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Home My WebLink About20183543.tiff CDPHE COLORADO ie 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 R E C E I V E D 1150O St PO Box 758 Greeley, CO 80632 NOV 0 5 2018 October 30, 2018 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On November 1, 2018, the Air Pollution Control Division will begin a 30-day public notice period for Extraction Oil Et Gas, Inc. - Walton HZ 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, x '..,I , �. = ,�,. �-...4.Lam, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure /A:0 \ski 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ra f� John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer PL.)b iC RA-VieGU cc` PLCTP). t-tc.c ), PW(£R/cH/Jm/CK) It r l t5/ 14? 2018-3543 ,A CDPHE Air Pollution Control Division co ,' Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Walton HZ Production Facility - Weld County Notice Period Begins: November 1, 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: Walton HZ Production Facility Oil and gas production facility NENE Sec 25 T7N R67W Weld County The proposed project or activity is as follows: Source is requesting ability to vent to flare vapors from the existing high pressure separator. 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 analysis, and a draft of Construction Permit 18WE0252 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us A COLORADO 1 1131' Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Carissa Money Package#: 576000 Received Date: 3/7/2018 Review Start Date: 8/9/2018 Section 01-Facility Information Company Name: Extraction Oil&Gas,Inc. Quadrant Section Township Range County AIRS ID: 225 NENE 25 7N 67 Plant AIRS ID: 989E Facility Name: Walton HZ Production Facility Physical Address/Location: NENE quadrant of Section 25,Township 7N,Range 67W County: Weld County Type of Facility: Eirpl©ratreas&Production yueit556d- What industry segment?Oil&Natural Gas Production&.Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? El Carbon Monoxide(CO) El Particulate Matter(PM) Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRS Point# Emissions Source Type Equipment Name Permit# Issuance# Action Control? Required? Remarks Permit Initial' 013 Separator Venting HP Separator Venting Yes 18WE0252 1 Yes -` lsseeece • Section 03-Description of Project Source is requesting a permit to vent and flare high pressure sates gas when needed.The site is an existing E&P site. Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,wh it-entreating Synthetic r why? q g yn Minor-Psrmit -- 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? N _- Is this stationary source a synthetic minor? Yes-: If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) _ _ Title V Operating Permits(OP) J ✓ El �✓ Non-Attainment New Source Review(NANSR) C ✓ Is this stationary source a major source? No If yes,explain what programs and which pollutants herr SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) C ❑ Title V Operating Permits(OP) Colorado Air Permitting Project Non-Attainment New Source Review(NANSR) L - EI Separator Venting Emissions Inventory • 013 Separator Venting 123 9E9Ej Facility Al Rs ID: - Oltz �• County Plant Point Section 02-Equipment Description Details Venting of sales gas front one high-pressure separator Detailed Emissions Unit Description: Enclosed flare Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency%: 98 Limited Process Parameter Gas meter V .m.. Section 03-Processing Rate Information far Emissions Estimates Primary Emissions-Separator Actual Throughput= j '-+ .'`e'- -4s1 :MMscf per year Requested Permit Limit Throughput= 18 35e MMscf per year Requested Monthly Throughput= 16 MMscf per month Potential to Emit(PTE)Throughput= 183 MMscf per year • Process Control(Recycling) Equipped with a VRU: Is VRU process equipment: ;-�j •�" "ij Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: I199P Btu/scf Volume of-waste gas emitted per BBL of ',e'dTAWIOJE, liquids throughput: r" l; scf/bbl Section 04-Emissions Factors&Methodologies Description Source usedrearesenta-;ve sample#5010 Rester Farms 0.3595 collected 5/13/17 to estimate VOC and HAP composition .etittegS MW ' '05 lb/Ib-mol Displacement Equation Ex=Q'MW'Xx/C We:s ht% Helium CO2 i ---�—3.91'. N2 o 9 methane --_ 61.69. ethane f t 17 84 propane 11,40 '. isobutane n-butane 130'. i�entane 077 pentane 3 98 cyclopentane 005 n-Hexane 224 cyclohexane _ 0.03'. Other hexanes 0f29'. Manes 0314 methylcyclohexane 0 0S'. 224-TMP 0.01. Benzene -0.02 Toluene 0.05 Ethylbenzene 0.33' Xylenes 0:03 C8+Heavies 0.09 Total 100.00 VOCWt% 15.65 Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) 0463.4169 169.26837.'14011122,1 ,fi , . 0.0649 Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) 0.0075 1. ._ 0.0075MV ditigatallillaW, f y/i 1110.,066',0 ;r( C y''`4), 0.0500 >_ 59.947 3 of 6 K:\PA\2018\18WE0252.CP1.xlsm Separator Venting Emissions Inventory • Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled - Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.82 0.00 0.00 0.82 0.8 138 PM2.5 0.82 0.00 0.00 0.82 0.8 138 SOK 0.06 0.00 0.00 0.06 0.1 11 NOx 7.22 0.00 0.00 7.22 7.2 1227 VOC 772.29 0.00 0.00 772.29 15.4 2624 CO 5.47 0.00 0.00 5.47 5.5 _ 929 Potential to Emit Actual Emissions Requested Permit Limits ' Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) . Benzene 2172 0 • 0 2172 43 Toluene 4738 0 0 . .F/38 95 Ethylbenzene 1579 0 0 1579 32 • Xylene __ 2961 0 0 2961 59 n-Hexane • 23889 0 0 23889 478 224 TMP 592 0 0 592 12 Section 06-Reg ulatory Summary Anal is Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVII.B,G Source is subject to Regulation 7,Section XVIl.B.2,G Regulation 7,Section XVII.B.2.e The control device for this separator is not subject to Regulation 7,Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID,and should have been collected within one year of the application received date.However,if L. the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes,the permit will contain: -An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented.The following questions do not require answer. g. s f�.ryrEr ' r44i atio ,,rrir >,r; / r Vii / hr i rri m "e#$fir 44 I da �` /� y d 4.0 ' rev m y o r;!4,5,44;:a;"r1;',I .P.*:"?4'.',/*;,:-:,',.,4:4'0',44,-fiiir",,,,a,e7A7,:Zit;,i,4c#11/ '.;, --/;,A,4-.',/,e05i,,00ttet a ,: �/ ,�- fe . i ft I I , .r'i s TS3uifi" fv` ., 1. /. .,4r , < 4 of 6 K:\PA\2018\18WE0252.CP1.xlsm Separator Venting Emissions Inventory Section 08 Technical Analysis Notes APEN does not specify cons*rucnoglda$efoiwell.eased on the condensate tank APEN(pt,�105�,fhe�afi.p'€�Yrstpro"duCRioFl is 12/2015.Thu l m assum"ngthe well was ccnstruc[ed of er 8/1/2014 anr�ShO°se'pse'parato s su6jee₹it In extended gas analysis used toestfmateVOC and HAP emissions is based on a'representative""sarriptefrom a different site.Since thesamples not site-specific,I will require an initial sample from this site. � Source is using NOX and CO nlsslon;fBplof,5from the control device manufacturer.No 90ppaf[>ng3tttormaYion was pros dedJnthe application,The unit will be tested to confirm combustion emissions as we Fos combustion eff ereneff'='--ic In the application andon the APEN,'theisource listed the control device as a thermaloxld4„0 If₹he device 3s a thermaloxidizer,then the combustion chamoertemoerature mus-toe measured.Extraction has argued on arevtousapplicattons the combustion'chamber temperasure cant be regulated and would'equ re retro;ftttjvg0!bd able to mnnitor temperature.The device doesn t appear to operate as a thermat oxidizer operates as an enclosed flare Thus,t}e permit'. anguage will use enclosedP are. Based'on the ongmnal req ues,total facility VCC emissions wou ld:he greater than 90 tpy and the.source would:not be able to maintain GP02 coverage.When I Informed the source about this issue they requested to convert t to storage tanks from GP01 to an individual permit.I processed permit t8WEI029for AIRS ID 123/9E9E/005 atthe sometime Now,facility-wide emcsons are below S0 tpy and the source can continue to use GP02: Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point v Process 8 SCC Code Pollutant Factor Control% Units 013 01 3-10-001-60 Flares PM10 8.93 0 lb/MMSCF PM2.5 8.93 0 lb/MMSCF SOx 0.71 0 Ib/MMSCF NOx 79.13 0 lb/MMSCF VOC 8463.42 98 lb/MMSCF CO 59.95 0 Ib/MMSCF Benzene 11.90 98 lb/MMSCF Toluene 25.96 98 lb/MMSCF Ethylbenzene 8.65 98 lb/MMSCF Xylene 16.23 98 Ib/MMSCF n-Hexane 130.90 98 lb/MMSCF 224 TMP 3.25 98 Ib/MMSCF 5 of 6 K:\PA\2018\18WE0252.CP1.xlsm Separator Venting Regulatory Analysis Worksheet • Colorado N. lotion 3 Parts A and B-APEN and Permit Reouirements • I Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled°actual emissions from any criteria pollutants from this individual source greater than 2.TPY(Regulation 3,Part A,Section ll.D.1.a)7 -,,,. 2. Are total facility uncontrolled OCT emissions greater than 5 TPY,BOX greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)7 'Not enough Information • NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY(Regulation 3,Part A,Section 11.0.1.a)7 t Source Req 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NON greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)7 AVM Source Req 'Source requires a permit Colorado Regulation 7,Section XVII - - 1 1. Was the well newly constructed,hydraulically fractured,orrecompleted on.or after August 1,20147 t'y Source isst (Source is subject to Regulation 7,Section XVII.0.2, Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions - Section XVII.G-Emissions Control Alternative Emissions Control(Optional Sentient a. Is this separator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? realThe control (The control device for this separator Is not subjecttm Regulation 7,Section 1011.0.2.. Section XVII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to'a particular situation based upon the individual facts and circumstances.This document does not change or substitute for anylaw, - 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 regulabons,and Air Quality Control Commission regulations,the language of the statute or regulation will control.The use of non-mandatory language such as"recommend,"may,"°should,"and°can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as°must"and'required"are intended to describe controlling requirements under the terms of the Clean Air Act andAir Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself CDPHE_ COLORADO DRAFT coAir Pollution Control Division Department of Pubhc Health&Environment CONSTRUCTION PERMIT Permit number: 18WE0252 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Walton HZ Production Facility Plant AIRS ID: 123/9E9E Physical Location: NENE SEC 25 T7N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Equipment Description Emissions Control Equipment ID Point Description HP Separator 013 Venting of sales gas from one high Enclosed flare Venting pressure (HP) separator (Questor Q5000) 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, bar 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 cOZE COLORADO a 7 Air Pollution Control Division , , . . Page 1 of 10 DRAF T 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.Qov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment AIRS Tons per Year Emission ID Point pM2.5 NO„ V0C CO Type HP Separator Venting 013 --- 7.2 15.4 5.5 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 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.) co tE COLORADO a 7 Air Pollution Control Davisioca Page 2 of 10 DRAFT Facility Equipment ID AIRS Point Control Device Pollutants Controlled HP Separator Venting 013 Enclosed flare (Questor VOC and HAP Q5000) PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit HP Separator Venting 013 Gas Venting 182.5 MMSCF The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of gas vented from all high pressure separator(s) using the flow meter. The owner or operator shall use the sum of monthly throughput records from all high pressure separators vented to the flare 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; 4, c.am COLORADO CO VI Air Pollution Control 1?roisscm .. ..„�,,;;, 3 .: • =r Page 3 of 10 DRAF T • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after issuance of this permit of the gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies) 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) 17. A source initial compliance test shall be conducted to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits specified in this permit and to demonstrate a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The throughput of gas vented from the HP separators, supplemental fuel flow rate and combustion chamber temperature shall be monitored and recorded during the test. eDZe COLORADO NCO Air Pollution Control Division ; xrr, Page 4 of 10 DRAFT 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 by the allowable number of operating hours for that averaging time. (Regulation Number 3, Part B., Section III.G.3) • Volatile Organic Compounds using EPA approved methods • Oxides of Nitrogen using EPA approved methods • Carbon Monoxide using EPA approved methods. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shalt not exceed the crtZE COLORADO �O 7 Air Pollution Control Division Page 5 of 10 DRAFT Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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. COME COLORADO co Air Pollution Control Division ::, Page 6 of 10 DRAFT By: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc for venting of gas from one high pressure separator (AIRS ID 013) cnelfr COLORADO 0 Air Pollution Control Division Page 7 of 10 DRAFT Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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. Uncontrolled Controlled Facility AIRS Equipment ID Point Pollutant CAS# Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 2,172 43 Toluene 108883 4,738 95 Ethylbenzene 100414 1,579 32 HP Separator Venting 013 Xylenes 1330207 2,961 59 n-Hexane 110543 23,889 478 2,2,4- 540841 592 12 Trimethylpentane 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 013: Weight Percent Uncontrolled Controlled of Gas Emission Factors Emission Factors CAS # Pollutant (%) (lb/MMSCF) (lb/MMSCF) Source N0x --- 79.129 79.129 Flare manufacturer clztE COLORADO co ;, Aix Pollution Control Jfsnsion �:,- Page 8 of 10 DRAFT CO 59.947 59.947 Flare manufacturer VOC 15.7 8,463.4 169.27 Extended gas analysis 71432 Benzene 0.02 11.900 0.2380 Extended gas analysis 108883 Toluene 0.05 25.963 0.5193 Extended gas analysis 100414 Ethylbenzene 0.02 8.6544 0.1731 Extended gas analysis 1330207 Xylene 0.03 16.227 0.3245 Extended gas analysis 110543 n-Hexane 0.24 130.90 2.6179 Extended gas analysis 540841 2,2,4- 0.01 3.2454 0.0649 Extended gas Trimethylpentane analysis Note: The controlled emissions factors for this point are based on the flare control efficiency of 98%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: • V0C, HAP, CO NANSR Synthetic Minor Source of: V0C 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the 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, Appendix A - Appendix I Appendixes 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 c a� COLORADO CO P f� Air Pollution Control Bzcnsron ... Page 9 of 10 DRAFT 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 4, E COLORADO c© +. Air Pollution Can rot Division ...... ,.. _ . __. Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Carlssa Money Package#: 376000 Received Date: 9/11/2018 Review Start Date: 10/9/2018. Section 01-Facility Information Company Name: Extraction Oil&Gas,Inc. Quadrant Section Township Range County AIRS ID: 123 NENE 25 7N 67 Plant AIRS ID: 3E35 Facility Name: Walton HZ Production Facility + Physical Address/Location: NENE quadrant of Section 25,Township 7N,Range 67W County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment?Oii&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes, �� If yes,for what pollutant? O Carbon Monoxide(CO) L r^^3 Particulate Matter(PM) 2 Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point# Emissions Source Type Equipment Name Permit# Issuance 6 Action Control? Required? Remarks Permit initial Convertin from. 005 Condensate Tank TK001-TK010 Yes, 18W€1029 1 Yes • lSsuence • GP01 Section 03-Description of Project Source is requesting to convert from GP01 coverage to an individual permit to keep total facility VOC emissions below 90 Spy(and thus to be able to retain GP02 coverage) Section 04-Public Comment Requirements Is Public Comment Required? Yes If why? yes, Y• Requesting Synthetic tYllnor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No • Is this stationary source a synthetic minor? - Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(P5D) _ Title V Operating Permits(OP) J� 19 ❑ El Non-Attainment New Source Review(NANSR) Is this stationary source a major source? No If yes,explain what programs and which pollutants here SO2 NOx CO VOC PM2.5 PM10 TSP HAPS Prevention of Significant Deterioration(PSD) E H jj��r s; B — E ❑ Title V Operating Permits(OP) Colorado Air Permitting Project - Non-Attainment New Source Review(NANSR) Condensate Storage Tank(s)Emissions Inventory 005 Condensate Tank , 123 9E9E 005 Facility Al Rs ID: ' County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit T§Hr`EitF-iIC a r arbi pfl�igN'ihp, YitfrX8d W8'iku1d H1a7tIf»td3 - m- -a" y333 3 - Description: ,,,N .t, i kkn..,a x . ..;,r, v ..,,, E ..,. 1 h.,n .«, rxia. 1, • Emission Control Device '.EtFk)9q@�a �€r�j 1,�y�' �j1133 �,.1 �'9.� it j j 3Eji7,i3I3 �j;IJ 3 111,140g I1, 3 I1 I Description: 3 �d — ,.��.-. ,1.. j a '1.1x1,* ,1'3.En-...... ;Xw„ I71 I 333 „_< — „� Requested Overall VOC&HAP Control rell,i1NAI Efficiency 95: $1,EZ4*giglif Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Condensate Throughput= irniliONAgiii Barrels(bbl)per year Actual Condensate Throughput While Emissions Controls Operating= 4604 Barrels(hbl)per year Requested Permit Limit Throughput= *-39h00&Barrels(bbl)per year Requested Monthly Throughput= 33633 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput = 475 200'Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= •-- 255 Btu/uf Volume of waste gas emitted per BBL of liquids produced= 244:scf/bbl Actual heat content of waste gas routed to combustion device= 22,278 MMBTU per year Requested heat content of waste gas routed to combustion device= 217,887 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 261,465 MMBTU per year Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? _ Uncontrolled Controlled Pollutant (Ib/bbl) (Ib/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) IIMICEI 1.15 r; 0.06 IIIMETZEIMIll 0.0016 0.00008 1€ . MIIMEMMI 0.0011 0.00006 tom'•�; IMIEMEMMEME 0.0001 0.000004 -,`7t4ir,"4..cr.LII:PPISTROIrilrl 0.0003,'.. 0.00001 IIIIMEIMEMIE 0.0I20 0.00060 *3 EMMEMEM 0,0012 0.00006 '_ 1 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) 075 .y 0.0041 . tl.. r - - 3 1 0.6 fli1075- 0.0041 gritTrititegegligg3,00,4.,,,re. MMZIMMIIE.. 084 0.0374 s ." P ME=3:MIMIll((((Yj33it00,33,11 •,p t: n 0.1706 Mithks Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limns Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) - (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) VOC 273.2 23.3 1.2 227.7 11.4 1934 PM10 1.0 0.1 0.1 0.8 0.8 138 PM2.5 1.0 0.1 0.1 0.8 0.0 138 NOR 8.9 0.8 0.8 7.4 7.4 1250 CO 40.5 3.5 3.5 33.8 33,8 - 5737 Potential to Emit Actual Emissions Requested Permit Limits Source's values in back up document Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (Ibs/year) (Ibs/year) (lbs/year) (lbs/year) Benzene 760 65 3 634 32 642 32 Toluene 523 45 2 436 22 426 21 Ethylbenzene 42 4 0 35 2 35 2 Xylene - 128 11 1 107 5 108 5 n-Hexane 5702 486 24 4752 238 4928 246 224 TMP 570 49 2 475 24 487 24 Section 06-Regulatory Summary Ana sis Regulation 3,Parts A,B. - Source requires APEN,is permit exempt Regulation 7,Section XII.C,D,E,F Storage tank is subject to Regulation 7,Section X11,C-F Regulation 7,Section Xll.G,C Storage Tank is not subject to Regulation 7,Section 511.0 Regulation 7,Section XVII.B,C.1,C.3 Storage tank is subject to Regulation 7,Section XVII,B,C1&C3 Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation 7,Section XVi1.C2 Regulation 6,Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6,Part A,NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8,Part E,MACF Subpart HH Storage Tank is not subject to MACT HO (See regulatory applicability worksheet for detailed analysis) 3 of 5 K:\PA\2018\18WE1029.CP1.xlsm Condensate Storage Tank(s)Emissions Inventory Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes,are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? ;,,�,' If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. - Does the company use a site specific emissions factor to estimate emissions? - If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted?This sample should be considered representative which generally means site-specific and .-". collected within one year of the application received date.However,if the facility has not been modified(e.g.,no • new wells brought on-line),then it maybe appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95%for a flare or combustion device? _ If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes The fankswere.consttuctedgishtmthe applicability datefor N5P9OOOOa hutper tank,the controlled emissions urn below6itpp.Thee,the tanks are notsubiect to NIPSO1O:O,a.. Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 005 0l ;a=µ- PM10 0.10 0 lb/1,000 gallons condensate throughput PM2,5 0.10 0 Ib/1,000 gallons condensate throughput NOx 0.89 0 lb/1,000 gallons condensate throughput VOC 27.4 95 lb/1,000 gallons condensate throughput CO 4.06 0 lb/1,000 gallons condensate throughput Benzene 0.04 95 lb/1,000 gallons condensate throughput Toluene 0.03 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.01 95 lb/1,000 gallons condensate throughput n-Hexane - 0.29 95 lb/1,000 gallons condensate throughput - 224 TMP 0.03 95 lb/1,000 gallons condensate throughput 4 of5 - K:\PA\2018\18WE1029.CP1.xlsm • Condensate Tank Regulatory Analysis Worksheet Colorado R-:urethan 3 Parts Aand B-'PEN and Penult RequIremm er'Soune a 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,Seaton liMIA)? aK e///��//.� 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 2for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greaterthan 5 TPY,NOx greater than?0170 Or CO withal.greaterthan 10 TPY(Regulation 3,Part B.5ealonll.03(? -[You have have indicated that source is in the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any aitena pollutants from this lndMdua l source greater than l TPY(Regulation 3,Part A,Section li.0.1.a)? '!a Source Reg 2. Is the construction date(service date)prior tol2/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and114 and Section 2 for additional guidance On grandfather apprcability)? 0093,. YSource Is Al 3. Are total fadlity uncontrolled VOC emissions greater than 2 TPY,NOx greaterthan 5TPY or CO emissions greaterthan 10TPY(Regulation 3,Part B,Section llD2)2 VA NN.' Req (Source requires'PEN,is permit exempt Colorado Regulation 7,Section 01.C-F 1. is this storage tank located In the 8-hr ozone control area or any atone non-attainment area or attainment/maintenance areal Yes Continue-' 2. Is the storage tank located at an oil and gas exploration and production operation',natural gas domprasor station or natural gas drip station? Yes Continue-' 3. Is this storage tank located upstream of a natural gasprocasing plant? .ifs -Source is sr. 'Storage tank is subject.Regulation 7,Section XII C F Section XII.C.1—General Requirements for Air Pollution Control Equipmenrt—Prevention of Leakage Section 0110,2—Emission Estimation Procedures Seaton X8.0—Emissions Control Requirements Section XII5—Monitoring Section all.F—Recordkeeping and Reporting Colorado Regulation 7.Section X0.5 1. Is the storage tank located in the 8-hr ozone control area or any mone non-attainment area orattainment/maintenance area?• Yes Continue-' 2. Isthk0orage tank located at a natural gas processing plant? No Storage Tar 3. Does this storage tank exhibit"Nash.(e.g.storing non-stabllhed liquids)emissions and have uncontrolled actual emissions greaterthan or equal to 2 tom per year VOC? Source issL 'Storage Tank is not nubjeat°Regulation 7,Section XII.5 Section 00.02-Emissions Control Requirements Section 011.0.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section XII.C2—Emission Estimation Procedures Colorado Regulation 7,Section XVII 1. Is this tank located at a transmission/storage facility? No Continue-' 2. Is this condensate storage tank'looted at an oil and gas exploration and production operation,well production facility',natural gas compressor nation'or natural gas processing plant? Yes Go to then 3. Is this condensate storage tank a fixed roof storage tank? ray Go to then 4. Are uncontrolled actual emissions'of this storage tank equal.or greater than 6 tons per year VOC? Rte... Source"s 'Storage tank is subject to Regulation 7,Section XVII,B,0.110 C.3 Section IMI.B—Geneml Provisions for Air Pollution Control Equipment and Prevention of Emissions Section IMI.LS-Emeslom Control and Monitoring Provisions _ Section XVIl.C3-Recerdkeeping Requirements 5. Doothe condensate storage tank ontalnony"stabilized"liquids? b'.i%ir./EI50urcea sL 'Storage tank is subject.Regulation 7,Section XVII.C.0 Section IMI.C2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR,Part 60,Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the intrw'dual storage vessel capacity greaterthan or equal to 75 cubic meters(m')(-472 BBLsl? Go to the 2. Ooes the storage vessel meet the following exemption in 6o.111b(d)(4)1 X¢<^.yj'.Storage Tar a.Does the vessel has a design opacity less than or equal to 1,589.874 ms(`10,0000801 used for petroleum'or condensate stored,processed,Or treated prior to custody transfer as defined in 60.111b? 3. Was this condensate storage tank constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984? • 4. Does the tank meet the definition of'storage vessel"'In 60.1110? 5. Does the storage vessel store a'volatile organic liquid(VOL)"'as defined in 60.1110? 6. Does the storage vessel men any one of the folbwing additional.emotions: a.Is the storage vessel a pressure vessel deslgned to operate in excess 00204.9 kPa['29.7 psi]and without emissions to the atmosphere(60.110b(d)(2))?;or b.Thedaign capacity is greater than or equal to 151 m'(^950 BBL)and stores a liquid with a maximum.re vapor probate'Iess than 3.5 kPa(60.110b(b))1:or c The design capacity is greaterthan or equal to 75 M'(-472 BBL]but lose than 151 m'('950 080)and stares a liquid with a maximum true vapor pressure"less than 15.0 kPa(60110b(b))? 'Storage Tank Is not subject to NSPS Kb Subpart A,General Provisions 4801120-Emissions Control Standards for VOC 460113b-Testing and Procedures 4601156-Reporting and Rscordkeeping Requirements 4601166-Monitoring of Operations 40CFR.Part 60.Subpart 0000,Standards of Performance for Crude on and Natural Gas Pmductlon,Transmissionand Distribution 1. Is this condensate storage vessel located at a fadlity in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue-' 2. Was the condensate storage vase)constructed,reconstructed,or modified(see definitions 40CFR,602)between Mg.23,2011 and September 18,2015? PiaMig Storage Tar 3. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? 4. Dos this condensate storage vessel meet the definition of"storage vase)"'per 605430? 5. Is.e storage vessel subO nto and controlled in accordance with requIreme„atorstoragevessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart NH? 'Storage Tank Is not subject to HOPS 0000 Subpart A,General Provisions per 4605425 Table 3 - 4605395-Emissions Control Standards for VOC 460.5413-Testing and Procedure §60.S395(g)-Notifimtlon,Reporting and Recordkeeping Requirements §605416(c)-Cover and Closed Vent System Monitoring Requirements 0605417-Control Device Monitoring Requirements [Note;If astorage vessel Is previously determined to be subject to NSFS 0000 due to emisslom above 6 tons per year VOC on the applicability determination date,R should remain subject to SOPS 0000 per 60.5365(e)12)even if potential 000 eMsslons drop below 6 tons per year] 40 CFR,Part 53,Subvert MALT OH,Olt 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: [Yes 'Continue- a.A facility that process,upgrades orstora hydrocarbon liquids'(63.760(a((2));OR b.A facility that procasa,upgada orstora 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(a)(3))? 2. Is the tank looted at a fadiity that is major for HAP'? `^.Storage Tar 3 Does the tank meet the definition Of'storage vessel'M 63.761? 4. Does the tank meet the definition of"storage vessel with the potential forflmh emissions"'per 63.761? 5. Is the tank subled to control requirements undar40 CFR Part 60,Subpart Kb Or Subpart 0000? 'Storage Tank is notsubject to.ACT HH Subpart',General provisions per§63.764(a)Tablet §63.766-Emissions Control Standards §03.703-Monitoring 463.774-Recerdkeeping 463.775-Reporting RACr Review RAC-review Is required If Regulation 7 does not apply AND If the tank is in the non-attainment area.If the tank meets bosh Mteda,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is note rule or regulation,and the analysis d contains may not apply to a particular sduabor based upon the individual facts and circumstances.This document does 0of change or substitute for any law, - regulation,or any other legally binrbhg requirement and is not legally enforceable.In Ire aveut 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 regulsti0n will control.The use of non-mandatory language such as"recommend,"'may,"should,'and"can,"is intended to dos beAPCD interpretations and recommendations.Mandatory terminology such as"must"and"required'are intended t0 describe controlling requirements under the farms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally hinting requirements in and of itself. CDPHE COLORADO DRAFT AwN co - Air Pollution Control Division I Department of P lbiic Health b Environment CONSTRUCTION PERMIT Permit number: 18WE 1029 Issuance: 1 Date issued: Issued to: Extraction Oil Et Gas, Inc. Facility Name: Walton HZ Production Facility Plant AIRS ID: 123/9E9E Physical Location: NENE SEC 25 T7N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID TK-001 Ten (10) 500 barrel fixed roof storage vessels through TK- 005 connected via liquid manifold and used to Enclosed Flare 010 Tanks store condensate 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 Pollutipn Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, blr 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 coe COLORADO CO /le Air Pollution Control Division Page 1 of 9 DRAFT 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.Qov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type TK-001 through 005 --- 7.4 11.4 33.8 Point TK-010 Tanks 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.) 4,, cCZE COLORADO .O ;. Air Pollution Control Division Page 2of9 DRAFT Facility AIRS Pollutants Control Device Equipment ID Point Controlled TK-001 through TK- 005 Enclosed Flare VOC and HAP 010 Tanks PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK 001 through TK 010 005 Condensate throughput 396,000 barrels Tanks The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that COME COLORADO C v. Air Pollution Control Division Page 3 of 9 DRAFT an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain•records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING E MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen-minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 17. This permit replaces the following permit, which is cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point GP01 123/9E9E/005 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) cDZE COLORADO co M Air Pollution Control Division Page 4 of 9 DRAFT • 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. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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 Deta' COLORADO O Air Pollution Control Division Page 5 of 9 DRAFT 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: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. for ten 500 bbl condensate storage tanks (AIRS ID 005) co €i gCOLORADO CO ! Air Pollution Control Division Page 6 of 9 DRAFT Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (Ib/yr) Benzene 71432 642 32 Toluene 108883 426 21 Ethylbenzene 100414 35 2 005 Xylenes 1330207 108 5 n-Hexane 110543 4,928 246 2,2,4- 540841 487 24 Trimethylpentane 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 005: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0374 0.0374 AP-42, Chapter 13.5 CO 0.1706 0.1706 AP-42, Chapter 13.5 VOC 1.15 0.06 Source 71432 Benzene 0.0016 0.00008 Source 108883 Toluene 0.0011 0.00006 Source cl,Ple COLORADO +0 Air Pollution Control,Division Page 7 of 9 DRAFT Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl 100414 Ethylbenzene 0.0001 0.000004 Source 1330207 Xylene 0.0003 0.00001 Source 110543 n-Hexane 0.0120 0.00060 Source 540841 2'2'4 0.0012 0.00006 Source Trimethylpentane Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Synthetic Minor Source of: Operating Permit VOC, CO, HAPs PSD Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendix A - Appendix I Appendixes 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 cn r E COLORADO +O Aix Pollution Control Division Page 8 of 9 DRAFT * cai zte COLORADO O "•r" Air Pollution Control Division Page 9 of 9 t:?\"\ 1r '1' d�g SPPHE 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: \ � �u AIRS ID Number: 123 /9E9E/ C) 3 e_ _ d `I'�5 «, Company equipment Identification: HP Separator Venting [Provide FT.ictity Equipment 10 to,.. . :;; :, t.iDs..;fa«mer._ is referenced within your f;_r.«3isA(1 Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Walton HZ Production Facility Site Location Site Location: NENE Sec. 25 T7N, R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E-Mail Address': ksteerman@extractionog.com • '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. • COLORADO Form APCD-211 Natural Gas Ventsn;APEN Rev 03 20" 341$1081 AV Permit Number: AIRS ID Number: 123 /9E9E/ 1),3A tints APO 1`; .:ready ?,,...tr�nedi._ . .i and AIRS I.1 _- 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' ❑ 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 Ft 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: HP Separator Venting Emissions For existing sources, operation began on: I For new or reconstructed sources, the projected start-up date is: /TBD/ r] 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 days/week weeks/year Will this equipment be operated in any NAAQS nonattainment ❑� Yes ❑ No area Is this equipment located at a stationary source that is ❑ Yes ❑✓ No considered a Major Source of(HAP) Emissions A,sW COLOR..60 Form APCD-21 € l=Aturat Gas 'Venting/.,PEN Rev 03/2017 2 I Permit.Number: AIRS ID Number: 123 /9E9E/ blank cf;tl _APCD I' rc c'y pe'i;'i, . 1,iC!AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: Gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? El Yes ❑ No Maximum Vent SCF/hr Vent Gas q BTU/SCF Iii Natural Gas Venting Rate: 20$33.3 Heating Value: ' '"" i` Process Parameters4: Requested: 182.5 MMSCF/year Actual: 182.5 MMSCF/year -OR Nfc - Liquid Throughput 4 Requested: Bbl/yr Actual: Bbl/yr Process Parameters4: 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth Molecular Weight: 20.50 VOC (mole%) 6.52 VOC (Weight%) 15.65 Benzene (mote%) 0.006 Benzene (Weight%) 0.022 Toluene(mole%) 0.011 Toluene (Weight%) 0.048 Process Properties: Ethylbenzene (mole%) 0.003 Ethylbenzene (Weight%) 0.016 Xylene (mole%) 0.006 Xylene (Weight%) 0.030 n-Hexane (mole%) 0.058 n-Hexane (Weight%) 0.242 2,2,4-Trimethylpentane 2,2,4-Trimethylpentane (mole%) 0.001 (Weight%) 0.006 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 a n-Hexane, temperature, and pressure) COLORDO A Fc�rrn�.i�CCi-Z17 -h�atu�'�� 'Vent ing a .^g�f4�Ehd Rev 03/2017 ,,;u._�. ��,. Permit Number: AIRS ID Number: 123 /9E9E t Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.550063, -104.832881 Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level Stack ID No. (°F) (ACFM) (ftlsec)' (Feet) Questor TO —40 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): TBD ❑ Other (describe): Section 6 - Control Device Information Pollutants Controlled: Size: Make/Model: ❑� VRU: Requested Control Efficiency VRU Downtime or Bypassed Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: '`''c' `%'iii' Make/Model: �� - Questor (,��, Combustion �4 r 0 Requested Control Efficiency: 98 % I I'�' Device: Manufacturer Guaranteed Control Efficiency >99 % Minimum Temperature: TBD Waste Gas Heat Content 14.95-- Btu/scf Constant Pilot Light: 2 Yes ❑ No Pilot burner Rating TBD MMBtu/hr Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested 0 COLORAD0 Form IAA D yy -ti at CGS. ct r:_�'2.; PE .. }C 93,297 4 I .. t ..jF l�' �L"�i -F.......� sE� ..,_1�J Permit Number: AIRS ID Number: 123 /9E9Ei 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? E Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency(% reduction): Overall Requested Control Pollutant Control Equipment Description Efficiency (%reduction in emissions) PM SOX NOX V0C Enclosed Combustion Device 98% CO HAPs Enclosed Combustion Device 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.) Emission Requested Annual Permit Uncontrolled Emission Factor Actual Annual Emissions Emission Limit(s)- Pollutant Emission Factor Source Factor Units (AP-42, Uncontrolled Controlled° Uncontrolled Controlled Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) PM SOX ,f 1. NOX i.)-ai 869 - Ib/MMBtu - 7.22 7.22 lcjicV5 VOC 8,456.3 Ib/MMscf Gas Analysis 771.64 15.43 771.64 15.43 c CO V 0.31 - Ib/MMBtu /-',t- +2- 5.47 5.47 J li Benzene 12.35 Ib/MMscf Gas Analysis 1.13 0.02 1.13 0.02 �r��li-h( Toluene 26.71 Ib/MMscf Gas Analysis 2.44 0.05 2.44 0.05 Ethylbenzene 8.39 Ib/MMscf Gas Analysis 0.77 0.02 0.77 0.02 Xylenes 16.79 Ib/MMscf Gas Analysis 1.53 0.03 1.53 0.03 n-Hexane 131.74 Ib/MMscf Gas Analysis 12.02 0.24 12.02 0.24 2,2,4 Trimethylpentane 3.01 Ib/MMscf Gas Analysis 0.27 0.01 0.27 0.01 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. A COLORADO Form:_PCl.-L1 ( lvntfural a is Vorit Sg f s'�t'l _ Rev ? 20175 { Atior .,-. Permit Number: AIRS ID Number: 123 /9E9E/ Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: Q✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303) 692-3175 or (303) 692-3148 APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 https://www.colorado.gov/cdphe/apcd Make check payable to: Colorado Department of Public Health and Environment Telephone: (303)692-3150 6 A., COLORADO o € s, Form C 21 i'ar_uraL Gn Venting APE c C312217 CP.\/ C a> > E Condensate Storage Tank(s) APEN Form APCD-205 CO Ve Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I t(Al D aol AIRS ID Number: 123 / 9E9E / 005 [Leave blank unless APCD has already assigned a permit fi and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Walton HZ Production Facility Site Location Site Location: NENE Sec. 25 T7N R67W County: Weld NAICS or sic Code: 211111 Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado 80202 Contact Person: Kelli Cox Phone Number: (720) 354-4597 E-Mail Address: kcox@extractionog.com I Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. QSLC). ct lit 116 1,7._ ................ _..__.. ___.. _...... _....... ._..... ._.__.. __.... __._ .........._ _._ y� .. CCLORA00.. Form APCD-205- Condensate Storage Tank(s) APEN - Revision 7/2018 1 I y Permit Number: AIRS ID Number: 1 23 /9E9E/005 [Leave blank unless APCD has alrear y assigned a permit."and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 0 Change permit limit ❑ Transfer of ownership' ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: GP-01 to Individual Permit modification 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Ten (10) - 500 bbl Condensate Storage Vessels Company equipment Identification No. (optional): For existing sources, operation began on: 12/01/2015 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ✓❑ Exploration Et Production(EEtP)site O Midstream or Downstream (non EEtP)site Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes O No Are Flash Emissions anticipated from these storage tanks? 0 Yes ❑ No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? O Yes ❑✓ No If"yes", identify the stock tank gas-to-oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 0 Yes ❑ No 805 series rules? If so, submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual O Yes ❑✓ No emissions ≥6 ton/yr(per storage tank)? COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 2 Permit Number: AIRS ID Number: 1 23 /9E9E/005 [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbllyear) (bbllyear) Condensate Throughput: 40,490 396,000 From what year is the actual annual amount? 2017 Average API gravity of sales oil: 41.8 degrees RVP of sales oil: 11.4 Tank design: ❑✓ Fixed roof ❑ Internal floating roof ❑ External floating roof ,, Total Volume of Installation`Date of Most Date of First Storage #of Liquid Manifold Storage Storage Tank Recent Storage Vessel in Production Tank ID Vessels in Storage Tank (bbl) Storage Tank(month/year) (month/year) TK-o1-TK-10 10 5,000 11/2015 12/2015 Wells Serviced by this Storage Tank or Tank Battery6(EEtP Sites Only) API Number Name of Well Newly Reported Well See Form APCD-212 ❑ O O O O 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 6 The EaP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.550063, -104.832881 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level (feet) (°F) (ACFM) (ft/sec) ECD —15 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑� Upward El Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter(inches): 60 ❑Square/rectangle Interior stack width (inches): Interior stack depth (inches): El Other(describe): _.... ................ _..__ ___ _....._ _....._. _.._._. _..._ _.... _._ _ _.... < COLORADO Form APCD-205 - Condensate Storage Tankis)APEN - Revision 7/2018 3 I A K:..., ulrn.,Z� Permit Number: AIRS ID Number: 123 /9E9E/005 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit (VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model:TB D ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 2,296 Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —8 psig Describe the separation process between the well and the storage tanks: HLP Separator, VRT, Condensate Storage Tanks o «LORADO 4 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 Permit Number: AIRS ID Number: 123 /9E9E/005 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency (%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) VOC _... .... ECD 95 NO9 CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2017 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor' Actual Annual Emissions Emission Limit(s) Pollutant 5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions Basis Mfg.etc) (Tonsl ear Y ) (Tons/year) (Tons/year) (Tons/year) VOC 1.15 lb/bbl Permit 23.28 2.27 227.7 11.4 J NOx 0.068 lb/MMBtu AP-42 0.76 # : �t 1 CO 0.31 lb/MMBtu AP-42 3.45 33.77 i Jf_: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor' Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service (CAS) Uncontrolled 8 Units (AP-42, Emissions Emissions Number Basis Mfg. etc) (Pounds/year)g ( Y ) (Poundslyear) Benzene 71432 0.002 lb/bbl Permit 80.98 4.05 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.012 lb/bbl Permit 485.88 24.29 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 7 Attach condensate liquid laboratory analysis,stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. cc�caaco Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 ":`." Permit Number: AIRS ID Number: 123 /9E9E/005 [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 an will e operated in f mpliance with each condition of the applicable General Permit. J 09/11/2018 Signature of egally Auth rized Person (not a vendor or consultant) Date Kelli Cox Air Quality Coordinator Name (print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with 5191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303) 692-3175 or (303) 692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303) 692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.gov/cdphe/apcd _.. _. .. CC LDR ADO Form APCD-205 -Condensate Storage Tank(s) APEN - Revision 7/2018 6 I °r`:'r`, Hello