEME Emission Factor Source 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 321.69 268.07 13.40 321.69 16.08 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0.00 0.62 0,52 0.52 0.62 0.62 2.85 2.37 2.37 2.85 2.85 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 2876.59 2397.16 119.86 2876.59 143.83 2255.83 1879.86 93.99 2255.83 112.79 65.28 54.40 2.72 65.28 3.26 1025.74 854.79 42.74 1025.74 51.29 21370.20 17808.50 890.42 21370.20 • 1068.51 509,97 424.98 21.25 509.97 25.50 Section 06 - Regulatory Summary Analysts Regulation 3, Parts A, B Regulation 7, Section XII.C, D, E, F Regulation 7, Section 011.6, C Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS 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 requlres a permit Storage tank is subject to Regulation 7. Section XII.C-F Storage Tank Is not subject to Regulation 7, Section XII.G Storage tank is subject to Regulation 7, Section XVII, B, 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 sub(ect to NSPS 0000a Storage Tank is not subject to MACT HH 2 of 5 K:\PA\2018\ 18WE0046.CP1.xlsm Condensate Storage Tank(s) Emissions inventory Section 07 - Initial and Periodic Sampling and Testing Requirement Does the company use the state default emissions factors to estimate emissions? i_-_Nsh If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. 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 le.g., no new wells yoj brought on-linel, then it may be appropriate to use an older site -specific sample. ki If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. N/A - operator developed site -specific emission factors 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 Anal PA i Thbheet.ebittegta Voli:mekrisFlow:; ..fsrfonnation,.th "(i) Heat -Content.. (in 60Rlne/bbl)= 4. Based on the coverlets, (APEN} Addendum form Included Notes S. The operator cant -armed the ambientpressu opetatorwas prayided With a draft'permit an AIRS Point It 001 Process a 01 Section 09 - Inventory5CC Coding and Emissions Factors 5CC Code nkVapor " stream or -the "Hash"stream from theta nk sae Stendf /}8er fofetationof both•streamg it we#,4 ye%.the differencetnemtssiont,urban comparing helene lmom (0 'smallenougtc e be:¢snsrdered pe8lID' b) lien usingthe Tanbvapor"; iream.Thl's minor offerenceholdsirve wlr ri<comparngth e FtAPemissi :ves;elsniecethatishatetfte operatorpresentedttte pplfnatlou. c ,' -specific pressurizoduondensete santple,ablotne atureand,pressere afthe sampte,ar,'e 133°Fapif. �bt(pear) =5.470,283332 scf/bbl produce tolheladlity.The list oiwelts is avail bl ... comment.The operatorreviewed.the d ocument D' rsffltlrfllp ,Pt:O%(343 Uncontrolled Emissions Pollutant Factor Control % PM10 0.00 0 PM2.5 0.00 0 NOx 5.90E-03 0 VOC 3.04 95 CO 2.69E-02 0 Benzene 1.36E-02 95 Toluene 1.07E-02 95 Ethylbenzene 3.08E-04 95 Xylene 4.84E-03 95 n -Hexane 1.01E-01 95 224 TMP 2.41E-03 95 Units b/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput b/1,000 gallons condensate throughput 6/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput b/1,000 gallons condensate throughput 3 of 5 K:\PA\2018\18 W E0046.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Co!or atla Re ulatlon SPans A and B -APEN and Permit Requirements Iron oro rs m 31.0 nuar:.,4rlo;. lloin Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3, Part A, Section II.D.e.all 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total faci2ry uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 1OTPY (Regulation 3, Part B, Section ll.e.3)? yon I00vrt in:Rtated ffrtt tat too 3o in the Nomatiaiomenl Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutantsfrom this Individual source greater Man TPY (Regulation 3, Part A, Section 11.D.l.a)7 s the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicab0ity)? 3. Aretotal facility uncontrolled VOL emissions from the greater than 2TPY, 000 greater than 5 TPY or CO emissions greater than 5TPY (Regulation 3, Pane, Section 11.0.2(1 Seurre requi:ca a tsartoit Colorado Regulation 7, Section 011.0-F 1. Is this storage tank located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located et an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? I Storufo tank isnrbieoi to Restoration 2, Section 011,00 Section 01LG3 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section %11.62— Emission Estimation Procedures Section 0t0.13 —Emissions Control Requirements Section 0ILE—Monitoring Section 0li.F—Recordkeeping and Reporting Colorado Regulation 7, Section 000.0 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash"(e.g.storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year 0O0? I`.ker tge Tony is not sub.er3 tc 0¢gobs:ion 7. betting 01130' Section 011.6.2 -Emissions Control Requirements Section 001.0.1 -General Requirements for Oh Pollution Control Equipment- Prevention of Leakage Section 011.0.2 -Emission Estimation Procedures Colorado Regulation 7, Section 0V11 1. Is this tank located at a transmission/storage facility? 2. Isthis condensate storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor statlonaor natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOCt 'Storage tank is sub . 40 ctmtiueon 0, Soc.tatMilk 3, ca E C.3 Section NV00.B-General Provisions for air Pollution Control Equipment and Prevention of Emissions Section OVII.C.1- Emissbns Control and Monitoring Provisions Section 1VII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stablllzed" liquids? latorago rant is sul. Mr, RoquieLon't, Section P..0.2 Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60. Subpart eb, Standards of Perform...I. volatile organic Lisold Storage Vessels 1. Is the individual storage vessel capacity greaterthan or equal to 75 cubic meters (ma) halo soap 2. Does the storage vessel meet the following exemption in 6o.111h(d)(4(? a. s the vessel has a design capacity less than or equal to 1,589.874 ma [-10,000 BBL] used for petroleum' or ondensate stored, processed, or treated prior to custody transfer' as defined In 60.1130? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1084? 4. Does the tank meet the definition of "storagevessel"a In 60.1110? 5. Does the storage vessel store a"volatile organic liquid (V0L)"sas defined In 60.11101 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa Ton.7 psi] and without emissions to the atmosphere (60.110b(d)(2)It; or b. The d.igri capacity is greeter that or equal to 151 tl' (^9S0 a0L) end stares a liquid with a maximum true vapor pressure° less then 15 kPe (00.110b(b))7; or c. The design capacity is greater than or equal to 75 M' ("472 BBL) but less than 151 ms (`950 BBL] and stores a liquid with a maximum.. vapor pressure° less than 15.0 kPa(60.S10b(b))? Yes Source Requires an APEN. Go to the next question Go to nett question Source Requires a permit Continue - You have Indicated the site attainment status on the project summary sheet. Continue - You have indicated the faccBty type on the project summary sheet. Source is subject Continue - You have determined facility attainment status on the Project Summary sheet. Storage Tank is not subject to Regulation 7, Section 0I1.G-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 our.. subject to parts of Regulation 7, Sections %VI I.B&C. Go to the next question Starage Tar.. is riot Subject 70 eLSPs Kh Subpart A, General Provisions 550.1126- Emissions Control Standards for VOC 460.1130 -Testing and Procedures 460.1156- Reporting and Recordkeeping Requirements 460.1166- Monitoring of Operations Nor 40 CFR, Part 60, Subpart 0000, Standards et Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located et a facility In the onshore oll 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, 00.4 between August 23, 2011 and September 18, 2015? 3. Are potential VOL emissions' from the Individual storage vessel greater than or equal to 6 tons per year? 4. Does thls condensate rtoragevessel meet the definition of"storage vessel' per 60.5430? S. Is the storage vessel sublect to and controlled In accordance with re uirements forstorage vessels In 40 CFR Pan 60 Subpart Kb or 40 CFR Part 63 Sub art HH? (Storage Tani. is not subject to NSPS 0000 Subpart A, General Provisions per 060.5425 Table 3 460.5395- Emissions Control Standards for VOC 460.5413 -Testing and Procedures 460.5395(g]- Notifiatlon, Reporting and Recordkeeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements 460.5417 -Control Device Monitoring Requirements [Note: If a storage vessel is prevlsusly tlalarminad to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.53654x)(11 even if potential nor emissions drop below 6 tans per year] 40 CFR Part 60 Subpart 00005. Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification. or Reconstruction Commenced After September ns, 2015 1. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 1e, 2015} 2. Does this condensate storage vessel m et the definition of"storage vessel"' per no 5450a0 3. Is this condensate storage vessel located at a facility in the crude oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Is the storage vessel sublectto and controlled in accordance with re uirements for store a vessels in 40CFR Part 60 Sub art Kb or 40 CFR Part 63 Sub art RH? I'tr,'raga Tank {s cost subject :n NSPS 00O0o 40 CFR, Part 63. Subpart MAR NH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(x)1211; OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(al(3)1? 2. la the tank located at a fealty that IS major' tot HAPs? 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does Os tank meet the definition of"storage vessel with the potential for flash emission's per 63.761? 5. Is the tank sublect to control requirements under 40 CFR Part 60 Subpart Kb or Sub art 0000? ISYr: ne Taank is notsubjeet. to MACS MN Subpart A, General provisions per 463.764 (a) Table 2 463.766 -Emissions Control Standards 463.773 - Monitoring 463.774- Recordkeeping 469.775 -Reporting RACY Review PAR review is required If Regulation 7 does not apply AND If the tank is in Me non -attainment area. Hthe tank meets both criteria, then review PACT requirements. Disclaimer This document assists operators with determining applicability of Canso requirements o/the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not rids or regulation, and the analysis it contains may not apply to a particular situation based upon Me Indhddual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'Veconanend,""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 teens of the Clean NrAct and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Continue - You have Indicated the source category on the Project Summary sheet. Storage Tank Is not subject SOPS 0000 -This tank was constructed prior to or after the applicability date. Go to the next question Go to the neat question Go to the next question Storage Tank is not subject NOES 0000a. 'Continue - You have indicated the source category on the Project Summary sheer. Storage Tank is not subject MAC] III -There are no MAC tiff requir meats for tanks at area sources CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0046 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Ft Gas, Inc. Triple Creek Production Facility 123/9F8C SENE SEC 8 T5N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Tank 001 Ten (10) 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 tntrIt eN Nab3 z Heah 6 LTIVVOTIrht l Page 1 of 8 3. his per sh if the3 or open • f the so 'ce for which this permit was issued: or ope ion of this source within 18 months uanc onstruction ermit or the date on which such ion acts '" w sched d to•mmence a et forth in the permit application ocated wi` `" is p i ii) dim .n inu- constructsor 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 Condensate Tank 001 --- --- 16.1 2.9 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shalt 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 Condensate Tank 001 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 tlepotr, r4 Envirbrvnerit Page 2 of 8 ulation Number 3, Part B, Section Facility Equipment ID A ' Point Process Parameter Annual Limit Condensate Tank 001 Condensate Throughput 5,041,615 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shalt 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 Pollution Control Division oepar ne, d denSh 3 E vir nmet,t Page 3 of 8 met within 90 days of the date that 14 he sto a to s co ed •` this p it a subject to t venting and Storage Tank Emission eq egulati_ ._ ber 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. 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 Aix Pollution Control Division 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 COLORADOAir Pollution Control Division ^uzpertY-nerd cr Pth hie lath y E; vtroru=.ser Page 5 of 8 Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Ft Gas, Inc. Permit for condensate storage vessels at a new synthetic minor oil and gas well production facility. !COLORADO Air Pollution Control Division 'lent of kdAr3 e6 ^.. J E'nvircli?teot Page 6 of 8 1) Th permit h=� .er e re• ed to .. or th- oc ssing ti for this permit. An invoice for these fe x ill b-,��. � ued ter � per�� t is is��'•d. T permit hold shall pay the invoice within 30 days to :;: t oice wi It 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) 001 Benzene 71432 2,877 144 Toluene 108883 2,256 113 Ethylbenzene 100414 66 4 Xylenes 1330207 1,026 52 n -Hexane 110543 21,371 1,069 2,2,4- Trimethylpentane 540841 510 26 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 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source CO 1.13x10-3 1.13x10-3 AP 42 Chapter 13.5 VOC 1.28x10-1 6.38x10-3 ProMax 71432 Benzene 5.706x10-4 2.85x10-$ ProMax 108883 Toluene 4.47x10-4 .2.24x10-5 ProMax 1330207 Xylene 2.03x10-4 1.02x10-5 ProMax 110543 n -Hexane 4.239x1O3 2.12x10-' ProMax 540841 2'2'4 Trimethylpentane 1.01x1O4 5.06x10-6 ProMax COLORADO Air Pollution Control Division netr+f Pure Fu.i3'Sh €r Envimr,tmtrt Page 7 of 8 based t 'the enclosed flare control efficiency of e estab ' ed using ProMax and a site -specific aine.'a; om th;:f,utl-t of the l . ; pressure separator for the Triple Creek 1/06/ 7. Th P-42 Chapte ,?3.5 CO emission factor (0.31 lb/MMBtu) was lb/. e , -- ter_ :rt conte 78.08 Btu/scf and a gas -to -oil (GOR) ratio of 1.47 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 APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit -fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2i(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, n -Hexane and Total HAPs NANSR Synthetic Minor Source of: VOC 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 DepartmentL"( lEf i C£ t& EgviroP.n' t Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Harrison Slaughter. PackageR: 373392. Received Date: 1/9/2018 Review Start Date: 5/2/2018 Section 01 - Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Triple Creek Production Facility Physical Address/Locatio SENE quadrant of Section 3, Township 5N, Range 66W, ii Weld County, Colorado Type of Facility: Exploration&Production WeliPad What industry segment? Dii & Natura'Qas Prodbcton &Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ® n Monoxide (CO) iculate Matter (PM) ne (NOx & VOC) Extraction Oil: & Gas, Inc. 123 9F8C Weld Quadrant Section Township Range SENE -; 8' Section 02 - Emissions Units In Permit Application AIRS Point 6 Emissions Source Type Equipment Name Emissions Control? Permit ti Issuance rt Self Cert Required? Action Engineering Remarks 402 lroduced WaterTahk --;.Produced Water Tank Yes 18WE0047 1 Yes. Permitlnihaf. issrtance Section 03 - Description of Project Extraction Oil & Gas Inc. (Extraction) submitted an application requesting permit coverage for produced water storage vessels eta new synthetic minor oil and gas well; production facility located m the;Pi,one non -attainment area, This source is APEN!required because uncontrolled aetual.VOC emissions are greater than 1 tpy (Colorado Regulation 3;.Part A Sectionll )Additionally, )source is permit T ctual VOC emissions from all APEN required sources at this facility are re' $3.a. th is ' mitre Uire t q d because uncontrolled a, greater thah 2 tpy (Colorado Regulation Part R Section II.D.2.a . i. This permit will require public com_ mentbecause;the opt project a re greater than 25 tpy Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting SynthetictvSnor Permit -eggesting new symhetic minor limits to avoid other requirements and the change ih V Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? --No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No. Yes SO2 NOx CO VCat 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) NOx CO VOC PM2.5 PM10 ❑ ❑ TSP HAPs ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory Section 01- Administrative Information acility AIRs ID: 123 9FSC 002 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: 4)400 barrel fixed root produced water storage vessels connected via liquid manifold. Emission Control Device Omissions from this coo Description: Requested Overall VOC & HAP Control Efficiency .%: i5 outraged by enclosed fla 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 liquid produced= 36 scf/hbl Actual heat content of waste gas routed to combustion device Requested heat content of waste gas routed to combustion device = 1,303,658 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 1,564,390: Barrels (bbl) per year 64390: Barrels (bbl) per year 1496. Btu/scf 70,210 MM BTU per year 84,252 MM BTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device= 84,252 MMBTU per year Section 04 - Emissions Factors & Methodologies Wil this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled )Ih/bbl) )Ib/bbl) Emission Factor Source (Produced (Produced Water Water Throughput) Throughput) VOC 2.62E-01 1.310E-02 7.00E-03: 3.500E Ben ene Toluene 0.000E+00 Ethylhenzene 0.000E+00 Xylene I..... /`-_ 0.000E+00 n -Hexane 224 IMP i •.......' 0.000E+00 2,20E-02. 3.100E-03 Pollutant Control Device Uncontrolled Uncontrolled )Ib/MMBtu) (Ih/bbl) (waste heat combusted) (Produced Water Throughput) PM10 PM2.5 0,0000 0.0000 NOx CO A.068W 3.662E-03 3100. 70E-02 Section 05 - Emissions Inventory Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 204.94 170.78 8,54 204,94 10,25 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 2.86 2.39 2.39 2.86 2.86 13.06 10.88 10.88 13.06 13,06 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled jibs/year) Ohs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylhenzene Xylene n -Hexane 224 TMP 10950,73 9125.61 456.28 10950.73 547.54 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 34416,58 28680.48 1434.02 34416,58 1720:83 0.00 0,00 0.00 0.00 0,00 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, Cl,,C.3 Regulation 7, Section XVII,C.2 Regulation 6, Part A, NSPS Subpart 0000 NSPS 0000a (See regulatory applicability worksheet for detailed analysis) Source requires a permit Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Storage tank is subject to Regulation 7, Section XVII.C.2 Storage Tank is not subject to NSPS 0000 Storage Tank is not subject to NSPS 0000a 1,303,6, Barrels (bbl( per year 2 of 4 X:\PA\2018\18W E0047.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to esthnate emissions? If yes and If there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, ifthe facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use n older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. N/A - emissions are calculated using the state default emission factors. 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 effidency of the combustion device based on inlet and outlet concentration sampling Sectier 08 - Technical Analysis Notes 1. Camhuctib a nswe calcula.eo-.4s ne the state heatcontent nd GORva(zoo may 2, The operotorwasprovided w�thadmftp rmic ana AP ,rtdJne. AIRS Paint it 002 Rand heateoeuvntf Section 09 - Inventory 5CC Coding and Emissions Factors The operators .ssels using the state default emission factors to ase ma Process # KC Code 01 4-04-003-15Fixed Roof Tank, Produced Water, working+breathing+flashing losses nos a rld every, Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP primary emirs Uncontrolled Emissions Factor Control % Units 0.00 0 lb/1,000 gallons liquid throughput 0.00 0 16/1,000 gallons liquid throughput 8.72E-02 0 I6/1,000 gallons Squid throughput 6.24 95 lb/1,000 gallons Squid throughput 3.98E-01 0 lb/1,000 gallons liquid throughput 1.67E-01 95 16/1,000 gallons liquid throughput 0.00E+00 95 lb/1,000 gallons Squid throughput 0.00E+00 95 lb/1,000 gallons liquid throughput 0.00E+00 95 lb/1,000 gallons liquid throughput 5.24E-01 95 16/1,000 gallons liquid throughput 0.00E+00 95 lb/1,000 gallons liquid throughput 3 of 4 K:\PA\2018\18W E0047.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and Injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts and R-APEN and Permit Requirements ISourtc is in the Non Attainment Arcs ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulatlon3, Part A, Section ll.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located eta non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part 0, Section H.D.3.M) 3. Are total facility uncontrolled VOC emissions greater than STPY NOx greater than 30 TPY or CO emissions greater than 20 TPY (Regulation 3, Part 0, Section 102.3)? 'You have Indicated that source is in the M1on-Attainment,0rea NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than OTPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Is the operator clalming less than 1% crude oil and is the tank located eta non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part e, Section S.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part 0, Section ISo:vice requrcesa permit Colorado Regulation 7, Section MI 2. 5. is this tank located ate transmission/storage facility? Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facil'ity', natural gas compressor stations or natural gas processing plant? Is this produced water storage tank a fixed roof storage tank? Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? IStorage tcnk It aubjecs 4o Regulation 7, Section OVA, 0, C.1 & CO Section XVII.t— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Seater XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. Storage tank iv sufyer4 to iteyulatiun 7, Sevtion XVII.C.? Section 1MI.C.2 -Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60, Subpart 0000, Standards of Performance for Crude 011 end Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2i between August 23, 2011 and September 18, 20152 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of storage vessel'' per 60.5430? Storage TAM is not suhjurt L5 NSPS 0000 Subpart A, General Provisions per 460.5925 Table 3 460.5395 - Emissions[ontrol Standards for Von §60.5413 -Testing and Procedures 460.5335l6)- Notification, Reporting and Recordkeeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements 460.5417 -Control Device Monitoring Requirements [Note: Ile storage vessel Is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 50.5355(e)(ei even If potential VOC emissions drop below 6 tons per year[ 40 CFR, Part 60, Subpart 0000a. Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification. or Reconstruction Commenced After September 18.1015 1. Was this produced water storage vessel constructed,reconstructed, or modified( see definitions 40 CFR, 60.2) after September 18, 20157 2. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5930a? 3. Is this produced water storage vessel located at a facility in the crude oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 4. Are potential VOCemisslons' 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 re ulrements for store a vessels in 40 CFR Part Sc Subpart Kb or 40 CFR Part 63 Sub art HIS? ISsprage Yank is trot suhJeut 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 Air Quality Control Commission regulations, This document (not a rule or regulation, and the analysis it contains may not apply to a➢articular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document end the language of the Clean Air Act„ ifs 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 "recomnrend,""may," "should,"and 'Pan," is intended to describe APCD interpretations end recommendations. Mandatory terminology such as "must" end 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Ye0 9LIs'ed tr'nor Yes 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 faulity type on the Project Summary sheet. Go to the next question Source is subject to parts of Regulation 7, Sections )(V11.0&C. Go to the next question iNa C53,I Source is subject to at provisions of Regulation 7, Sections 0 & C Yes Nd ,. Yes......'i.''. NA 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: 1 8WE0047 Issuance: 1 Extraction Oil Et Gas, Inc. Facility Name: Triple Creek Production Facility Plant AIRS ID: 123P9F8C Physical Location: SENE SEC 8 T5N R66W 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 Produced Water Tank 002 Four (4) 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.eov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air pollution Control Division *."ern d P b1 l ier"h.'v E ;:n.mrm ent Page 1 of 7 3. is perms all :� e owner ator of t = • e for whi this permit was issued: structio .tion or on of thi urce within 18 months the ?:te issuance of thi onstru on permit or e date on which such or a sty sch uled to men as set forth the permit application iated with i -rmi :l ' ontin ° ins u '""i n for a p ii •' 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 Produced Water Tank 002 --- 2.9 10.3 13.1 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 Produced Water Tank 002 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 Orp=sttn r t :•r F;eek C, E^vtt r;r rt Page 2 of 7 r inspectn reque ber 3, Part B, Section acuity ' S Equipment ID Point Process Parameter Annual Limit Produced Water Tank 002 Produced Water Throughput 1,564,390 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • - 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 shalt 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 Et MAINTENANCE REQUIREMENTS 14. 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 OftM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COLORADO Air Pol tiortControtDivison Dvartmem of Public E ei th.v E_bir,oYrrie°tt Page 3 of 7 15 'is not wire• . con. '"„t initial tin ;,ected by the Division or ess otherwise �' o er state or fe• era requiremen 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) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section 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 Page 4 of 7 this acti . =-;.peratiosource al authorization of the om the riting dance wi r' the provisions of 25-7- C Reg tion ber , : 3, �. rt B, Section G. Final authorization era n or act co ' '�-nces and has .:-n verified by the APCD on orming r . espe e co • "s = permit. • f -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 Et Gas, Inc. Permit for produced water storage vessels at a new synthetic minor oil and gas well production facility. COLORADO Air Pollution Control Division Ytrent or 4'ubiio Health & E^,viror;mei;t Page 5 of 7 f this pe uance: pay fe-e • it is ued. T the . andc:. F F.y t (Regulation Number 3, Part A, Section VI.B.) m for this p it. An invoice for these lder shall pay invoice within 30 days result in tion of this permit. 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-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 10,951 548 n -Hexane 110543 34,417 1,721 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/bbl Controlled Emission Factors lb/bbl Source NOx 3.66x10-3 3.66x10-3 AP 42 Chapter 13.5 CO 1.67x1O2 1.67x10-2 AP 42 Chapter 13.5 VOC 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 N0x 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 Air Pollution Control Division veY r,,nt or b f5e ^L LTiirorirrivIC Page 6 of 7 AP the ass at fore thear term e res. Please refer to the APE °:-xpi :tion dat "�r each emissions point rding pecific expirat date call the Division 7) mi fulfills t = uire d a v i i • -r ecting the tank and associated control device per the Colorado Oil and Gas Conservation Commission applicable. 8) This facility is classified as follows: rule 805b(2)(A) when Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, n -Hexane and Total HAPs NANSR Synthetic Minor Source of: VOC 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 E:YI?ktb€+.rz rforthh& f'Tr ror'vnerit Page 7 of 7 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Harrison: Slaughter 373392 1/9/201&" 5/3/2018 Section 01- Facility Information Company Name: Extraction Oil & Gas, Inc. '! County AIRS ID: 123 Plant AIRS ID: 9F8C Facility Name: Triple Crank Production Facility Physical Address/Locatio SENE quadrant of Section 8, Township 5N, Range 66W, in Weld County, Colorado Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natura€Gas Produrton & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Bon Monoxide (CO) Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SENE 8' 5N 66 isolate Matter (PM) ne (NOx & VOC) AIRS Point if Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 003 ""' "! E+," Separator Venting VRT Gas Venting Yes::" 18WE0048 1 ': Yes ...: Permit Initial Issuance" Section 03 - Description of Project Extraction Oil & Gas Inc. (Extraction) submitted an application requesting permit coverage for vapor recovery tower (VRT) and gas buster venting at a new synthetic minor oil and gas well " production facility located in the ozone non -attainment area. This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy (Colorado Regulation 3 Part ASection ll,8.3.a):;Additionally, this source is permit required_ because uncontrolled actual VOC emissions from all APEN required sources at this facility are' greater than 2tpy ,(Coloratrio Regulation Part 8 Section il.D.2.a). This permit will require public comment because the operator is requesting new synthetic minor limits to avoid other req result of the project are greater than 25 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? RequesttngSynthe irements and the change in VOC emissions 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. Ye Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) N SO2 NOx Is this stationary source a major source? If yes, explain what programs and which pollutants her( SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) CO VOC PM2.5 PM10 TSP HAPs NOx CO VOC PM2.5 ❑ O PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory Seaton 01 -Administrative Information FaaIM AIPs ID, SectonO2-Omit. ..Description Details County Tor°(2)405 recover,. Detaled Emeslons Unit Description. Emission Control Device Description "�IladlryaCoes, Requested Overall VOC& HAP Control Efficienry °6: grec Plant United Process Parameter a':w'rr Gas meter Seaton 03 -Processing Rate Information for Emissions Estimates Potential to Emit (PTE) Throughput= 25.0 MMscf per year Process Control (Re.945,) ISV PU P�deq P Vnt ih Uncontrolled and controlled emissions used to establish requested permit Emits are based nnkon when the IOU Iypased ll.e waste gas volume that is routed to the Ravel Secondary Emissions- Combustion De*e(s) for Air Pnllutlon Control scf/bbl Description ertr sample r.a, obtained *551,10,55e,ypor r-ccove on 15/05 rptra n tic.. 5,1 yeas busUr,. , Ib/hra,. and gas heating valucererebb d nopat,t25 va#,,framIll,ProMon simufaton t were axeldwish pc Displacement Equation Ex • MW•Xx/C Vapor Volumetric Flovirate MW O0 MMSCV/day .751'. Ib/Ib-cool Ihrhr Hydrogen Sulfide C02 N2 thane 348:. ethane isobetane 8623 28. isopentane ryclomentane n -Hexane cyciohesene Other hexane. hepOnes mettrytrycichexane 224TMP Benzene Toluene thylbenzene Xyknes CB. Heavies 83 643' Total VOC 366 63 313.99 plrupiz ro and presnuro are 6l'F ar 3 ftr ans., icula:o a thz rig. domcnsitmOs - opals v ,,cs Emission Factors Pollutant Separator Venting Uncontrolled Controlled A./mown promo -0 (Gas Throughput) (Gas Throughput) Em¢slan Factor Source VOC 110022.6002 2200,4520 Benzene Toluene 130.9122 2.6182 8.507 0.9909 3.0214 30.8721 0.)224 ethylbenzene Xylem 49.5178 151.0711 1693.6058 36.1213 224TMP Emission Factor Source Primary Control Device Uncontrolled Uncontrolled /b/MMetu) 10/Moan (Wain Heat Combusted) (Gas Throughput) 0.000 0.000 183.555 836.795 NOx aaseo -: .........ono° Section 05- Emlssbes Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (inns/year) (tons/year) Requested Permit Umits Uncontrdled Controlled (tons/year) (tons/year/ PM10 PN4i5 VOC CO 0,00 0.00 0.00 0.00 0.60 0.00 000 c.00 Don ow 0m aoo 0.00 1375.28 S 11.62 1375.28 7 1046 n422 aaz 10 6 10.46 Hazardous Alr Pollutants Potential to Emit Uncontrolled (fos/year) i Actual Emissions Uncontrolled Controlled Ilt./yearl Ohs/yea/I Requested Permit Umits Uncontrolled Controlled PM/y..1 Ilbs/yearl Benzene Toluene Ethylbenzene Xylene n -Hexane 229 TRAP 3272.81 13133.. 27.66 3272.81 65.46 1237.95 10.46 1237.95 4.76 3776.78 1596,15 31.92 78 75,54 92390.15 17893.56 357.88 42340.15 846.80 933.03 381.44 7.63 9x13.03 18.06 5eatono6-Regulate Summa ry Ana Is Regulation 3, Parts A, B Regulation ',Section XVII.B, G Regulation 7, Sectbn XVII.B.2.e (See regulatory applicability w00.50,t for detailed era lysls) Source requires a permit Source Is subject to Regulztbn 7, Section %VII...; 0 The control device for this separator h not subject. Reguation 7. Seaton %VII.B.2.e Odin odor ceostaflrgfemlalone front Displecemerd Equation Ex. Qe Mw a Xx/C low 5:Tallb/Ib-cool Hydrogen Sulfide 0.00 0.55 methane 093 .Mane tE.32 Propane 50k5 isohrrtane neop etane !]2 9enrane 7 cyclopentane 033. n -Hexane 132 clohexane 012 Other hexane, 0 09 heptanes 1.28 methylcT'cbhexane au 224TMP Bemene0.03 Toluene 0.33 Ethylbenzene 0 94 Xylenes 012 CBv Heavies 0.55 Total VOC Wt% 85.64 Criteria Pollutants Pottial to Emit Uncontrolled (tons/year) } Actual missions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Wnits rm Uncontrolled Corltrolled (tons/yea) (tons/Pearl Po25 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0.10 0.00 0.00 0.00 0.00 0.00 0.00 2.29 0.92 0.92 2.29 7-29 9 11.64 669 2170.96 10.46 442 442 10.46 Hazardous Air Pallutanh Potential to Emit Uncontrolled /2.//0511 Actual missions Uncontrolled Controlled Ilbstearl Rbs/marl Requested Permit Umits Uncontrolled Controlled llbz/yv.r) /bs/se.,) Beruene Tobin Ethylbemene Xylem Z. TEAR 3276.1 15546 27.7 3276.1 65.5 1241.0 520.5 10.5 42387.1 17913.7 3583 @387.1 900,2 350.4 7.6 900.2 18.0 k\PA\2015\15W E0048.CP1alsm Separator Venting Emissions Inventory N nOl-InMal and Pedotlk Samprima and Tess aulrements Using Gas Thmug3potm Monitor compliance z the company use site specific emission rs based on agaassamplem estimate nst Ye Ms ample should represent the gas outlet of the equipment covered under this AIRSID, and should have been collectedopyea r ar of the application received dare. However, if the facility has not been modified(e.g. new welh brought can -line?, then d may he appropriate to use an older si pecificsample. If no, the permh coal condin an "Initial Testing Bequlremene to collect a site -specific gas sample horn the equipment being permitted and conduct an emssion factor analysis to demonstrate that the emission factors are less than 0103001 to the emissions hctors 00300 shed with rho appt#ion. le permitretl emissuin of VOCgreater thanaequa to 90 ton per year? EISIETZ If. , the permit will conMn: "Inhhl Testing Requirement"to collect asite-specific .3 amp. from the equipment beingpermitted and conduct an emission factor analyse to Nmoristrote that the emission factors are less than or equal m the emissions factors ...shed with Mh application. •A "Pedodeeeting Requiremem° m collect a site -specific gas ...from the equipment being permitted and conduct an emission factor anahosis m demonstrate that the emission factors are less than or equal to the emissions factors 000blished with this appiiwtion on an annual basis. Will the operator have a meter installed and operational upon startup of this point3 teo If no, NC permit will contain a condition that requires the operator to cakulate gas throughput using the liquid throughput until the meter '¢ Installed and operational (not to exceed 180 days). The condition will use the "Volume of waste gas emitted per BBLof liquids throughput. (scf/bbg value le section 03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? eyes, Me pe w8com and initial compliance [e st condition to demons..the destruction efficiency of the cornbnn device based on inlet and outlet wnxntraton sampling Nrsion.o4-Leuhnlgpl..lwl..-t_.,.,._ 5, Tr L13100 fay, greit5i0n, ftgrusepamtmeare calclatedungthh displacementoquo Hon from the EPA mNssu ltoorimayhnpr enl:Pro&am Fublrcaewd-Vplmne ll, Ciaapte03Displacement Equation 1104-911rx=Q'MW°volcl.Thrsmlcu.uon methodology Iv Incl..tothe rigit1,0 Section 04 of theanaiyss and smended 30 usedhr comparatvepmpo500life operatoftalolated emissions using a 00334 ovnulotion used on as. specific gas analysts obtained from thcodtl0 of thevpor tococeiy.towetsoonl/0611] The Opersterued? Oile% values item theyicanaysta'to speel30 a gas stream hi the Pr0Nlac3lmhl.00 The Prossey simulation was then used to - determine- It, lb/Mites of each coie.neMnthesas...basedon e; standard'volumetric % H1,0Oht 15 eeitscf/da Po g p fi I loo tlwdotogy ars milable N5e5Dan05 above TheI sulting from the ...mess' .uatioe ss.pt224IMP aro slightly fn. conservative - than the values obtained from fhe PION1aXSIMIlidliOn. However, the dlferencoa the valuesbooi.1lenough tobdwoikkred03g0glble.Asaresult it was determinedthe values estieNed using the Pro ax simulation...acceptable for permitting purposes.. 2. Basedon the anpl of es, a flow meter was matalkdatxh s facility to measurethmonlretyeftho VH!md gas bosresgasventedham both VRTsandthegas buster.mk flowmeieris looted downstream of Mevapor recovery wits at this facility too used tocomprea Verandgashustesgasard tooth it et the ale. 0pel'me.mistawmeeesa thus used tmeasue:torsiVHS anagasbusler gas thew footed to the-Nere. oGdber during VRU downtime. Buedon the flowmeter loohon, the operator wig not MCdtntnctVR000tow lmemmds In eonl.ttienwHhfi0w mater data to demonstrate tompassige withate permit Tons. The flowww0803ed byahe Nov meter will besot(reign010000miretradaigcompiarlce.. thepermsttmits. S. the application indtetoethe flosrnatersarel,,0011 0 andape,Wnatateoo000lity: 4, NeIi loihaknor periodic to ifid22apachlteslswerelncluded irk the is requhed to dodo. insiMe ....checks per G. OP... anmp4n. In the ev ntykeile emissions are obsetved,theoperetoek requlredioenher Nate, 3 egmpmettammediatefy and conduct repairs or conduct a formal method??opadty test In the event vivble emissions are observed tlttoughai metheci22, the operator is required hi immeda 2ydondbe[ repairsnrshid inthe„ sit if reNirs mnnot he conducted immediately,. Once this reroH mpfaoca demonsizatiorsthan a one-time method .22, this nigalwniphancedemomtra'wnn rotnecoaryn the perms Ad,0natty; the daily vise* emission checks and subsequent requltemen1,00, 1010 ml 01 no 1 von. bserved l5aaiHitf mion-going compldemonsHatfdD,sop^imMnmeth. 22 opacity emtinglsnot Fog uircdin thepermrC 5. The he.°tere used t000l 013. ROA and C0eM&son was obtained from the Poleax simuimion 6.the operator saequestmga30 l.i,uchon efficiency t the thermatovideer controlling emisv s, As a result,. oPeratioo S. Typcallytlrcrtnalo,ddhers rere33000000 maintain a minimum combustion dwmbet temper[melnordertodemooso-arethecon eel deyke ismeetlogthe requestedeomtvoikeotS0 try(usually greater H ,00* that's derimiuo-medln practice Nrough Nidafad, periodicshrkioting:However, Meopenmrmdim.dMotttiedehum'oneifideehrgh esed by Mntheio too fumton of th000Necozer-It h 0 100temtent tit farad,mbupenbriie dfadsfrom othotgases addned bythtitdoe aweBdstl.Testderzedme ofthegumibe mmbuzh-m chamberrewlt in Meliigherdatruition.fiuehry:rgontedforMrs Merma[ondvenrt shouldhe odfosr than the cantem0kossssce00053033 00 thermal mmmlIn Nata dice rmttetioiesuyp.menhlfuel to combust the wastegss Frthe-.m maintain of thevaper temtceyto to gass m(269 eml03oiomhoo vin I' gher loan Ne dotom, retuofwaste�zs msly t000 rono-dkdby tlrermaloxNizersIde, eari000100ratasdH'wno-1 01require ppiem Nl 0el m maintain the combustion chamber order tom comp.. mbus result if was demrmmedtlaem um cooihusGonchamber mture would t be a None limit for this Normal ade stead; the cabaftesting andopeatmn andmafdhnance cequiredtarthethermal'. oxidizer ssufiuenbfdcdemmntra 11 be required todemontrate Fhdine mat±cod aer Is capable of.. 0 the denim. comp onent00 P0031 ua0bn was specifiedusngthe1001,01,0igh, Od p icgravty of the Cith compoioo,i n the pressurdedlirsample used Lot t econdom..., vessel ern.;5in h m theproMaxsimulation closely mirror.eresults using traditional racolanpnmethods, 'Iwasd ..mined the values..t sip cityihq deco nery 0teto-were acceptable Tlin 0,3Corod 30010Rasngie. 311,01010 rrs lAtIlizedto contaal ...us from both the VIT.. hunterand ) dieing 'flip downdm0 meopetat0y 00Mir Qitxamtien 0 0001 ntthemodelwassetml2.lgs"u. 10,The gas3uterisloratedapstvam of the 00300 a ruuitudng Ne-.-- 00-mposit100 hem Me VRimesgma1051 sro000103mh the03*dgastamte aconsnvatrve est 12. Theppem[or wasp.Vdedwtt Beenepermit and APETtredine mrevlewprwrtopuWI comment iheopertw reviewe ll1120cOme'Nand expressed they had no commend. Nihon 09- Invenmry5CC Coding and Emission Factors KC Ol Sf Flares n effa.nq dun pg Uncontrolled EMISSIOnS Pollutant Patter Control% Ple2.5 0.00 0 SO NIN g.6 0 VO CO 03080 Benzene 130.. Toluene 425.39 S thyibenzene .52 98 Bylene 351.02 98 mHexane 224 TAP 36.12. U. 3/0181501 s1F b/m3SC0 b/MMSCF b/toms b/Mle56 b/NIMSCF lefAMISCE b/MM5CF 1/3333511 b/MM5CF b/MM5CF 3004 k\PA\2018\18WE0040CPleism Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and a- APEN and Permit Reoulrements [ne 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 ll.D.1.a}? 2. Are total facility uncontrolled VOC emissions greater than 5TPY,NOx greater than 10TPY or CO emissions greater than lorry (Regulation 3, Part I, Section 11.0.31? You have indicated that wanela in the Nen.Attaimnent Area NON -ATTAINMENT 1 Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section II.D.1.)7 1 a)7 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)7 'Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? 'Source is subject to Regulation 1, Section 0011.0.2, G Section XVII.a.a - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XN1.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? Iihe control device for the separator is nut svbloct to Regulation 7, Section 0011.5.0.e section 0011.5.2.e -Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requrements of the Clean Air Act, Rs Implementing regulations, and An Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substRie for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations. and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend,""may," 'should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as °must" and "required" are intended to describe controllurg requirements under the terms of the Chan Air Act end Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Yes ., S e Re quires an APEN. Go to the next question Ve#,source Requires a permit The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e CONSTRUCTION PERMIT Permit number. Date issued: Issued to: 18WE0048 Issuance: 1 Extraction Oil &t Gas, Inc. Facility Name: Triple Creek Production Facility Plant AIRS ID: 123/9F8C Physical Location: SENE SEC 8 T5N R66W 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 VRT Gas Venting 003 Low pressure gas venting from two (2) vapor recovery towers (VRT) and one (1) gas buster. Low pressure gas is routed to and controlled by a Questor Q5000 thermal oxidizer 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 COLORADO Mr Pollution Control Division pCJtment O! Publitt hleWtn C blvitor;i'i,,tt Page 1 of 8 Division. dition mit. s ca ' s the s. F•., eto m A sel" rtific ay ion. (Reg b n fo taine• mbe operator's to compli nd guid line ce on h. t www.c bility to s 180 day o self -c ado. • o ectio • ) y complia ay r ult in revo ify compliance a' acific/cd•he/air with the on of the uired 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 Gas Venting 003 --- 2.3 27.5 10.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shalt 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 AIRS Pollutants Equipment ID Point Control Device Controlled ICOLORADO Air Pollution Control Division Departmeelt Cif PubIC 4 ieu:':h f ErriirrArriert Page 2 of 8 PRO rATIONS AN .� S 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4. ) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT Gas Venting 003 Natural Gas Venting 25.0 MMSCF The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the vapor recovery tower (VRT) and gas buster and routed to the Questor Q5000 thermal oxidizer 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 COLORADO Air Pollution Control Division UelArtrsent :31 P bl Hearn & enviresr;rnwtt Page 3 of 8 st have a>> - destructio f .�, cy of at l t 98% for 14. Upon s" artup of this "poin the owner or operator s a " of ow a"`most recen opera ing and maintenance ((&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. A source initial compliance test shall be conducted on this emission point to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The operator shall also demonstrate the thermal oxidizer (TO) achieves a minimum destruction efficiency of 98% for VOC. The operator shall measure and record, using EPA approved methods, VOC mass emission rates at the thermal oxidizer inlet and outlet to determine the destruction and removal efficiency of the thermal oxidizer (process models shall not be used to determine the flow rate or composition of the gas vented to the TO for the purposes of this test). The natural gas vented and thermal oxidizer combustion chamber temperature shall be monitored and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results, in units of lb VOC/MMSCF waste gas, by the allowable waste gas volume for that averaging period as indicated in the process limits section of this permit. Volatile Organic Compounds using EPA approved methods. 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) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or COLORADO Air Pollution Control Division Depirt,nentof Pub1 vEsi.IYrtent Page 4 of 8 tons per ear or mor or any no a rep • "• utant. ore, a c r is less, actual emi e level rep ns of five ed on the If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section 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 COLORADO Mr Pollution Control Division De rt! ent ct puuit lie(Sxhit E VROM12-4 Page 5 of 8 rato bef it, the o 'vision's perator of .F' urce may 24. - lion 25 7 4.7(2)( ;1 C.R. •wires .t all sour requir • file an Air Pollu f ` Emission muser th.. - ,e f . ns and ad •'r = n. 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 Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas Inc. Permit for VRT and gas buster venting at a synthetic minor oil and gas well production facility. !COLORADO 3 Air Pollution Control Division Dzoutirk.,:i Pbulic Eiei; his Envirornment Page 6 of 8 Notes t•! rmit Hold_ ! t the" permit iss 1) The requi to • ees for th -" time fo s peit. An invo : for these fees ll be iss after t •ermi ssued. e permi lder sh. •ay the invoice w ' n 30 days e inv.' ure _ invoie-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 (lb/yr) VRT Gas Venting 003 Benzene 71432 3,273 66 Toluene 108883 10,635 213 Ethylbenzene 100414 1,238 25 Xylenes 1330207 3,777 76 n -Hexane 110543 42,341 847 2,2,4- Trimethylpentane 540841 903 18 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 NOx 183.56 183.56 AP -42 Chapter 13.5 CO 836.8 836.8 AP -42 Chapter 13.5 VOC 110,022.6 2,200.45 ProMax 71432 Benzene 130.91 2.62 ProMax 108883 Toluene 425.39 8.51 ProMax 100414 Ethylbenzene 49.52 9.9x10-1 ProMax 1330207 Xylene 151.07 3.02 ProMax 110543 n -Hexane 1,693.61 33.87 ProMax COLORADO Air Pollution Control Division epartmera of PubVx Meath b Er;iirnrriert Page 7 of 8 S # �: ollut Uncontr. ed Emission (lb/ CF) Contr s°� Emission ` (lb/ • o F) S • e 2,2 Trimethy pen ane Note: The controlled emissions factors for this point are based on the thermal oxidizer control efficiency of 98%. The emission factors listed above are based on a ProMax simulation that utilizes a site specific vapor recovery tower gas sample obtained on 11/06/2017. The sample temperature and pressure are 61°F and 4.35 psig respectively. 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/MMscf using a heat content of 2,699.34 Btu/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, benzene, n -Hexane and Total HAPs. NANSR Synthetic Minor Source of: VOC 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 Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 6: Received Date: Review Start Date: HarriaomSlaughter ,373392 • f9/,2tz�°l; Section 01. - Facility Information Company Name: Extraction -CO Gas, Inc County AIRS ID: Plant AIRS ID: Facility Name: Tatite eek ProdO„ctiooTacitity Physical Address/Locatio SENE quadrant of Section 8, Township 5N, Range 66W, in Weld County, Colorado Type of Facility: exploration&PtIoddctt iWellWhat industry segment?',bit,&• Natural Gas PodE Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? [on Monoxide (CO) 9 Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range 66 irritate Matter (PM) Erie (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit 6 Issuance 6 Self Cert Required? Action Engineering Remarks 004 ,_,3as,r ,,,,L,,..., .SeparatorVenting Produced'qas Ve g YSWE0044 1. , , ;, Yes . Permit Initial Issuance- : „1,11,33 .r. . -. - _ ::i 3 ? 3 ,iii,,,. ' - ... %%AAR,: Section 03 - Description of Project Extraction Oil & Gas Inc. (Extraction) submitted an application requesting permit coverage for lovd3,pressure produced gas; venting a well production facility located in the ozone non -attainment area This source iS APENrequired because uncontraried(actua VOC emrssi (Colorado Regulation 3 Part A Section II.B.3 aj. Additionally, this source is permit required because uncontrolled actdal tlt7C emissions S this fac'II are rea'terthan2t Y g py (Colorado ,,„ , anon Park; „Sect€on N [9 2a). permit will require public comment becaus It`of the,project are greater tharn:25 Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? RegUeajj )heticminor oil and gas re greater than I tpy m altAPEN,required sour€es ew- synthetic minor limits to-avo) ttUti�c 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. Yes - Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANS(?) Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory YNon 01 -Administrative InRarmatinn Facilby Al63IO: ..on 02- Egwpmer0 D2tt1PHon Details Detailed Emissions Unit Description: E.ss on Control Device Description: pre 4067606E L rdmligd b)ta q emd Overall VOC&HAP Control Efficiency%: Limited Process Parameter 166776 Gm meter yA Session 03- Processing Nate Information for Emissions Estimates Requested Permit limit Throughput - Potental to Emit /,El -throughput= 60.0 Nmoscfper year Process .nt of (Neryding) Equ coded-witha Art N vaumm s eqgUncontrolled and controlled emissions used to establish requested permit limits are based only on when me VRU is bypassed li_e secondary Emissions - Combustion 0066/2 (s) for Air Pollution Control Separator as Heating Value. ]92J:: Btu/zcf Volume of waste gas emitted per BBL of"',s 1 liquids throughput ..//fij sWt. Section O4 Emissions factors &Me.odologles r 005,606 s. based. 342865)7 Sraf Wpnal meth64 eta' ILWzting Vapor Volumetric Flowrate MW Displacement Equation Fx=Q•MW•kr/C 42. MMscf/day 1519 Ib/Ib-cool Ib/hr Owneen CO2 NZ thane ethane propane Ba,ut e n -butane dsapeMane opentrine cyclopenmne n Hex wdohexane :..:1,43;00 82 heptanes methvicyclohmane 224TMP Benzene Toluene Ethyroenzene x762778 .4. Heavies ,;.1161. Total vac 630 43 3'72.61816 Emission Factors Pollutant Separator Ve.ng Uncontrolled )Ib/MMsc11 Controlled (6/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 33232.3426 1703.6469 Benzene Toluene 37.0690 36.2225 7.5179 17414 37045 EUrylbe6 36 Xylem 0118 6107174 17.1576 032. 12.3943 0.3132 2247MP Emission .ctor Source Prima's/Control Device Uncontrolled (Ib/NINSm) Ib/MMsef (Waste Combusted) Uncontrolled (Gas Throughput) 0.000 PM2.5 8.900 Co 602.237 Section O5- Emissions Inventory Udtemfa Pollutants Potential. Emit Uncontrolled (53775/year/ Actual Omissions Uncontrolled Controlled (tons/year( (lens/rear) Requested Permit Umd6 Uncontrolled .6trolled (tons/year) Mons/72671 MOO PM2.5 SCM NO VOC CO 0.00 0.00 600 0.00 0.00 atm p,p0 oda 0.00 0.00 B.O0 at. oleo 000 ova 165&47 832.22 17.60 165&4] 33.16. 18.07 9.61 9.61 Hazardous Air Pollutants76/1anPollutantsUncontrolled P ntafr.l to E /Ibs/year) Actual Ems dons Uncontrolled Cantm (Ins/rear/ (I6s/year7 Requested Permit Um 6 Uncontrolled trolled Controlled (17/yea) //62/7em/ Benzene Toluene EMenv 4418.1ylene n -Hexane 229 TMP 5224.. 2.8.98 55.58 522614 104548 5113.35 2720.04 54.40. 5113.35 love 15107 80.36 161 151.07 3.02 156307 830.11 16.61 1561.07 3122 371..05 19779.48 395.59 31183.05 7..66 1029.46 .7.62 10.95 1029.. 2099 Section 06- 526516tery Summary Ana Regulation 3, Parts A,0 Regulation Section %VII.B,G IRgulatdon 7, sedan XVII.8.2.e (See regulatory appliea6ldy warla6eet for detailed analysis) 3ource requires a permit Source is snblestto Emulation 7, Section X101.8.2,6 The control device for this separator h riot steeled to Regulation 7, section XVII.3.2.e 5530,5'.36 mkv)3503 673/625016 166667676///3271 these) Displacement Equation Ex= Q•rvMy•xx/C Mw .9162 Es/lb-mod weight% CxYgen 3,43 methane ethane propane isobutane rhbuMne isopentane n -pentane cyclopentane n -Hexane cycmhemne Other hexanes heptanes methvlcyclohesane 224-3,48 Benzene Toluene Ethvlbemene %ylenes CB• Heaves ' 14.06 21:53 0.15 Total Voss V.& __..0:,D 131100 600,1 Crdteia Pollutants Potential to Emit Uncontrolled (inns/year) Actual missions Uncontrolled Contmlled (ions/year) (to6s/36ar) Requested Permit Umla Uncontrolled Controlled (tons/year) (inns/year/ PM1O Ps sox NOx CO 0.00 oar, o.00 ow 0.00 0.00 0.00 3.96 2.'/11 2.11 3.. 3.96 882.79 17.66 33.19 9.61 189875 18.07 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual rotrsions uncontrolled !rolled Illes/yead R16/Marl Requested Permit..mi6 Uncontrolled Controlled (16/year/ (Ibs/year) Benzene Toluene Etin6bemene Bylene nNexane 5223.9 2778.9 511345 2720.0 54.4 5113.35 102.3 154.8 1.6 13478 8292 16.6 1558.88 31.2 372363 19807.8 396, 37236.25 744.7 2of4 IC\8.201.18W E0049.CPladsm Separator Venting Emissions Inventory Section 07 - Mita, and Periodic Samegng and Testing Require's,. Using Gas Throughput to Monitor Compliance Does the company use:te specific emssionfactors bases on a gassamale to estimate emissions? _Nt This sample should represent the gas outlet of the equipment covered under this Ails lo, and should have been collected within one facility has not been modified Ie.g, no new wells brought on-line), Men It maybe appropriate to use an older site-speciFlc sample. a!the app tion received date. However, if the If no, the permit will contain an Mnitul Testing Requirement" to cogect a sitmspecific gas sample from the equipment being permitted and conduct an emission factor analysis M aemonstmte that Me emrssbn factors are less than or equal to the emissions factors established with this apprcatbn. Are fat ity-wile permitted emission of VOC greater than or equal t090 tons per years Iles, the permit wBl contain: -An NOM Testing Pequimmem" to collect site -sped. gas sample from Me equipment being permitted and conduct an emission factor analysis to demonstrate Mat the emission factors are less Manor equal to the emission factors estabished with Mis application. A"PeaOdk Testing Requirement' to collect a sitezpecif gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate Mat the emission factors are less than or qual torte emissmns factors established with this application on an annual basis. Will the operator have a meter M.S. and operational upon startup of this point! Yes If no, Me permit will condin a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput"' (sd/bb0 value In section 03. Does the company request a control device elfickncy greater Man 95%for a flare or combustion devices If yes, the permit will contain and initial compliance rest condition to demonstrate the destruction efficlency of the cambntim, device based on inlet and outlet conrentstun sampling section 00 • Technical ayssNgies 1 Traditiomlly,mmissiopsfs,Mpepatamrsare- Me ifisplacement equation from tIne EPA ErnissicineProgramhl' VoiumetkChiptttliDisplaquation (3tr4-3j15x 4 / ) ovcu=ton • •-metnodofo6'Y-'ntudeabs the rgbt«as¢dit 04 Vii analysis and tipsdea tote used for comparative prposes. Theopetetofcakpit 'ssonsuslt Plotazshtt hdoq baspp tiprt gas analysis;ofiined from the outlet of Me Si p p CM Do tbwrt£lTPoIle Vic VCf Y 1(>3h 18 TFeopcsmr a-ctl Mcrro e°G v0. uosf -Meg ly mspec fya„a.-Pp W?h P hg 1 01atipn The Pro Max srmula.onwx Mee dlb/hr ms ex z hie entlntltogd;sstofelt(Mtneo sbvativ v I rvMume - fDt 603835e MMsd/day Oteresutnsem s 5frbtt each oTbupltton rneModologyaieayila6 nSecP on05 ibwe<The ematororezlsltAgrtom Me dspkttn en eq p dcnxenc and y e;'aie,sbginiy meeoruervat't Man Me aloes do dinedHowever,.n -- gligiblc. Asaretilt rag Me' cam the Pro Ma,:imu.atvn. Med'Hzrenrc_ the value's sma enougM1tohe cdnis dere3ne ,'cwasdeermined Meva ues nl'makdusi Pralines sirnirlaleonwere acceiptableb permitturgpurposes.• • 2. Based on the a pelication, afinwmetei was installed c"'ryo /ofte toed from the low of the HL se ozTh's Row meter is located downstream of the vapor NIVRU)atOts- t cad at measure low preswre nerve heat 'ucEtythat needare used tornmpaidme pressure rdsin. onjuncs and nuteTm the? a=spipeline,. iameo:meter:manse zel mthheps.tis. The he Sow gas asuredythedmMetn"rma oxidiser during VRIJ Mmec:nninacam<don Meth Me per Meagan, the operator dunntn«drorcr.eauroe�mdthe;Fcom:'acnntn conjunction with now meter cap to demerrz."ice compran<n.wm mbP nlihiFs-meuewmeMnted nvmeflow me.er will.,e.ethde„t for ern erns pr _wrm rrfrtlimits. 3. The application indicates Me No.MeteE___ at.lid and operat,nafat eMs Mein, A Neither in,al nor periodic methodd mpagay tests were included •n Me perm, hes. the operator-sregrired to do daily vabtezmminx, checks per Me opead g andmaintenancepan Inthe event visible maimlon<re observed, the operator's re,Nreil to either Mut ntheegWpmmfRmn dote s arty to e ws'blre -observe Miguel the method -22 0 o redto tet'y conduct rat iftpn of bengpd05tedmrnedatcy.Sinne l,s ra6 a onthanea mint -time method22, tits 'ndalm paanen demrs necessaryin MepermrtA Penalty, Me daily visible emsz,an samoru complianceton r+not Mimi, and.ubse to i a6Mgntk f ns are phservedlsasulac moo o 6Fdinpriatce' demonstration, so perkdic method' 22 opacity testing) regced-in the permit q eq emmts,,,,,, heat content Situpe:IJOP dCO emissions obtained Mom lrcP mniuon. fi The operators regemtinge 78Mdestnictim efficiency for th- Mermaloxidice cph00(00tmeo ?Asa rmutt nxnbalcopppt petit be reyuteP to aemenstrete the thermal oxidizer- s Rabic ofineenns Mild n efficiency duel rag 7. 'catty t`ermaipMdfzenamregtp d so mar. era n n n F_mber-temperature Oder todeit, ENHsec n No( deuce is meeting Me requested combos:ten efficiency (usually er than 9V ISa' d monstrotcd'npsctice - u5h� snap rrod csntk 3at'M3 P- m hInh' netts evedhy MNshetindm nimbus nchamber d ed trf, edes p'""}* r'''''''' des eoftr ciwneifide ed for oothermal andiae td bent dtn.is mbusto.... d" o.'d'c''nNat' ottequfesilpppn !_gas. er, Me r wprersdtewaste gas stream Il"p�9.55 Btu/scf)ssgnificantly higher than ii ttpt content ofwe's'7 ssb. z typica y ed by emm u t< e of ergo onto maloe x is c eanddahyd__ is ts)C nchambm tiVtI combos cob stern c.. nher- temperature wouldof rmrthm ttorM,et thermaloxidiser. m, Instead, e nw� q e p .on one n,0. me *eq redv me ternatn e:e , �amee or rem n„rc, rn.t d.e xap,o _afar ., a, ton.o n,°n singeing aaab. w M, Me Proanar a:<ear„�mwspn.. --- - 00. The <nemtlsepm r eed usngMe malecuu .,ndsi vrrot VtV m xedlq d mplen Ircondensate'stomgeveese(em¢tons• 3mcecacns.n from the PtoNlaxcmn ncbse�lyiniirorMecexulcu ngtiadII Icalwaoon tw sactetn ramWva uezu m.oz eCFyMeoecanPitromwere..0..a•=t0.. - - - ]] The operator ,d cared Mea3Mg-ie coal osM-servo! xd mcono-ol<m ns4pm both the VaT/gas baste an W - pastors annn3V Vacmncme 12 TM1 p car onfrmd Meambiessfpressureofti,e_modei was see to lV psa ]3. Tice operethrwasprovdedwpM adraRpem,tand APEN red ere rorev oub'c comment The operaeviewd the shcwnmrfrand expmssedthey had mama, Section 09- Inventory SCC Coding and Emissions Factors AIRgPointone Process. [Cade 01 0.10.00[-60 Flares Uncontrolled Emissions Pollutant Factor Control vs Units b/MMSCF PM2.5 MOO lb/NAINS55 SOB Ib/MMSPFF NOP 132.10 0 ro/nonscF VOC N/MMSCF CO i 602-29 M/MMSCF Benzene 87.07 fla/NIIVISCF Toluene 85.22 55 M/MMSCF Ethylbenaene 2.52 05 IN/MN 5ykne 20.03 M/MMSCF n -Hexane 619.72 M/5155 224105 17.16 90 ro/MMSVP Separator Venting Regulatory Analysis Worksheet Colorado Oe ation 3 Parts A and B- seEN and Permit Requirements Source is in Thu lion-Attalnmoni 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.e)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, Nth, reefer than 10TPY or CO emissions reater than 10TPY (Regulation 3, Part B, Section 11.0.3 `feu have indicated that source la in the tuon.Actaicment Area (JON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section it D 1 a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5TPV or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)7 ISeurce requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? Ioource is subject to Regulation 7, Section RVil.E.2, G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section 0011.6 - Emissions Control Alternative Emissions Control (Optional Sectiont Is this separator controlled bye backup or alternate combustion device (i.e., not the primary control device) that is not enclosed? IThe combol devicefur the ocrocotor(snot subject to Regulation 7, Section XVn.E.2.e Section OVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substeuie for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any confect between the language of this document and the language of the Clean Air Act„ es implementing regulations, and Air Quality Control Commission regulations, the language of the statute orregulatbn will control The use of non -mandatory language such as "recommend,""may," "should" and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, bid this document does not establish legally binding requirements in and of ewe.. 5 rce Requires an APEN. Go to the next question Source Requires a perm t h :_ The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e CONSTRUCTION PERMIT Permit number: Date issued: Issued to: ADO n Contro 1 8WE0049 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Triple Creek Production Facility 123/9F8C SENE SEC 8 T5N R66W 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 004 Low pressure gas venting from twenty-two (22) three-phase, high -low pressure (HLP) separators. Low pressure separator gas is routed to and controlled by a Questor Q5000 thermal oxidizer 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 COLORADO Air Pollution Control Division Dptetment Pub₹it i•₹et;₹h v EnVIS OrJftet;t Page 1 of 8 Division. ditions. F mit. s ica s th e to Znn A sel rtific ay b ion. (Reg n fo taine• mbe operator's to compli., nd guid.., line ce on h •1 t www.c ectio bility to s 180 day - o self -c ado. ' o .) y complia ay r ;.ult in revo' ify compliance a' pacific/cd•he/air with the 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 004 --- 4.0 33.2 18.1 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 AIRS Pollutants Equipment ID Point Control Device Controlled COLORADO Air Pollution Control Division y'4ep rtme"d u! Pbu€ ' tieE;;th v EY' imn>neet Page 2 of 8 PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Produced Gas Venting 004 Natural Gas Venting 60.0 MMSCF The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the low pressure separators and routed to the Questor Q5000 thermal oxidizer 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 COLORADO Air Pollution Control Division .�%:tt -3e C 't Puh₹c E' it t fs Grairbr:nul Page 3 of 8 st have a destructio P cy of at t t 98% for OPERA 14. i p"on s artup of this porn , the owner or operators x a ""` of ow' "W'"e most recen opera Ong 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 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. A source initial compliance test shall be conducted on this emission point to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The operator shall also demonstrate the thermal oxidizer (TO) achieves a minimum destruction efficiency of 98% for VOC. The operator shall measure and record, using EPA approved methods, VOC mass emission rates at the thermal oxidizer inlet and outlet to determine the destruction and removal efficiency of the thermal oxidizer (process models shall not be used to determine the flow rate or composition of the low pressure gas vented to the TO for the purposes of this test). The natural gas vented and thermal oxidizer combustion chamber temperature shalt be monitored and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results, in units of lb VOC/MMSCF waste gas, by the allowable waste gas volume for that averaging period as indicated in the process limits section of this permit. (Regulation Number 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. 16. 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 this emissions unit in order to verify the VOC, benzene, toluene, xylenes, n -hexane, and 2,2,4-trimethytpentane 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 shalt 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 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.) Air Pollution Control Division ns occurs a flows: source lesons p in actual ef 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,J in ozone nonattainment areas emitting less than 100 tons of VOC or NO per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation 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. COLORADO Air Pollution Control Division Deixrt?' .r<C uC Public EEv n v e ,ia.orsnerx Page 5 of 8 23. less specifi e been de tion 25-7- e, the gen CD to be n pecific c• assure c contained i e with the is permit visions of 24. ery coand is not . Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas Inc. Permit for low pressure separator venting at a synthetic minor oil and gas well production facility. COLORADO Air PollutionControl Division h E-.RY4+rv�ix2=t Page 6 of 8 Notes t• rmit Hold t the permit iss 1) The rrmit holde s. requi to • R ees for t time fo g's pe it. An invo for these fee' ll be iss =fter t •ermi ssued e perms lder sh •ay the invoice w n 30 days e invure 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 (lb/yr) Produced Gas Venting 004 Benzene 71432 5,225 105 Toluene 108883 5,114 103 Ethylbenzene 100414 151 3 Xylenes 1330207 1,561 32 n -Hexane 110543 37,183 744 2,2,4- Trimethylpentane 540841 .1,030 21 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 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x 132.1 132.1 AP -42 Chapter 13.5 CO 602.24 602.24 AP -42 Chapter 13.5 V0C 55,282.34 1,105.65 ProMax 71432 Benzene 87.07 1.74 ProMax 108883 Toluene 85.22 1.7 ProMax 1330207 Xylene 26.02 5.2x10-1 ProMax 110543 n -Hexane 619.72 12.39 ProMax 540841 2'2'4 Trimethylpentane 17.16 3.43x1O1 ProMax COLORADO Air Pollution Control Division s for this p® eased on th tors listed . eased on press separator h :s sampl stained fr 2018. sampl =mperatur ,3 d pressu AP 42 3.5emissi oxidizer con efficiency :►simulation t utilizes a the P.wntown DT �.es C7 -5 -6 - re 84°F and 49 psi pectively. /MMBtu anMMBtu respectively) were converted to units of lb/MMscf using a heat content of 1,942.7 Btu/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, benzene, n -Hexane and Total HAPs. NANSR Synthetic Minor Source of: VOC 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 f f'ufa� b _ .h.'v LfuvUnn9ct Page 8 of 8 `\C-c6CSIi0\ Vick t.' —'-&,t. Condensate Storage Tank(s) APEN - Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid 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: 18WE0046 AIRS ID Number: 123 / 9F8C / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Triple Creek Production Facility Site Location: SENE Sec 8 T5N R66W Mailing Address: (Include Zip code) 370 17th St. 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. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 1 COLORA,p0 DeyarnmantOANic Permit Number: 18W E0046 AIRS ID Number: 123 / 9F8C / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action E NEW permit OR newly -reported emission source 0 Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) LI Change in equipment ❑ 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 a Notes: Please issue individual permit for condensate storage tanks. 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: 10/11/2017 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: El Exploration a Production (EEtP) site weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? Yes No p ■ Are Flash Emissions anticipated from these storage tanks? Yes No p ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No HI ■ 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 Fl ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No O ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 21 COt.0RADO tixpasnuetzl Jic Permit Number: 18W E0046 AIRS ID Number: 123 / 9F8C / 001 N/A [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information moiun Ye„ uesi ,inual Permit Etmi 5000#0 111111111: ondensate Throughp 4,201,346 5,041,615' From what year is the actual annual amount? Projected Average API gravity of sales oil: 61.2 degrees ❑ Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 11.2 D External floating roof liquid Manifold Storai essels in.Storage„Tank 10 x 400 bbls 4000 stallat1on Date of ecent Storage esse; orage Tan Before 10/2017 10/2017 ells .Servicei umber orare Tan lvameol an Battery PaS�tes `Only' Newt See Attached CI 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 40.414161, -104.794418 Operatoi Stack. ID.N6 Discharge Height Above .,,'. =rGround Level (feeE Temp (°F.) Flow Rate '3 34 ... «Mtlsec �1oc�) ,,#i!a j N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ID Upward ❑ Horizontal ❑ Downward O Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): Unknown 0 Square/rectangle Interior stack width (inches):. Interior stack depth (inches): El Other (describe): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 31 COLORADO iicabhfrEcrunnsab Permit Number: 18WE0046 AIRS ID Number: 123 / 9F8C / 001 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr Make/Model: 95% 98% % Waste Gas Heat Content: Constant Pilot Light: ❑� Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP separator, Vapor Recovery Tower Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 4 COLORADO Keaurn,.,n ,qy s.S }&fr Eamonabh 4.N Permit Number: 18WE0046 AIRS ID Number: 123 / 9F8C / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): VOC ECD. erall Requested Cori 7c�enc'y fe�uctton m emtsslpn5 95% • NOx CO HAPs EC0 95% - Other: From what year is the following reported actual annual emissions data? Projected VOC 0.128 tss>on ,ac lb/bbl ritena Pollutant Emtssiansa' Promax nnuaC Eimssio 268.072 . 13.404 ' 321.687 • 16.084 ' ontrotled: on %ye.w i NOx CO 0.05 0.3\ IbCO/MMBtu AP -42 2.373 • 2.373 • Benzene n7,Cntena Repattaite Pollutant 71432 Thssion 0.00057 missions•Inventor 2.847 . 2.847 • lb/bbl Promax 2397:161 • 119.858 • Toluene 108883 0.00045 - lb/bbl Promax 1879.858 • 93.993 • Ethylbenzene Xylene n -Hexane 100414 1330207 110543 0.00020 • 0.00424 • lb/bbl lb/bbl Promax Promax 854.786. 17808.486 . 42.739 ' 890.424 2,2,4- Trimethylpentane 540841 0.00010 lb/bbl Promax 424.978 • 21.249 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. iNDb 05I BSI 1§ 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 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 tOL139ADC n.•Vnm.•caa. Permit Number: 18WEO046 AIRS ID Number: 123 / 9F8C / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson Date Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, H.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-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 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 :c9L0RAC9 6I W E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil & Gas, Inc. Source Name: Triple Creek Production Facility - Condensate Tanks Part 1 Emissions Source AIRS ID2: ail, iciFcleioO Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 43745 TC-AIMS 1-9-11 11 05 - 123 - 43747 TC-AIMS 2-9-11 r 05 -123 - 43746 TC-AIMS 3-9-11 L 05 - 123 - 43749 TC-AIMS 4-9-11 /1 05 -123 - 43743 TC-AIMS C4-9-11 V 05 -123 - 43744 TC-AIMS C5-9-11 -- 05 - 123 - 43507 TC-COUNTRY CLUB WEST 1-9-11 /1 05 -123 - 43511 TC-COUNTRY CLUB WEST 2-9-11 11 05 -123 - 43506 TC-COUNTRY CLUB WEST 3-9-11 /1 05 - 123 - 43505 TC-COUNTRY CLUB WEST 4-9-11 .1 05 - 123 - 43508 TC-COUNTRY CLUB WEST 5-9-11 A 05 -123 - 43509 TC-COUNTRY CLUB WEST A2-9-11 0 05 -123 - 43504 TC-COUNTRY CLUB WEST C1-9-11 0 05 - 123 - 43510 TC-COUNTRY CLUB WEST C3-9-11 L1 05 - 123 - 43512 TC-HILAND KNOLLS 1-9-11 r 05 - 123 - 43517 TC-HILAND KNOLLS 2-9-11 ►1 05 - 123 - 43516 TC-HILAND KNOLLS 3-9-11 ... 05 - 123 - 43514 TC-HILAND KNOLLS 4-9-11 11 05 -123 - 43515 TC-HILAND KNOLLS C6-9-11 A 05 - 123 - 43513 TC-HILAND KNOLLS C7-9-11 /1 Footnotes: ' 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 2017_1212 Triple Creek Storage Tank Addendum E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Extraction Oil & Gas, Inc. Source Name: Triple Creek Production Facility - Condensate Tanks Part 2 Emissions Source AIRS ID2: ilfb/q}'$G Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 43748 TC-MOISER HILL 2-9-11 0 05 - 123 - 43742 TC-MOISER HILL 3-9-11 /1 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 2017_1212 Triple Creek Storage Tank Addendum - Number 2 Triple Creek Produced Water Tank APEN 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. RECEIVED JAS — 9 2018 APCD Stationary Sources This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number. 121j /g6CJ 06 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Triple Creek Production Facility Site Location: SENE Sec 8 T5N R66W Mailing Address: (Include Zip Code) 370 17th St. 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. 373388 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 1 I ;COLORADO Gap:nmmiaPublic I. BMOC mM • Triple Creek Produced Water Tank APEN Permit Number: l`' (-OE (MLR AIRS ID Number: l /ct C/ [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit 0 GP05 ❑ 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 0 Change company name ❑ Change permit limit ❑ Transfer of ownership3 OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - O APEN submittal for permit exempt/grandfathered source 0 Other (describe below) Additional Info Et Notes: Please issue individual permit for produced water storage. 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: 10/11/2017 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 0 Exploration EL Production (MP) site weeks/year 0 Midstream or Downstream (non EELP) site Will this equipment be operated in any NAAQS nonattainment area? Yes No el ■ Are Flash Emissions anticipated from these storage tanks? • Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • p Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes 12 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 F4 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No O • Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 21 ;COLORADO fiunAbinNimewM Triple Creek Produced Water Tank APEN Permit Number: tctADEOO-n- AIRS ID Number. /��cd�/ Co7_ [Leave blank unless APCD has already assigned a permit ≥# and AIRS ID] Section 4 - Storage Tank(s) Information lnual Amount Nor luci irons 1,303,658 1,564,3° From what year is the actual annual amount? Tank design: ❑✓ Fixed roof Projected Ikativ c, pC( cLdt° ca ❑ Internal floating roof Lw.all. I•kt)c- Ds/lbf I O External floating roof o74 i w� ` aratf a - Total Vol me o Install ttow p Mos � grade et oragto RP 'oz 'Hate of rs N/A 4 x 400 bbl 1600 Before 10/17 10/2017 ieo See Attached 0 0 0 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. s 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 40.414161, -104.794418 o rt N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) 0 Upward 0 Horizontal ❑ Downward ❑ Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): Unknown ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 3 I ;COLORADO DeparlsmUcd HeathbtmisenrtMM Triple Creek Produced Water Tank APEN Permit Number: ce) AIRS ID Number: /��L/ OO2 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information D Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 95% 98% Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP Separator Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 4 COLORADO 7x.� nn�x Enut�.oiu�a.N Triple Creek Produced Water Tank APEN Permit Number: Ic(2) (LE oy3il- AIRS ID Number: 12, /9 ESC/ O32 — [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 ( at ut nt Des ono Eoro tMe od(s � �a Overall Req es t V itr•I pct 4e uctio n emissions <_ , VOC ECD 95 NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected VOC 0.262 • IbVOC/ bbl PS Memo 14-03 m1ssT01.1k, V -e.. 170.78 • NOx Co Benzene O. 0td 0.31 "b1w,4tto Mr4 ) 71432 AP -‘11_ 2.•39 lb Benzene/bbl 0.007 9,125.61 • 456.28 • 8.54 • PS Memo 14-03 204.94 • L.gb 13.0ko 10.25. Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 • lb n-Hezaneebbl PS Memo 14-03 28,680.48 • 1,434.02 • 2,2,4- Trimethylpentane 540841 i;cal;v%cs ?or 0.tkaC}qc.A C 1. 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. VkiDS 05INits?, 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 1 ;COLORADO Health En.6u.uvoM Triple Creek Produced Water Tank APEN Permit Number: 1(butDEO3yR AIRS ID Number: I7_,&C1ESC/ (m'2- [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. kathu SteeYkkram 1/3/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordintor Name (print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit 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-B 1 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 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 6 COLORADO Dey.eaamaatPublic WANT 6P Mwnumrt E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil & Gas, Inc. Source Name: Triple Creek Production Facility - Water Tanks Part 1 Emissions Source AIRS ID2: j2 3 I IFRC66Z Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 43745 TC-AIMS 1-9-11 ►1 05 - 123 - 43747 TC-AIMS 2-9-11 LI 05 - 123 - 43746 TC-AIMS 3-9-11 ►1 05 - 123 - 43749 TC-AIMS 4-9-11 /1 05 - 123 - 43743 TC-AIMS C4-9-11 r 05 - 123 - 43744 TC-AIMS C5-9-11 11 05 - 123 - 43507 TC-COUNTRY CLUB WEST 1-9-11 /1 05 - 123 - 43511 TC-COUNTRY CLUB WEST 2-9-11 .1 05 - 123 - 43506 TC-COUNTRY CLUB WEST 3-9-11 /1 05 - 123 - 43505 TC-COUNTRY CLUB WEST 4-9-11 /1 05 - 123 - 43508 TC-COUNTRY CLUB WEST 5-9-11 r 05 - 123 - 43509 TC-COUNTRY CLUB WEST A2-9-11 /1 05 - 123 - 43504 TC-COUNTRY CLUB WEST C1-9-11 .1 05 -123 - 43510 TC-COUNTRY CLUB WEST C3-9-11 A 05 - 123 - 43512 TC-HILAND KNOLLS 1-9-11 .1 05 - 123 - 43517 TC-HILAND KNOLLS 2-9-11 A 05 - 123 - 43516 TC-HILAND KNOLLS 3-9-11 /1 05 - 123 - 43514 TC-HILAND KNOLLS 4-9-11 /1 05 - 123 - 43515 TC-HILAND KNOLLS C6-9-11 ►/ 05 - 123 - 43513 TC-HILAND KNOLLS C7-9-11 A Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 2017_1212 Triple Creek Storage Tank Addendum E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Extraction Oil & Gas, Inc. Source Name: Triple Creek Production Facility - Water Tanks Part 2 Emissions Source AIRS ID2: 123 A k Esc/ 062_ Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 43748 TC-MOISER HILL 2-9-11 ►1 05 - 123 - 43742 TC-MOISER HILL 3-9-11 I1 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: ' 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 2017_1212 Triple Creek Storage Tank Addendum - Number 2 c.cu ‘Fe.c).• c�St b \t% v • c,, r•-. o :\ . Triple Creek VRT Gas Venting 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.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: 18WE0048 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: VRT Gas Venting AIRS ID Number: 123 / 9F8C/ 003 [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. Triple Creek Production Facility Site Location: SENE Sec 8 T5N R66W Mailing Address: (Include Zip code) 370 17th St. Suite 5300 Denver, CO 80202 E -Mail Address': ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 1 Permit Number: 18WE0048 Triple Creek VRT Gas Venting AIRS ID Number: 123 /9F8C / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action 0 NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership' 0 Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Please issue individual permit for 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: VRT gas is combusted when compression is unavailable. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 10 / 11 / 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 ❑ No ❑ Yes ❑✓ No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 Permit Number: 18WE0048 Triple Creek VRT Gas Venting AIRS ID Number: 123 / 9 F8C / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information • Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy?❑ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 27000 SCF/hr Vent Gas Heating Value: 2699.3 BTU/SCF Requested: 25.000 MMSCF/year Actual: 10.566 MMSCF/year -OR- Requested: N/A Bbl/yr Actual: NA Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 48.74 lb/lbmol • VOC (mole %) 75.485 . VOC (Weight %) 85.643 , Benzene (mole %) 0.064• Benzene (Weight %) 0.102. Toluene (mole %) 0.175 • Toluene (Weight %) 0.331 • Ethylbenzene (mole %) 0.018 • Ethylbenzene (Weight %) 0.039 • Xytene (mole %) 0.054. Xylene (Weight %) 0.118 • n -Hexane (mole %) 0.746, n -Hexane (Weight %) 1.318 • 2,2,4-Trimethylpentane (mole %) 0.012 • 2,2,4-Trimethylpentane (Weight %) 0.028' Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 31 Permit Number: 18WE0048 Triple Creek VRT Gas Venting AIRS ID Number: 123 / 9F8C / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information N/A GeographicalCoordinates (atitudelLongrtude or tlTM) 40.414161, -104.794418 Unknown Indicate the direction of the stack outlet: (check one) Unknown Unknown Unknown ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 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: VOC, HAPs Rating: 200 MMBtu/hr Type: ECD Make/Model: Questor Q5000 Requested Control Efficiency: 98% % Manufacturer Guaranteed Control Efficiency 99.99% % Minimum Temperature: Constant Pilot Light: ❑✓ Yes 0 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 03/2017 4I PM Permit Number: 18 W E0048 Triple Creek VRT Gas Venting AIRS ID Number: 123 I9F8C/ 003 [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? El Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): verallx Requested Corm icienc r ctron rn emissions. SOX NO. VOC Thermal Oxidizer 98% CO HAPs Thermal Oxidizer 98% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) puree; (AP -42, Mfg. etc) PM SOX NO. 0.068 IbNOx/MMBtu AP -42 VOC \~JI.MM SCc Site Specific Sampling CO 0.31 IbCO/MMBtu AP -42 Benzene Toluene i3o.°ll 425.3 c tbl nnM Sc.( (rnw, Scc Site Specific Sampling Site Specific Sampling Ethylbenzene 4c1.52. Site Specific Sampling Xylenes 61. o1- mMr Site SpeWfic Sampling Uncontrolled (Tons6year)„„ 0.970 581.223 • 4.421 • 0.692 ' 2.247. 0.262 • 0.798 • 0.179 - 21.170' Controlled (Tonsfyear) ricontrotled 0.970 . 2.294 • ontrolled (l onslyear) 2.294 . 11.624 • 1375.281 • 0.014. 1.636 . 0.045 . 5.317. 27.506 10.460 . 0.033 • 0.106. 0.005 0.619 • 0.012 . 0.016 • 1.888 • 0.038 • n -Hexane I,ug3.el Site Specific Sampling 8.947 . 0.423. 2,2,4- Trimethylpentane �..lz lbjws r. Site SpetGc Sampling 0.191 • 0.004 • 0.452 0.009• Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Hpb OS(l $I V� 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I Permit Number: 18WE0048 Triple Creek VRT Gas Venting AIRS ID Number: 123 / 9 F8C / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Cam A�-� 6llhlzcA Signature of Legally Authorized Person (not a vendor or consultant) Catie Nelson Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑r 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 43OO Cherry Creek Drive South Denver, CO 8O246 -153O 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 cotcaADO 6 I A est Uri- leraT= 1\CL-(A' d o s ,toil tg vice c w,a,i 1 Triple Creek Produced Gas Venting 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: 18WE0049 AIRS ID Number: 123 / 9F8C/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Produced Gas Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. Triple Creek Production Facility Site Location: SENE Sec 8 T5N R66W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 E -Mail Address': ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 6ti Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 Permit Number: 18WE0049 Triple Creek Produced Gas Venting AIRS ID Number: 123 /9F8C / 004 [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' 0 Other (describe below) - OR • APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Please issue individual 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 is combusted when compression is unavailable. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 10 / 11 / 2017 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 days/week weeks/year Yes 0 No 0 Yes ❑✓ No ................. Permit Number: 18WE0049 Triple Creek Produced Gas Venting AIRS ID Number: 123 / 9F8C / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: El Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑� Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 41 5OO SCF/hr Vent Gas Heating Value: 1942.70 BTU/SCF Requested: 60.00 MMSCF/year Actual: 31.917 MMSCF/year -OR- Requested: N/A Bbl/yr Actual: NA Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 34.9182 tb/lbmol • VOC (mole %) 39.743 • VOC (Weight %) 60.057 • Benzene (mole %) 0.042 • Benzene (Weight %) 0.095 • Toluene (mole %) 0.035. Toluene (Weight %) 0.093 • Ethylbenzene (mole %) 0.001 • Ethylbenzene (Weight %) 0.003 • Xylene (mole %) 0.009 . Xylene (Weight %) 0.028. n -Hexane (mole %) 0.273. n -Hexane (Weight %) 0.673 • 2,2,4-Trimethylpentane 2,2,4-Trimethylpentane (mole %) 0.006. (Weight %) 0.019• Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) CI Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 3I Permit Number: 18WE0049 Triple Creek Produced Gas Venting AIRS ID Number: 123 / 9F8C/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Indicate the direction of the stack outlet: (check one) O atffi. ,e ID; N/A cal. Coordinates itude/Longitude or UTM) ,, 40.414161, -104.794418 Unknown Unknown Unknown Unknown ❑ 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: VOC, HAPs Rating: 200 MMBtu/hr Make/Model: Questor Q5000 98% % Type: Thermal Oxidizer Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency 99.99% % Minimum Temperature: Constant Pilot Light: El Yes ❑ 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 4 I i Permit Number: 18WE0049 Triple Creek Produced Gas Venting AIRS ID Number: 123 / 9F8Ci 004 [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? El Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): PM IXerall Requested Control Efficiency reduction "in emission SOX NO. VOC Thermal Oxidizer 98% CO HAPs Thermal Oxidizer 98% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) PM Uncontrolled (Tons/year) �ontrolledb (Tonsfyear) ncontrollec ;mss_ (Tons/year) ontrolled Tons%year) SOX NO. 0.068 IbNOx/MMBtu AP -42 2.108 • 2.108 ' 3.963 • 3.963 • VOC 5S,2S2. iy CO Site Specific Sampling 882.223 • 17.644 1658.472 • 33.169 • 0.310 IbCO/MMBtu AP -42 9.611 • 9.611 • 18.067 - 18.067' Benzene S1. ' ,ien5cc Site Specific Sampling 1.389 0.028 • 2.612 0.052 - Toluene Ethylbenzene 55. tZ iv,w1Stf Site Specific Sampling 1.360 ' 0.027 2.557 . 0.051 ' Xylenes Zb•o'� Site Specific Sampling 0.415 . 0.008 • 0.781- 0.016. n -Hexane 2,2,4- Trimethylpentane loly.�Z klrhm5cf Site Specific Sampling Site Specific Sampling 9.890 - 0.274 . 0.198 • 0.005- 18.592 • 0.515 0.372. 0.010. 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. 1-1175 OS At Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I Triple Creek Produced Gas Venting Permit Number: 18WE0049 AIRS ID Number: 123 t 9F8C/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. O94 c6It `o t Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-205 -Natural Gas Venting APEN Rev 03/2017 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd pp COLO RADA 6 l may I Hello