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Home My WebLink About20180085.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 1150O St PO Box 758 Greeley, CO 80632 December 19, 2017 Dear Sir or Madam: RECEIVED DEC 2 7 2017 WELD COUNTY COMMISSIONERS On December 21, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Carlson 15-D 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 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govfcdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer P�biic c.c., PLC MM ( TP), f -IL C3 -O, 1 3lig PWCER(CHr3Nnre.K) iafs$( l7 2018-0085 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Carlson 15-D Production Facility - Weld County Notice Period Begins: December 21, 2017 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Extraction Oil a Gas, Inc. Facility: Carlson 15-D Production Facility Oil and Gas exploration and production facility NENE Section 15, T5N, R65W Weld County The proposed project or activity is as follows: Applicant proposes to construct a well production facility and is requesting to vent 9.2 MMscf/year of natural gas from the 3 -phase separators and 4.3 MMscf/year of natural gas from the vapor recovery towers. 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): • 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 analyses, and drafts of Construction Permits 17WE1028 and 17WE1029 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: Oluwaseun Ogungbenle Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: NENE quadrant of Section 15, Township 5N, Range 65W, in Weld County, Colorado Type of Facility: Exploration -& Production Well Pad What industry segment? Qil&.Natural GasProductlarr& Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Larbon Monoxide (CO) [particulate Matter (PM) EOzone (NOx & VOC) - 123 9F62 Carlson 15-0 Production Facility Gas, Inc. Weld Quadrant Section Township Range NENE SN" 65W Section 02 - Emissions Units In Permit Application AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Vapor Recovery Tower(VRT) VRT Venting Yes 17WE1028 1 Yes Permit initial Issuance New point 002 Separator Venting Separator Venting Yes 17WE1029 1 Yes Pe€mit lnitI issuance New point Colorado Air Permitting. Project Section 03 - Description of Project In addition to the two emission pointsi emission points: condensate storage t Besides the two points covered by this bythis analysis, as part of this permitting action ? ft lcflnn=L7ei& Gas is al vessels), produced seater storage tank (2-400 bbl vesseels(. and three nati ",,,,, er equip " equipment -with reportable emission at this facility are covered under Ge' Emissions due to•Separatorventing and VRTventing were modeled usin u Fsed to calculate the separator venting emissions was based on a samp oiled VOC emissions i .oMax. There are twelve (12) HLP 3 -phase separators a otained from one =cfthe 12 wells serving this `facility. the VRT vented gas are -10.71toy; therefore, Permit 17WE1028 initially contained a VOC permit limit of 10.7 tpy In;their"comments On sulta nt, requested that the permit limit be rounded up to 10.8 tpy_ To address operator's concern (about the`: possibility of rounding do ues) and in keepingwnt, h l zsi j grounding policy (per PS Mern 9�) ck anged the VOC limit in the permit to 10.8 tpy: Section 04 -Public Comment Requirements Is Public Comment. Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? #o 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) 4 Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New. Source Review (NANSR) 502 NOx ❑ O ❑ ❑ ❑ ❑ 0 a o CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ O O S02 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑: O . ❑- O ❑.: O ©: Produced Natural Gas Venting/Flaring Preliminary Analysis Division Information Engineer. Oluwaseun Ogungbenle Control Engineer. Stephanie Spector Review Date: 12/05/2017 Application Date: 09/05/2017 Facility Information Permit No. 17WE1028 123 Weld 9F62 001 VRT Venting Extraction Oil & Gas, Inc. Carlson 15-D Production Facility NENE Section 15, Township 5N, Range 65W AIRs County # Facility # Point # Facility Equipment ID Colorado Department of Public Health and Environment Air Pollution Control Division Attainment Status PM10 Attainment PM2.5 Attainment SOx Attainment NOx Nonattainment VOC Nonattainment CO Attainment Potentially Located within EAC - determine attainment status of NOx and \ Company Name: Source Name: Source Location: SIC: 211111 Elevation (feet) x New Permit (CP1) Modification (Issuance #) APEN Required/Permit Exempt Transfer of Ownership APEN Exempt/Permit Exempt Notes Condensate from onsite gas busters flows to two VRTs. Flash emissions from the VRTs are normally routed to three vapor recovery units (VRUs) onsite. Emissions from the VRT are routed to an enclosed combustor during VRU downtime. Produced Natural Gas Venting/Flaring Preliminary Analysis Eauigment Description This source vents natural gas from:31{`tad'separator Emissions from this source are: 1Qb#6 t€ nclosed flare Colorado Department of Public Health and Environment Air Pollution Control Division Natural gas venting from a well head separator. Emissions from this source are routed to an enclosed flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Maximum Vent Rate I _ 12128 scf/hr RequestedThroughput (Q) 4.3 MMscf/yr 486.5 scf/hr I 0.000 MMscf/d I 0.36 MMscf/mo % Vented I 4% MW 46.430 Ib/Ib-mol Component mole % MW Ibx/Ibmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 0.9857 44.01 0.434 0.009 CO2 0.6 4878 2.44 N2 2.5117 28.013 0.704 0.015 N2 0.9 7912 3.96 methane 6.5204 16.041 1.046 0.023 methane 1.3 11762 5.88 ethane 20.3115 30.063 6.106 0.132 ethane 7.8 68667 34.33 propane 33.1432 44.092 14.6135 0.315 propane 18.8 164334 82.17 isobutane 7.4676 58.118 4.3400 0.093 isobutane _ 5.6 48805 24.40 n -butane 16.9893 58.118 9.8738 0.213 n -butane 12.7 111035 55.52 isopentane 4.2711 72.114 3.0801 0.066 isopentane 4.0 - 34636 17.32 n -pentane 4.3654 72.114 3.1481 0.068 n -pentane 4.0 35401 17.70 cyclopentane 0.2213 70.13 0.1552 0.003 cyclopentane 0.2 1745 0.87 n -Hexane 0.8395 86.18 0.7235 0.016 n -Hexane 0.9 8136 4.07 cyclohexane 0.0824 84.16 0.0693 0.001 cyclohexane 0.1 780 0.39 Otherhexanes 1.1615 86.18 1.0010 0.022 Otherhexanes 1.3 11256 5.63 heptanes 0.6956 100.21 0.6971 0.015 heptanes 0.9 7839 3.92 methylcyclohexane 0.1100 98.19 0.1080 0.002 methylcyclohexane 0.1 1215 0.61 224-TMP 0.0114 114.23 0.0130 0.000 224-TMP 0.0 146 0.07 Benzene 0.0783 78.12 0.0612 0.001 Benzene 0.1 688 0.34 Toluene 0.0731 92.15 0.0674 0.001 Toluene 0.1 758 0.38 Ethylbenzene 0.0117 106.17 0.0124 0.000 Ethylbenzene 0.0 140 0.07 Xylenes 0.0316 106.17 0.0335 0.001 Xylenes 0.0 377 0.19 C8+ Heavies 0.1168 122.706 0.1433 0.003 C8+ Heavies 0.2 1612 0.81 Notes VOC mass fraction: 0.8215 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control monthly limit assuming 95% control (lb/mo.) 214.5 10.7 1821.4 Mole %, MW, and mass fractions from analysis of Carlson Pad West VRT gas sample collected 07/28/2017. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+ based on the average MW on the analysis for the gas. Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Flaring Information Equipment Description Flare to combust low-pressure separator aas during VRU downtime. Manufacturer Questor Model Q5000 Serial Number TBD Gas Heating Value 2570 Btu/scf Throughput 10953.34 MMBtu/yr Combustion emission factor source: AP -42: Chapter 13.5 0.068 lb NOx/MMBtu 0.31 lb CO/MMBtu 0.37 tpy NOx 1.70 tpy CO Emissions Summary 0.37 tpy NOx Uncontrolled/PTE 1.70 tpy CO 214.5 tpy VOC Controlled 10.7 tpy VOC Uncontrolled Total (Iblyr) Scenario A Reportable? Controlled Total (lb/yr) Benzene 688 Yes 34 Toluene 758 Yes 38 Ethylbenzene 140 No 7 Xylenes 377 Yes 19 n -hexane 8136 Yes 407 224 -IMP 146 No 7 Emission Factors for Permit meter installed: Uncontrolled NOx 174.8 Ib/MMscf natun CO 796.7 lb/MMscf natun VOC 100634 lb/MMscf natun Benzene 161.393 lb/MMscf natun Toluene 177.735 lb/MMscf natun Ethylbenzene 32.7754 lb/MMscf natun Xylenes 88.5217 lb/MMscf natun n -Hexane 1908.92 lb/MMscf natun 224-TMP 34.3594 lb/MMscf natun Controlled NOx 174.8 lb/MMscf natun CO 796.7 lb/MMscf natun VOC 5032 lb/MMscf natun Benzene 8.0697 lb/MMscf natun Toluene 8.8868 lb/MMscf natun Ethylbenzene 1.6388 lb/MMscf natun Xylenes 4.4261 Ib/MMscf natun n -Hexane 95.4461 Ib/MMscf natun 224-TMP 1.7180 lb/MMscf natun I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented 1 gas vented I gas vented I gas vented I gas vented I gas vented I gas vented Produced Natural Gas Venting/Flaring Preliminary Analysis Regulatory Applicability AQCC Regulation 1 Colorado Department of Public Health and Environment Air Pollution Control Division This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 3 u Part A: An APEN is required for this source because uncontrolled VOC emissions exceed one ton per year in a nonattainment area for ozone. Part B: A permit is required for this source because uncontrolled VOC emissions from this facility exceed two tons per year in a nonattainment area for ozone. This source is subject to Section III.D.2 (Minor Source RACT) because it is located in a nonattainment area. RACT for this source has been determined to be the use of a flare to control emissions. Is public comment required? Public Comment Required AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, XVII.B.2 Facility Status This facility is a synthetic minor source of VOC and HAP for Title V applicability. This facility is a synthetic minor source of VOC for NSR applicability. COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT AIR POLUTION CONTROL DIVISION INVENTORY AIRS (County/Plant) 123/9F62 Permit No. 17WE1028 Date 12/5/2017 Point # Seg * SCC Pollutant or CAS Fug Dust Uncontrolled Emission Factor Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable ? 001 31000205 NOx n 174.76 lb/MMscf AP -42: Chapter 13.5 0.4 0.4 0% CO n 796.7 lb/MMscf AP -42: Chapter 13.5 1.7 1.7 0% VOC n 100634.32 lb/MMscf Engineering Calcs 10.7 214.5 95% 71432 Benzene n 161.393034 lb/MMscf Engineering Calcs 34 688 95% Yes 108883 Toluene n 177.735224 lb/MMscf Engineering Calcs 38 758 95% Yes 100414 Ethylbenzene n 32.7754354 Ib/MMscf' Engineering Calcs 7 140 95% No 1330207 Xylene n 88.5216887 lb/MMscf Engineering Calcs 19 377 95% Yes 110543 n -Hexane n 1908.92111 lb/MMscf Engineering Calcs 407 8136 95% Yes 540841 224-TMP n 34.3594195 lb/MMscf Engineering Calcs 7 146 95% No NOTES *Emissions of criteria are reported in tons/yr; emissions of NCRPs are in lb/yr. You can copy each row into the permit history file for a facility -wide summary. The first row can be copied into the Criteria tab. The second and third rows can be copied into the HAPs tab, Be sure to do Edit, Paste Special, Values to avoid creating links back to this PA in the history file. Controlled Emissions Uncontrolled Emissions POINT 001 PERMIT 17WE1028 Description Produced natural gas venting NOx 0.4 VOC 10.7 Fug VOC Controlled Emissions Formaldehyde CO 1.7 Reportable HAPs Total HAPs NOx 0.4 VOC 214.5 Fug VOC CO 1.7 Reportabl e HAPs POINT 001 PERMIT 17WE1028 Description Produced natural gas venting Acetaldehyde Uncontrolled Formaldehyde Benzene 34 Acrolein Toluene 38 Ethybenzene 7 Xylene 19 n -Hexane 407 2,2,4 -Trim( 7 Methanol 1,3-Butadiehe POINT 001 PERMIT 17WE1028 Description Produced natural gas venting Acetaldehyde Benzene 688 Acrolein Toluene 758 Ethylbenzene 140 XNene 377 n -Hexane 8136 2,2,4 -Trims 146 Methanol 1.38utadiene Total HAPs Produced Natural Gas Venting/Flaring Preliminary Analysis Division Information Engineer: Oluwaseun Ogungbenle Control Engineer. Stephanie Spector Review Date: 12/05/2017 Application Date: 09/05/2017 Facility Information Permit No. 17WE1029 123 Weld 9F62 002 Separator Venting Extraction Oil & Gas, Inc. Carlson 15-D Production Facility NENE Section 15, Township 5N, Range 65W AIRs County # Facility # Point # Facility Equipment ID Company Name: Colorado Department of Public Health and Environment Air Pollution Control Division Attainment Status PM10 Attainment PM2.5 Attainment SOx Attainment NOx Nonattainment VOC Nonattainment CO Attainment Potentially Located within EAC - determine attainment status of NOx and \ Source Name: Source Location: SIC: 211111 0 Elevation (feet) x New Permit (CP1) Modification (Issuance #) APEN Required/Permit Exempt Transfer of Ownership APEN Exempt/Permit Exempt Notes The low-pressure gas streams from the HLP separators are captured with three vapor recovery units (VRUs) under normal operating conditions. During VRU downtime; emissions from the low-pressure sides of the HLP separators gas streams are routed to an enclosed combustor. The high-pressure gas streams are sent directly to a 2 -phase separator, outlet gas from the 2 -phase separator is sent to the sales line. Produced Natural Gas Venting/Flaring Preliminary Analysis ulpinent Description This source vents natural gas from: arator �l3 �1i3�1113 j� ��33 p 6i Emissions from this source are: t eftslosed flare Colorado Department of Public Health and Environment Air Pollution Control Division Natural gas venting from a well head separator. Emissions from this source are routed to an enclosed flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex =emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-moi) at 60F and 1 atm Maximum Vent Rate I 208000 scf/hr RequestedThroughput (Q) 9.2 MMscf/yr 1050.2 scf/hr I 0.000 MMscf/d I 0.78 MMscf/mo % Vented 0.50% MW 21.264 Ib/Ib-mol Component mole % MW Ibx/Ibmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 2.4546 44.01 1.080 0.051 CO2 3.0 26223 13.11 N2 0.2057 28.013 0.058 0.003 N2 0.2 1399 0.70 methane 76.8285 16.041 12.324 0.580 methane 34.2 299159 149.58 ethane 12.8564 30.063 3.865 0.182 ethane 10.7 93821 46.91 propane 4.8354 44.092 2.1320 0.100 propane 5.9 51754 25.88 isobutane 0.6754 58.118 0.3925 0.015 isobutane 1.1 9528 4.76 n -butane 1.2893 58.118 0.7493 0.035 n -butane 2.1 18189 9.09 isopentane 0.3041 72.114 0.2193 0.010 isopentane 0.6 5323 2.66 n -pentane 0.2923 72.114 0.2108 0.010 n -pentane 0.6 5117 2.56 cyclopentane 0.0159 70.13 0.0112 0.001 cyclopentane 0.0 271 0.14 n -Hexane 0.0604 86.18 0.0521 0.002 n -Hexane 0.1 1264 0.63 cyclohexane 0.0065 84.16 0.0055 0.000 cyclohexane 0.0 133 0.07 Other hexanes 0.0837 86.18 0.0721 0.003 Other hexanes 0.2 1751 0.88 heptanes 0.0541 100.21 0.0542 0.003 heptanes 0.2 1316 0.66 methylcyclohexane 0.01 98.19 0.0098 0.000 methylcyclohexane 0.0 238 0.12 224-TMP 0.0002 114.23 0.0002 0.000 224-TMP 0.0 6 0.00 Benzene 0.0065 78.12 0.0051 0.000 Benzene 0.0 123 0.06 Toluene 0.0101 92.15 0.0093 0.000 Toluene 0.0 226 0.11 Ethylbenzene 0.0008 106.17 0.0008 0.000 Ethylbenzene 0.0 21 0.01 Xylenes 0.0024 106.17 0.0025 0.000 Xylenes 0.0 62 0.03 C8+ Heavies 0.0075 136.291 0.0102 0.000 C8+ Heavies 0.0 248 0.12 Notes VOC mass fraction: 0.1851 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control monthly limit assuming 95% control (lb/mo.) 47.8 2.4 405.8 Mole %, MW, and mass fractions from Carlson K 15-16 C gas analysis collected 07/28/2017. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+ based on the average MW on the analysis for the gas. Produced Natural Gas Venting/Flaring Preliminary Analysis Flaring Information Equipment Description Flare to combust VRT as during VRU downtime. Manufacturer Questor Model Q5000 Serial Number TBD Gas Heating Value 1225 Btu/scf Throughput 11270 MMBtu/yr Combustion emission factor source: AP -42: Chapter 13.5 0.068 lb NOx/MMBtu 0.31 lb CO/MMBtu 0.38 tpy NOx 1.75 tpy CO Emissions Summary 0.38 tpy NOx Uncontrolled/PTE 1.75 tpy CO 47.8 tpy VOC Controlled 2.4 tpy VOC Colorado Department of Public Health and Environment Air Pollution Control Division Uncontrolled Total (lb/yr) Scenario A Reportable? Controlled Total (Ib/yr) Benzene 123 No 6 Toluene 226 No 11 Ethylbenzene 21 No 1 Xylenes 62 No 3 n -hexane 1264 Yes 63 224-TMP 6 No 0 Emission Factors for Permit meter installed: Uncontrolled NOx 83.3 lb/MMscf natun CO 379.8 lb/MMscf natun VOC 10388 lb/MMscf natun Benzene 13.398 Ib/MMscf natun Toluene 24.557 lb/MMscf natun Ethylbenzene 2.2411 lb/MMscf natun Xylenes 6.7232 lb/MMscf natun n -Hexane 137.34 lb/MMscf natun 224-TMP 0.6028 lb/MMscf natun Controlled NOx 83.3 lb/MMscf natun CO 379.8 lb/MMscf natun VOC 519 lb/MMscf natun Benzene 0.6699 lb/MMscf natun Toluene 1.2279 lb/MMscf natun Ethylbenzene 0.1121 lb/MMscf natun Xylenes 0.3362 lb/MMscf natun n -Hexane 6.8671 lb/MMscf natun 224 -IMP 0.0301 lb/MMscf natun I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented I gas vented Produced Natural Gas Venting/Flaring Preliminary Analysis Regulatory Applicability AQCC Regulation 1 Colorado Department of Public Health and Environment Air Pollution Control Division This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of. odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 3 Part A: An APEN is required for this source because uncontrolled VOC emissions exceed one ton per year in a nonattainment area for ozone. Part B: A permit is required for this source because uncontrolled VOC emissions from this facility exceed two tons per year in a nonattainment area for ozone. This source is subject to Section III.D.2 (Minor Source RACT) because it is located in a nonattainment area. RACT for this source has been determined to be the use of a flare to control emissions. Is public comment required? Public Comment Required AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, XVII.B.2 Facility Status This facility is a synthetic minor source of VOC and HAP for Title V applicability. This facility is a synthetic minor source of VOC for NSR applicability. COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT AIR POLUTION CONTROL DIVISION INVENTORY AIRS (County/Plant) 123/9F62 Permit No. 17WE1029 Date 12/5/2017 Point # Seg * SCC Pollutant or CAS Fug Dust Uncontrolled Emission Factor Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable. ? 002 31000205 NOx n 83.3 lb/MMscf AP -42: Chapter 13.5 0.4 0.4 0% CO n 379.75 lb/MMscf AP -42: Chapter 13.5 1.7 1.7 0% VOC n 10387.9382 lb/MMscf Engineering Calcs 2.4 47.8 95% 71432 Benzene n 13.3978892 lb/MMscf Engineering Calcs 6 123 95% No 108883 Toluene n 24.557124 lb/MMscf Engineering Calcs 11 226 95% No 100414 Ethylbenzene n 2.24105541 lb/MMscf Engineering Calcs 1 21 95% No 1330207 Xylene n 6.72316623 lb/MMscf Engineering Calcs 3 62 95% No 110543 n -Hexane n 137.342269 Ib/MMscf Engineering Calcs 63 1264 95% Yes 540841 224-TMP n 0.60279683 Ib/MMscf Engineering Calcs 0 6 95% No NOTES *Emissions of criteria are reported in tons/yr; emissions of NCRPs are in lb/yr. You can copy each row into the permit history file for a facility -wide summary. The first row can be copied into the Criteria tab. Thesecond and third rows can be copied into the I1APs tab. Be sure to do Edit, Paste Special, Values to avoid creating links back to this PA in the history file. Controlled Emissions Uncontrolled Emissions POINT 002 PERMIT 17WE1029 Description Produced natural gas venting NOx 0.4 VOC 2.4 Fug VOC Controlled Emissions Fomal<MMe CO 1.7 Reportable Total HAPs NOx 0.4 VOC 47.8 Fug VOC CO 1.7 Reportabl e HAPs POINT 002 PERMIT 17WE1029 Description Produced natural gas venting Acetaldehyde Benzene 6 Acrolein Toluene Edryleuene Xhlene 3 n -Hexane 63 2,2,4 -Trims Methanol 1.3 -Butadiene Uncontrolled Formaldehyde POINT 002 PERMIT 17WE1029 Description Produced natural gas venting Acetaldehyde Benzene 123 Acrolein Toluene 226 Ehrylbenzene 21 X11ene 62 n -Hexane 1264 2,2,4 -Trims 6 Methanol 1.3 -Butadiene Total HAPs Point 001 Pollutant VOC Benzene Toluene Ethylbenzene Xylenes n -Hexane 2, 2,4 -TM P Point 002 Pollutant VOC Benzene Toluene Ethylbenzene Xylenes n -Hexane 2,2,4 -TM P Point 006 VOC Benzene Toluene Ethylbenzene Xylenes n -Hexane 2,2,4 -TM P Emission facto Uncontr. emissions (lb/yr) Uncontrolled 428360 100506.80 687 161.164 756 177.482 140 32.731 377 88.402 8125 1906.319 146 34.315 rs (lb/MMscf) Controlled 5025.34 8.058 8.874 1.637 4.420 95.316 1.716 Emission factors (lb/MMscf) Uncontr. emissions (lb/yr.) Uncontrolled 95380 10367.39 123 13.374 226 24.514 21 2.237 62 6.712 1261 137.109 6 0.602 228280 958 575 9 336 8226 165 Controlled 518.37 0.669 1.226 0.112 0.336 6.855 0.030 lb/bbl (unc.) lb/bbl (contr) 0.148 0.01 0.0006193 0.000031 0.0003715 0.000019 0.0000055 0.000000 0.0002175 0.000011 0.0053190 0.000266 0.0001070 0.000005 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1028 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Carlson 15-D Production Facility 123/9F62 NENE SEC 15 T5N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description . Emissions Control Description VRT Venting 001 Vapor Recovery Tower (VRT) gas controlled by an enclosed combustor during VRU downtime. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the 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 I AirPottution Control Division tkvotme ^t put* 43e4ith.'v f;;virorvner t Page 1 of 7 3. all e aK : e o •tor of r - aich this per (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4. ) Annual Limits: Facility Equipment ID AIRS Point _ Tons per Year Emission Type PM2.5 NO, VOC CO VRT Venting 001 --- --- 10.8 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT Venting 001 Emissions from the VRT are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime VOC and HAP !COLORADO Air Pollution Control Division ;.evv° neat of PublicHerilth,v Envisficombf;t Page 2 of 7 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT Venting 001 Natural Gas Venting 4.3 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. Upon installation of the flow meter, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from VRT using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten -digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OftM) plan and record -keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to COLORADO Mr Pollution Control Division { >F%srtr-x t ot Pci a c 3te£ n fs E-lS3r-tol lei t Page 3 of 7 are �� Di �k.u.��:.1 pri Part B, Section III.G.7, 'on. (Regul �W �, ber 3, COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or 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. Federal regulatory program requirements (i.e. NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). COLORADO Air Pollution Control Division vvra A PI.tYEi_ WE.'Fl.'s.0 En,ri,oro•rtnt. Page 4 of 7 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Oluwaseun Ogungbenle Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. !COLORADO Air Pollution Control Division Dep6rtment P bile H th , C^vsarrriee:t Page 5 of 7 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment. ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) VRT Venting 001 Benzene 71432 687 34 Toluene 108883 756 38 Ethylbenzene 100414 140 7 Xylenes 1330207 377 19 n -Hexane 110543 8,125 406 2,2,4- Trimethylpentane 540841 146 7 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 001: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x 174.8 174.8 AP -42 CO 796.7 796.7 AP -42 V0C 100506.80 5025.34 ProMax 71432 Benzene 161.164 8.058 ProMax 108883 Toluene 177.482 8.874 ProMax 100414 Ethylbenzene 32.731 1.637 ProMax 1330207 Xylene 88.402 4.420 ProMax 110543 n -Hexane 1906.319 95.316 ProMax COLORADO Air Pollution Control Division 'p,,,t nem of Ptthli Hetin n thviror:rners Page 6 of 7 CAS # .�5� Pollutant _. .... lled Emission Factors (lb/MMSCF) Emission Factors (lb/MMSCF) • Source 540841 2'2'4 Trimethylpentane 34.315 1.716 ProMax Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 79 °F and separator pressure of 6 psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, and total HAPs NANSR Synthetic Minor Source of VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I 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 tA:pmmeftof EnviYOY;r..W.>rt Page 7 of 7 Department of Public Health Er Environment. CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1029 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Carlson 15-D Production Facility 12319F62 NENE SEC 15 T5N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Separator Venting 002 High -Low Pressure Separator gas controlled by an enclosed combustor during VRU downtime. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION. 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the 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 Gelb xxrst bt Public Rebid, & E:,;ircirment Page 1 of 7 3 fit sha .r� if thmperat •. s s ^. which this as 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 atone 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 Separator Venting 002 --- --- 2.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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 Separator Venting 002 Emissions from the Separators are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime VOC and HAP !COLORADO Pollution Control Division Fuol Page 2 of 7 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Separator Venting 002 Natural Gas Venting 9.2 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. Upon installation of the flow meter, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten -digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The 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, rpust either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (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 COLORADO otion Control Division iedth.b E 7:v.urintent Page 3 of 7 plan Part B, Section IIl.G.7.) tation. (Re:, . umber 3, COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emittingless than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; 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. Federal regulatory program requirements (i.e. NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). COLORADO Mr Pollution Control Division >05,trAnt or Public Heat,t, Page 4 of 7 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Oluwaseun Ogungbenle Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil, Et Gas, Inc. COLORADO Air Pollution Control Division =hA=rti-x"t Gf Pubk• i,th.G erironne'it Page 5. of 7 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Separator Venting 002 Benzene 71432 123 6 Toluene 108883 226 11 Ethylbenzene 100414 21 1 Xylenes 1330207 62 3 n -Hexane 110543 1261 63 2,2,4 Trimethylpentane 540841 6 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x 83.3 83.3 AP -42 CO 379.8 379.8 AP -42 V0C 10367.39 518.37 ProMax 71432 Benzene 13.374 0.669 ProMax 108883 Toluene 24.514 1.226 ProMax 100414 Ethylbenzene 2.237 0.112 ProMax 1330207 Xylene 6.712 0.336 ProMax 110543 n -Hexane 137.109 6.855 ProMax COLORADO Air Pollution Control Division fieEkitit Page 6 of 7 CAS # Pollutant troll Emission Factors (lb/MMSCF) ed Emission Factors (Ib/MMSCF) Source 540841 2,2,4- Trimethylpentane 0.602 0.030 ProMax Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 93 °F and separator pressure of 348 psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, and total HAPs NANSR Synthetic Minor Source of VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I 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 Mr Pollution Control Division Page 7 of 7 vA� fn 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 alt 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: 1I WI 1 �2�b AIRS ID Number: (23 / 9 F6Z/ d 0 Leave blank i islets APCD has already assigned a permit # and AIRS ID] Company equipment Identification: VRT Venting [Provide Facility Equipment €D to identify low this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc Site Name: Carlson 15-D Production Facility Site Location: NENE Sec. 15 T5N R65W Mailing Address: (Include Zip Code) 370 17th Street, 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 a -mail to the address provided. Form APCD-205 Natural Gas Venting APEN - Rev 03/2017 p c, .COLORADO 1 /751\-- 368742 III Permit Number: TBD AIRS ID Number: [Leave blank unless APCD has already assigned a permit II arid AIRS ID] Section 2- Requested Action r❑ NEW permit OR newly -reported emission source - OR - • MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ 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 Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: VRT Venting Emissions For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 06 / 05 / 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 -Naturat Gas Venting APEN - Rev 03/2017 days/week weeks/year 0 Yes ❑ Yes ❑ No 0 No - COI.O R.AOO v.h Permit Number: TBD AIRS ID Number: / / ave Wank unless APCil has already assigned a permit_ .. and AIRS ID] Section 4 - Process Equipment Information 0 Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 12 128 SCF/hr Vent Gas Heating Value: 2 570 BTU/SCF Requested: 4.262 MMSCF/year Actual: 2.131 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 46.43 VOC (mole %) 69.7 VOC (Weight %) 82.1 Benzene (mole %) 0.0783 Benzene (Weight %) 0.132 Toluene (mole %) 0.0731 Toluene (Weight %) 0.145 Ethylbenzene (mole %) 0.0117 Ethylbenzene (Weight %) 0.0268 Xylene (mole %) 0.0316 Xylene (Weight %) 0.0723 n -Hexane (mole %) 0.8395 n -Hexane (Weight %) 1.56 2,2,4-Trimethylpentane (mole %) 0.0114 2,2,4-Trimethylpentane (Weight %) 0.0280 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 It n -Hexane, temperature, and pressure) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 3 I' COLORADO Permit Number: TBD AIRS ID Number: / / L are bank unless APCD has already assigned a permit and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.403391°, -104.641192° Operator Stack ID No Dischar e Height z Above Ground Level Tem p (°F) Flow Rate (ACFM Velocit lsec) Q5000 -30' TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap TBD 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: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: TBD MMBtu/hr Make/Model: Questor/Q5000 95 % >99 % Waste Gas Heat Content Constant Pilot Light: ❑ Yes ❑✓ No Pilot burner Rating 2,570 Btu/scf N/A MMBtu/hr Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 APCD-205 -Natural Gas Venting APEN Rev 03/2017 PM PM Permit Number: TBD AIRS ID Number: t_eave blank uri[eSs AFCI) has already a6si<_gned a permit = and AIRS I€i] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): • Control Equipment Description Overall Requeste.d:Control. Efficiency;_ {% reduction in emissions) SOX NO), VOC ECD 95% CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Factor: Emission Factor Emission Factor::. Source (AP -42, Mfg.:: etc) Uncontrolled (Tons/year). Controlled, (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) SOX NO), 0.068 Ib/MMBtu AP -42 0.19 0.37 VOC 100.5 Ib/Mscf Promax 107.09 5.35 214.18 10.71 CO 0.31 Ib/MMBtu AP -42 0.85 1.70 Benzene 0.16 Ib/Mscf Promax 0.17 0.009 0.34 0.017 Toluene 0.18 Ib/Mscf Promax 0.19 0.009 0.38 0.019 Ethylbenzene Xylenes 0.09 Ib/Mscf Promax 0.09 0.005 0.19 0.009 n -Hexane 1.91 Ib/Mscf Promax 2.03 0.102 4.06 0.203 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 Natural Gas Venting APEN Rev 0312017 5 { c� OLORAD© Permit Number: TBD AIRS ID Number: Leave blank unless APCD has already assigned a permit and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 9/5/2017 Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance ✓❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-205 -Natural Gas Venting APEN Rev 0312017 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 ACOLORADO 6 i ' ,,,,t„ l .� . E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil & Gas, Inc. Source Name: Carlson 15-D Production Facility Emissions Source AIRS ID2: l r/ (SID / c(1:7-6 i/o a 1 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 41709 Carlson J-15-16-HN 1 05 -123 - 41710 Carlson B -15 -16 -HC 1 05 -123 - 41711 Carlson C-15-16-HN // 05 -123 - 41712 Carlson K -15 -16 -HC .1 05 -123 - 41713 Carlson E -15 -16 -HC 05 -123 - 41714 Carlson D-15-16-HN /1 05 -123 - 41715 Carlson L-15-16-HN .1 05 -123 - 41716 Carlson F-15-16-HN /1 05 -123 - 41717 Carlson H -15 -16 -HC 1 05 -123 - 41718 Carlson G-15-16-HN A 05 -123 - 41719 Carlson I-15-16-HN 0 05 -123 - 41720 Carlson A-15-16-HN // - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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 Carlson 3.6 AP_FormAPCD-212-EP-StorageTank-APEN-Addendum.docx Gas/Liquid Separator APEN — Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Gas/Liquid Separators only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped. 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: r4-03 Io2R AIRS ID Number: (23 /cF (o 2/ 0 02_, [Leave blank unless APCD has already assigned a permit r and MRS ID] Company equipment Identification: Separator 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. Carlson 15-D Production Facility Site Location: NENE Sec. 15 T5N R65W Mailing Address: (include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado E -Mail Address2: ksteerman@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 1Please 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-211 - Gas/Liquid Separator APEN - Rev 02/2017 Rore: ct\ 368741 COLORADO 1 I : tc. atL entH hSiz 3F.:ry 3 F nvFx?nzY�e5F Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit 4 and MRS ID) Section 2- Requested Action O NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name El Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' El Other (describe below) OR - • APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: s 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: Separator Venting Emissions from HLP For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 06/05 /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 0 Yes ❑ No ❑ Yes 0 No Form APCD-7.11 -Gas/Liquid Separator APEN - Rev 02/2017 _.. COIO@ADQ I_ Cagan:cmte.:fi 4tc Hxaisr� b F:�:aF��nrce:ct In Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information If you are requesting uncontrolled VOC emissions greater than 100 tpy 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: 208 000 SCF/hr Vent Gas Heating Value: 225 BTU/SCF Requested: 9.20 MMSCF/year Actual: 4.60 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 21 .264 VOC (mole %) 7.6546 VOC (Weight %) 18.5055 Benzene (mole %) 0.0065 Benzene (Weight %) 0.0239 Toluene (mole %) 0.0101 Toluene (Weight %) 0.0438 Ethylbenzene (mole %) 0.0008 Ethylbenzene (Weight %) 0.0040 Xylene (mote %) 0.0024 Xylene (Weight %) 0.0120 n -Hexane (mole %) 0.0604 n -Hexane (Weight %) 0.2448 2,2,4- Trimethylpentane 0 0002 2,2,4-Trimethylpentane (Weight %) 0.0011 Additional Required Information: r❑ Attach a representative gas analysis (including BTEX £t n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 A COLORADO 3 �• v n�erna:a¢tK NeaI��F .£�tuvr.:a Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID' Section 5 - Stack Information Geographical Coordinates (LatitudeILon itude or UTM) 40.403391°, -104.641192° operator Stack In Na Discharge Height Above round Level (Feet) s �np �� F) Flaw ):ateelocify (ACFM) l (ft/ sec Q5000 -30' TBD TBD TBD Indicate the direction of the stack outlet: (check one) 2 Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency VRU Downtime or Bypassed Make/Model: ❑ Combustion Device:' Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: TBD MMBtu/hr Make/Model: Questor/Q5000 95 >99 % Waste Gas Heat Content 1,225 Btu/scf Constant Pilot Light: ❑ Yes ❑✓ No Pilot burner Rating N/A MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 Permit Number: AIRS ID Number: PM PM [Leave blank unless APCD has already assigned a permit # and AIRS lD] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Overall Requested Control Efficiency (% reduction in emissions) SOX NO„ VOC ECD 95 CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Factor Emission Factor Units Emission Factor Source Mfg etc): Controlled' (Tons/year) Uncontro€ledControlled (Tons/year) (Tons/year) Uncontrolled (Tons/year) Sax NO„ 0.068 Ib/MMBtu AP -42 0.19 0.38 VOC 10.37 Ib/Nlscf Promax 23.84 1.19 47.69 2.38 CO 0.31 lb/MMBtu AP -42 0.87 1.75 Benzene Toluene Ethylbenzene Xylenes n -Hexane 0.137 Ib/Nlscf Promax 0.315 0.0158 0.631 0.0315 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 -Gas/Liquid Separator APEN - Rev 02./2.017 5A fl A COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 9/5/2017 Signature of Legally Authorized Person (not a vendor or consultant) Kathy Steerman Date Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: ❑r Draft permit prior to issuance Q✓ 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-211 -Gas/Liquid Separator APEN - Rev 02/2017 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 COLORADO 6 IA j Hello