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Home My WebLink About20182749.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 August 23, 2018 Dear Sir or Madam: RECEIVED AUG 2 8 2018 WELD COUNTY COMMISSIONERS On August 30, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Silverback 36-A 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 Ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Lary Wolk, MD, MSPH, Executive Director and Chief Medical Officer �u,�31 i tr IS4.4l.G14) CC . pL .PMMJTPP H L C.S 09-05 -I% 1,14 mill og/ a8 I , 2018-2749 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil a Gas, Inc. - Silverback 36-A Production Facility - Weld County Notice Period Begins: August 30, 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: Silverback 36-A Production Facility Oil and gas production facility NENW Sec 36 T12N R62W Weld County The proposed project or activity is as follows: Source is requesting to operate new sources for flaring of gas at an existing production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0271 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 COtORA DO I50lip. use Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Carissa Money. Package If: 376100 Received Date: 3/9/2018- Review Start Date: 8/14/2018 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: ',Exploration & Production Well Pad What industry segment? OR & Natural Gas Production &Processing Is this facility located in a NAAQS non attainment area? - No If yes, for what pollutant? ❑ Carbon Monoxide (co) Extraction Oil & Gas, Inc. 123 9E67 Silverback 36-A Production Facility. NENW quadrant of Section 36, Township 125, Range 62W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NENW '. Particulate Matter (PM) i ( Ozone (NOx & VOC) 36 1214 62 AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 007 Separator Venting Sales Gas Venting Yes 18WE0271- 1 Yes Permit Initial fssuanee 008 Separator Venting LP Gas Venting Yes 18WE0272 1 Yes Permit Initial -- issuance Section 03 - Description of Project The source is requesting to permit equipment at an existing E&P site. The site had an existing well and the source drilled a new well, The source is requesting individual permits for the LP separator venting, and sales gas venting, The source is also requesting individual permits for crude oil tanks, produced water tanks, and condensate loading (package 384364, permits 18WE0744, 18W€0745 and 18WE0746). There are also several eninges at the site covered by GP02. I confirmed this site is located outside (north) of the NAA boundary. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section OS - 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. Y Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants hers 502 NOx CO VOC PM2.5 PM10 Prevention of Significant Deterioration (PSD) SO2 NOx CO VOA PM2.5 PM10 TSP HAPs DOODD TSP El ❑J HAPs Colorado Air Permitting Project Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) O CI Separator Venting Emissions Inventory 002 Separator Venting Facility AIRs ID: 9E67 Plant Point Section 02 - Equipment Description Details Venting of sales gas fro Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates two high -pre Primary Emissions - Separator Actual Throughput= '''109,51.: MMscf per year e separators Requested Permit Limit Throughput = 125.0 MMscf per year Requested Monthly Throughput= 11 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 125 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL o liquids throughput: Section 04 - Emissions Factors & Methodologies Description Source used expected tttruughputofYatei 352". Btu/scf 23,993 lb/lb-rnol MW Weight % Helium CO2 N2 methane ethane 56 46.90' propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 17;43 dA: 7:90' 005 0:59' 0.09 0.001 06 0)01- 0,02 Total VOC Wt % 100.00 33.62 scf/bbl Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) VOC 21281.6 Benzene 22.790 Toluene 34.818 Ethylbenzene 6.9637 Xylene 9.4959 n -Hexane 251.96 224 TMP pollutant 0.0000 (Gas Throughput) 064.1 1.1395 .7409 0.3482 0.4748 2.598 0.0000 Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) lb/MMscf (Gas Throughput) PM10 'RL5S75 10.074 22/20/2016 at Silverbeckt Displacement Equation Ex=Q•MW•Xx/C Emission Factor Source Emission Factor Source 3 of 10 K:\PA\2018\18 W E0272.CP1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncomrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 5Ox NOx VOC CO 0.63 0.55 0.55 0.6 0.6 107 0.63 0.55 0.55 0.6 0.6 107 0.05 0.04 0.04 6.0 0.05 8 5.75 4.99 4.99 5,7 5.7 976 1330.10 1154.23 57.71 1330.1 66.5 11297 26.20 22.73 22.73 26.2 26.2 4450 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled llbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled tpy tpy Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2849 2472 124 2849 142 1.42 0.07 4352 3777 189 4352 218 2.18 0.11 870 755 38 870 44 0.44 0.02 1187 1030 52 1187 59 0.59 0.03 31495 27330 . 1367 r 31495 1575 15.75 0.79 0 0 0 0 0 0.00 0.00 Section 06 - Re ulg story summa Anal sis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is subject to Regulation 7, Section XV11.0.2.0 (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? 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 an an we 4 410 K:\PA\2018\ 18WE0272.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes • Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point 6 007 Process 9 SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 10.07 0 lb/MMSCF PM2.5 10.07 0 lb/MMSCF 105 0.80 0 Ib/MMSCF NOx 91.94 0 lb/MMSCF VOC 21281.60 95 lb/MMSCF CO 419.13 0 lb/MMSCF Benzene 22.79 95 Ib/MMSCF Toluene 34.82 95 lb/MMSCF Ethylbenzene 6.96 95 lb/MMSCF Xylene 9.50 95 lb/MMSCF n -Hexane 251.96 95 lb/MMSCF 224 TMP 0.00 95 Ib/MMSCF 5 of 10 K:\PA\2018\18WE0272.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re , ulatiun 3 Parts A and B - APEN and Penn it Requirements 'Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, PartA,5ection ll.D.l.a)1 2. Are total fac'iry uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 0.0.3)? 'Source requires a permit NON -ATTAINMENT 1. Are uncontroled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facilgy uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section l 0.0.2)7 'You have indicated that source Is In the Attainment Area Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, orrecompleted on or after August 1,2014? 'Source is subjectto Regulation 7, Section XVII. 5.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section )(VMS - Emissions Control Alternative Emissions Control (Optional SectIon) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is subject to Regulation 7, Section 50 11.0.2.0 Section XVII.B.2.—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 fads and circumstances. This document dyes not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ ifs implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,"may,""shoutµ"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. • \fe 3 1 Source Req Yks- �'1 5 rce Req Source Is st 2g`•`'m:I„ The control Separator Venting Emissions Inventory 001 Separator Venting Facility AIRs ID: County E Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Venting of gas from two low-pressure separators Enclosed flare Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency Limited Process Parameter Gas meter for Er Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = 5.0 MMscf per year Requested Monthly Throughput = MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 5 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description Source use 2018 Btu/scf LP separator gas from Poor MW 364543. Weight Helium C02 N2 methane ethane 4.57 0.477 ........ :::....16.77. propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies Total VOC Wt 7,52'. 4i 2 0,54 a 3.10' L31: 0.49' 0:001 0.23 0-. 37: Emission Factors 100.00 67.16 scf/bbl Ib/Ib-mol Separator Venting Uncontrolled Pollutant (Ib/MMscf) VOC Benzene Toluene E yIbenzene Xylene n -Hexane 224 TMP Pollutant (Gas Throughput) 64597.3 219.69 217.67 33.376 58.096 1684.3 0.6733 Controlled (lb/MMscf) (Gas Throughput) 10.883 2.9048 0.0337 Primary Control Device Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) 15.038 625.65 ample of LP eparatorgas toile Displacement Equation Ex=Q•MW •Xx/C Emission Factor Source Emission Factor Source 7 of 10 K:\PA\2018\18W E0272.CP1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 0.04 0.02 0.02 0.0 0.0 6 PM2.5 0.04 0.02 0.02 0.0 0.0 6 SOx 0.00 0.00 0.00 0.0 0.00 1 NOx 0.34 - 0.16 0.16 0.3 0.3 58 VOC - 161.49 77.52 3.88 161.5 8.1 1372 CO 1.56 0.75 0.75 1.6 1.5 266 Potential to Emit Actual Emissions Requested Permit Limits Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) tpy tpy Benzene 1098 527 26 1098 55 0.55 0.03 Toluene 1088 522 26 1088 54 0.54 0.03 Ethylbenzene 167 80 4 167 8 0.08 0.00 Xylene 290 139 7 290 15 0.15 0.01 n -Hexane 8422 4042 202 8422 421 4.21 0.21 224 TMP 3 2 0 3 0.2 0.00 0.00 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B2.e (See regulatory applicability worksheet for detailed analysis) Section Si - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVI1.8.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? 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? Napa �h If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an an 8 of 10 K:\PA\2018\ 18WE0272.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 008 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 15.04 0 Ib/MMSCF PM2.5 15.04 0 Ib/MMSCF 5O8 1.19 0 Ib/MMSCF NOx 137.24 0 lb/MMSCF VOC 64597.31 95 Ib/MMSCF CO 625.65 0 Ib/MMSCF Benzene 219.69 95 Ib/MMSCF Toluene 217.67 95 lb/MMSCF Ethylbenzene 33.38 95 lb/MMSCF Xylene 58.10 95 Ib/MMSCF n -Hexane 1684.30 95 lb/MMSCF 224 TMP 0.67 95 Ib/MMSCF 9 of 10 K:\PA\2018\18WE0272:CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Am total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY ar CO emissions greater than lO TPY (Regulation 3, Part B, Section 11.1.3)? 'Source requires a permit NON•ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section Il.D.1.a)? 2. Are total facgity uncontrolled VOC emissions from the greater than 2 TPY, Non greater than 5TPY or CO emissions greater than 10 TPY (Regulation 3, Part 5, Section 11.0.2)? 'You have indicated that source is in the Attainment Area Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? 'Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.8.2 — General Provisions far Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional section( Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,"may," "should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Req Source Reg �y '='' ` The control Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment DRAFT CONSTRUCTION PERMIT 18WE0271 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil &t Gas, Inc. Silverback 36-A Production Facility 123/9E67 NENW SEC 36 T12N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Sales Gas Venting 007 Venting of sales gas from two high pressure (HP) separators Elevated open flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO titian Control Division Page 1 of 7 DRAFT 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Sales Gas Venting 007 --- 5.7 66.5 26.2 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Sales Gas Venting 007 Elevated open flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) COLORADO it Pollution Control Division trti kr ta,?MnrTgot Page 2 of 7 DRAFT Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Sales Gas Venting 007 Gas Venting 125.0 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 open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of 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 COLORADO .Air Pollution Cartiro' Division M.VITIVre.. Puzlist:1,6agI ErvArorIVM Page 3 of 7 DRAFT 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually bliApril 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. 17. 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 18. 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. 19. 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 COLORADO it Pollution Control Division .'X11 ?i$ hw;Vl' Page 4 of 7 DRAFT 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. 20. 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. 21. 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. 22. 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. 23. 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. 24. 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 a Gas, Inc for venting of gas from two high pressure separators (AIRS ID 007) COLORADO Air Pollution Control Division De?,' VttrA l!. 3f Pui t °.±Y Er En4srr nets: Page 5 of 7 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. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Sales Gas Venting 007 Benzene 71432 2,849 142 Toluene 108883 4,352 218 Ethylbenzene 100414 ` 870 44 Xylenes 1330207 1,187 59 n -Hexane 110543 31,495 1,575 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 007: CAS # Pollutant Weight Percent of Gas (%) Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx --- 91.939 91.939 AP 42, Table 13.5-1 CO --- 419.13 419.13 AP -42, Table 13.5-2 VOC 33.6 21,282 1064.1 Extended gas analysis 71432 Benzene 0.04 22.790 1.1395 Extended gas analysis 108883 Toluene 0.06 34.818 1.7409 Extended gas analysis `COLORADO Air Pollution Control Division (,),9 t^exu Page 6 of 7 DRAFT 100414 Ethylbenzene 0.01 6.9637 0.3482 Extended gas analysis 1330207 Xylene 0.02 9.4959 0.4748 Extended gas analysis 110543 n -Hexane 0.40 251.96 12.598 Extended gas analysis 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP, CO PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health Et Environment DRAFT CONSTRUCTION PERMIT 18WE0272 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Silverback 36-A Production Facility 123/9E67 NENW SEC 36 T12N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP Gas Venting 008 Venting of gas from two low pressure (LP) separators Enclosed flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Divi"sion. Page 1 of 7 DRAFT 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO LP Gas Venting 008 --- --- 8.1 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LP Gas Venting 008 Enclosed flare -r= VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) [COLORADO Air Pollution Control Division 1.krairki kit 3i Fu t f lAth Page 2 of 7 DRAFT Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LP Gas Venting 008 Gas Venting 5.0 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 low pressure separator(s) using the flow meter. The owner or operator shall use the sum of monthly throughput records from all low 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; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 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 'COLORADO :Ail Pollution Control Division Page 3 of 7 DRAFT 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) ADDITIONAL REQUIREMENTS 16. 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. 17. 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 18. 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. 19. 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 COLORADO - Air Pollution Control Division r : srrr>:'totc Page 4 of 7 DRAFT 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. 20. 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. 21. 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. 22. 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. 23. 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. 24. 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 Ft Gas, Inc for venting of gas from two low pressure separators (AIRS ID 008) COLORADO it P nution Control Division Mra 04 t3e,7tit r:earth ETW,tOr:M ,f; Page 5 of 7 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 wilt be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP Gas 'Venting 008 Benzene 71432 1,098 55 Toluene 108883 1,088 54 Ethylbenzene 100414 167 8 Xylenes 1330207 290 15 n -Hexane 110543 8,422 421 2,2,4 Trimethylpentane 540841 3 0.2 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 008: CAS # Pollutant Weight Percent of Gas (%) Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) - Source NOx --- 137.24 137.24 AP 42, Table 13.5-1 CO --- 625.65 625.65 AP -42, Table 13.5-2 VOC 67.2 64,597 3,229.9 Extended gas analysis 71432 Benzene 0.23 219.69 10.984 Extended gas analysis DRAFT 108883 Toluene 0.23 217.67 10.883 Extended gas analysis 100414 Ethylbenzene 0.03 33.376 1.6688 Extended gas analysis 1330207 Xylene 0.06 58.096 2.9048 Extended gas analysis 110543 n -Hexane 1.75 1,684.3 84.215 Mended gas analysis 540841 2'2'4-0.001 Trimethylpentane 0.6733 0.0337 Extended gas analysis 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP, CO PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Aar Pollution C4ntrot Divisfi Page 7 of 7 Colorado Air Permitting Project County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploration & Production Welt Pad What industry segment? 0it & Natural Gas Production &Processing Is this facility located in a NAAQS non attainment area? If yes, for what pollutant? PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Cadssa Money Packaged: 384364 Received Date: 6/25/2018 Review Start Date: 8/16/2018 Section 01 - Facility Information Company Name: Extraction oil & Gas, I 123 9667 SGiverback 36•A Production Facility NENW quadrant of Section 36, Township 12N, Range 62W Weld County Section 02 - Emissions Units In Permit Application de (CO) No. Quadrant Section Township Range N' 36 12N 62 _z Particulate Matter (PM) ❑ Ozone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Liquid Loading Hydrocarbon loading No 18W90746 2 YeS Permit Initial ISSuanCe Converting from GP07 002 CrudeOlTTank ..: CrudeOil torageTanks Yes. 18WE0744 1 Yes ... , Permit Initial, Issuance Converting fromGPM 003 - Produced Water Tank PWTanks Yes -'..18WE0745 1 Yes .:.PermitInitial issuance Converting,_ from OPUS Section 03 - Description of Project The source is requesting to modify three existing points at an existing facility to convert from GP to individual perm€ts, The source needs the individual permit limits instead o GP limits to maintain facility -wide emissions below 90 tpy and thus maintain GP02 coverage_ Please note that for Point 002, the source had an individual permit (16WE0337) and then in March 2018, requested GP48 coverage. Prior to an engineer review of the application, the source canceled the GP08 request and requested to maintain an individual permit Due to these application requests, the tanks received a new permit number instead of simply modifying the old permit Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greaterthan 50 tons -;per year in an Attainment Area _ Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? 502 NOx CO VOC PM2.5 PM10 TSP HAPs J ❑ ❑ Colorado Air Permitting Project If yes, explain what programs and which pollutants here 5O2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) L Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 T5P HAPs n❑ Hydrocarbon Loadout Emissions Inventory 001 Liquid Loading, acuity AIRS ID: 123 County ::9667 Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Hydrocarbon loadout to tank trucks:.. None Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded Requested Permit Limit Throughput = Potential to Emit (PTE) Volume Loaded = 0.00 76,432 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 101,353 Barrels (bbl) per year Requested Monthly Throughput = 101,353tparrels (661) per year Barrels (bbl) per year 8608 Barrels (bbl) per month I Secondary Emissions - Combustion Device(s) Emission Factor Hydrocarbon Loadout Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? MMBTU per year MMBTU per year MMBTU per year he state default emissions factors may be used to estimate emissions. Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) Emission Factor Source VOC = 0.1040 0.1040 0.0002 0.0000 0.0000 0.0000 0.00 0.0000 Benzene E 0.00010 Toluene Ethylbenzene Xylene n -Hexane 224 TMP 0.0016 Pollutant Control Device Uncontrolled (Ib/MMBtu) Uncontrolled (lb/bbl) Emission Factor Source 3 of 11 K:\PA\2018\18WE0745.CP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOn VOC CO 0.00 0.00 0.00 0.00 0.00 - 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 5.27 3.97 3.97 5.3 5.3 895 0.00 0.00 0.00 0.00 0.00 0 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Iles/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 18 14 14 18 18 0 D 0 0 0 0 0 0 0 0 0 0 0 0 0 162 122 122 162 162 0 0 0 0 0 Section 06- Re: ulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section II I.D.2.a (See regulatory applicability worksheet for detailed analysis) Site is in attainment and not subject to RACT Section 07 - Initial and Periodic Sampling and Testing Requirements You have indicated above the source is not controlled. The following question does not require an answer. Section 08 -Technical Analysis Notes_ AIRS Point # 001 Section 09 - Inventory SCC Coding and Emissions Factors Process # 01 SCC Code 4-06-001-32 Crude On: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 2,5 0 lb/1,000 gallons transferred CO 0.00 0 lb/1,000 gallons transferred Benzene 0.00 0 lb/1,000 gallons transferred Toluene 0.00 0 lb/1,000 gallons transferred Ethylbenzene 0.00 0 lb/1,000 gallons transferred Xylene 0.00 0 lb/1,000 gallons transferred n -Hexane 0.04 0 lb/1,000 gallons transferred 224 TMP 0.00 0 lb/1,000 gallons transferred 40111 K:\PA\2018\18W E0745.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Perrnit�uirements (Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude og per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation3, Part B, Section 11.0.3)? 'Source requires a permit NON -ATTAINMENT 1. 2. Are uncontrolled emissions from any criteria pollutants from this individual source greater -than 1 TPY (Regulation 3, Part A, Section 11.1.1.0)7 Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Fart B, Section 11.0.1.1)? 3. Isthe loadout operation loading less than 10,000 gallons (238 BBi,$) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facilty uncontrolled VOC emissions from the greater than 2TPY, N0x greater than STPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, Section 11.0.2)7 You have indicated that source Is in the Attainment Area 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation3, Part B, Section 01112.W ARP.':'.,. Y: Ivies is in attainment and not subject to RACT 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 applyto a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language Mitre Clean Air Act„ its implementing regulations, and Air Qualify Control Commission regulations, the language of the statute or regulation will control. The use ofnon-mandatory language such as'recommend,"°may,"should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "musr and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Go to next. Go to then Go to next Go to next Go to next The loadou Crude Oil Storage Tank(s) Emissions Inventory 002 Gude Oil Tank Facility AI Rs ID: 123' 9E61 002 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Four SOO bbl fixed roof crude oil storage vessels connected via liquid man Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput= Requested Permit Limit Throughput = 461 Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating = ` 105,353: Barrels (bbl) per year Requested Monthly Throughput = 8608 Barrels (bbl) per month Potential to Emit (PTE) Throughput = Secondary Emissions- Combustion Device(s) Heat content of waste gas= - 3 Volume of waste gas emitted per BBL of liquids produced = 23 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 24 Barrels (bbl) per year 5 Btu/scf 6,867 MMBTU per year 8,241 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 9,889 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Crude Oil Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Crude Oil Throughput) (Crude Oil Throughput) VOC .6269 0.0813 0.0001 0.0001 0.00001 0.00002 0.0010 0.00001 Benzene Toluene 00030':. 0.0021': 0.0003 .. 0.0005 0.0196 0.0001 Ethylbenzene Xylene n -Hexane 224 TMP Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBiu) (Ib/bbl) (waste heat combusted) (Crude Oil Throughput) Emission Factor Source Emission Factor Source PM10 PM2.5 0.0075 0 8,0680 0.0006 0.0006 0.0055 0.0252 NOx CO Section OS - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) fibs/month) VOC 98.9 68.7 3.4 82.4 4.1 700 PM10 0.0 0.0 0.0 0.0 0.0 5 PM2.5 0.0 0.0 0.0 0.0 0.0 5 505 0.3 • 0.2 0.2 0.3 0.3 48 CO 1.5 1.1 1.1 1.3 1.3 217 Potential to Emit Actual Emissions Reque ted Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled _ Uncontrolled Controlled (lbs/year) fibs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 360 250 13 300 15 Toluene 254 176 9 211 11 Ethylhenzene 36 25 1 30 2 Xylene 57 40 2 48 2 n -Hexane 2383 1655 83 1986 99 224 TMP 16 11 1 14 1 Section 06 - Regulator/ Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 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, MACr Subpart HH Storage Tank is not subject to MACTHH (See regulatory applicability worksheet for detailed analysis) 6 of 11 K:\PA\2018\18W E0745.CP1.xlsm Crude Oil 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 20 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 14-03 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 of crude oil drawn at the'' - facility being permitted? If no, the permit will contain en "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. 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 Section 08 - Technical Analyses Notes The tanks are not subject to NIPS 0000 because ,he emorceable control emissions are less than 6 toy These tanks rere permitted under 16WE0337 In March 2018, the so rc requested to cancel the ndividuaI petmit and be covered under OPUS The division logged in the March 201$ application but pr or to the application be rig rev ewed, the sources bm�ted a rev sed application Lune 2418 to maintain an: rid v�dua, permit for the. tanks The fa_ilily-w de VOC emissions are at 89 toy, thus, far the source tc mam,t'r GPO2 'ftcoverage, the tanks mu5i be covered. by an in ividuaIpermt Lm t.D'oe to the multiple apps cations, the tank_ will get a new perm t nuln ber instead of simply a mod hcation to the eniacin permit number. Section 09 - Inventory 5CC Coding and Emissions Faders AIRS Point # 002 81 Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.01 0.01 0.13 38.7 0.60 0.07 0.05 0.01 0.01 0.47 0.00 Control% Units O lb/1,000 gallons crude oil throughput O lb/1,000 gallons crude of throughput O lb/1,000 gallons crude of throughput 95 lb/1,000 gallons crude oil throughput O lb/1,000 gallons crude oil throughput 95 1b/1,000 gallons crude of throughput 95 lb/1,000 gallons crude oil throughput 95 lb/1,000 gallons crude oil throughput 95 lb/1,000 gallons crude oil throughput 95 lb/1,000 gallons crude oil throughput 95 1b/1,000 gallons crude oil throughput 7 of 11 K:\ PA\2018\18 W E0745,;CP1.x I s m Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A,Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to N2 is yes, Is the crude oil throughput less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.2.2)? You have indicated that source is in the Attainment Area No Colorado Regulation 7, Section XVII 1. Is this tank located at a transmisslon/storage facility? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this crude oil storage tank a fixed roof storage tank? 4. Are uncontrolled actual emiss ons° of this storage tank equal to or greater than 6 tons per year VOC? Yes tom, _. won 'Storage tank Is subject to Regulation 7, Section XVII, 8, C.184 C.3 Section XVILB —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section 00111,1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. 'Storage tank is subject to Regulation 7, Section 0011.1.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart I.32, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the Individual storage vessel capacity greater than or equal to 75. cubic meters (m) ("472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 ms [^10,000 BBL] used for petroleum' or ondensate stored, processed, or treated prior to custody transfer' as defined in 60.11lb? 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 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa [-29.7 psi] and without emissions to the atmosphere (60:110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m' ("950 BBL] and stares a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 Mt ("472 BBL' but less than 151 ms [`950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.1126 - Emissions Control Standards for VOC §50.153k - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude OII and Natural Gas Production, Transmission and Distribution 1. Is this crude ail storage vessel located at a facility in the onshore ail and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel"' per 60.5430? 'Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures §00.5395(g) -Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a norage vessel Is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6tons per year] 40 CFR, Part 63, Subpart MAR HH Olt and Gas Production Facilities 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria; a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 1. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel"' in 63.751? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank sublease control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Yes Yes Source Req Go to next Source Req Continue -' Continue-' Go to the n Source is at 'I5ource isst 'Storage Tank is not subject to MAR HH Subpart A, General provisions per §63.7 §63.766- Emissions Control Standards §63.773 - Monitoring §63.774-Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer (a) Table 2 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 isnot a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute orregtdation will control. The use of non -mandatory language such as "recommend,"°may," "should"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must' and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Go to then Storage Tar Continue -' Storage Tar Continue-' Storage Tar Produced Water Storage Tank(s) Emissions Inventory 003 Produced Water Tank Facility AIRs ID: 123 i 9E67 003 Plant Section 02- Equipment Description Details Detailed Emissions Unit One 300 bbl fixed roof produced water storej Description: Emission Control Device Enclosed flare Description: Requested Overall VOC & HAP Control Efficiency °6: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = 229,391: Barrels (bbl) per year 273,997 Barrels (bbl) per year Requested Monthly Throughput = Actual Produced Water Throughput While Emissions Controls Operating = 228,331;! 23271 Barrels (bbl) per month f Potential to Emit (PTE) Produced Water Throughput = 28,796! Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= ' ';. _ � Y49G! Btu/scf Volume of waste gas emitted per BBL of liquids produced= ; 36: scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 12,297 MMBTU per year 14,756 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 17,708 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 4.262........__. 0.013 0.0004 0.0000 0.0000 0.0000 0.0011 0.0000 Control Device Benzene Toluene oo' Ethylbenzene Xylene n -Hexane 224 TMP 0.0220 Emission Factor Source Emission Factor Source Pollutant Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) PM10 PM2.5 NOx CO 00680 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 43.1 29.9 1.5 35.9 1.8 305 0.1 0.0 0.0 0.1 0.1 9 0.1 0.0 0:0 0.1 0.1 9 0.6 0.4 0.4 0.5 0.5 85 2.7 1.9 1.9 2.3 2.3 389 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2302 1598 80 1918 96 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 7234 5023 251 6028 301 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NIPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 9 of 11 K:\PA\2018\18 W E0745.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? 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 tanks are not subject to NSPS.OOOOa because the enforceable control em i sons are less than 6 tpy. Section 09 - Inventory SCC Coding and Emissions Factors AIRS. Point # Process # SCC Code 003 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons liquid throughput PM2.5 0.01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n -Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 10 of 11 K:\PA\2018\18WE0745.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks et water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the 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 11.0.1.5)? 2. Is the operator claiming less than 1% crude oil and is the tank located eta non-commercial facility for processing oil and gaswastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 50 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? (Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section II.0.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part e, Section II.D.1.M) 3. Are total fadlity uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.2.2)? 'You have indicated that source is in the Attainment Area Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4, Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons peryear VOC? Yes No Yes Yi Storage tank is subject to Regulation 7, Section XV II, 6, C.1 & C.3 Section XVII.0 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1' Emissions Contra! and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. (Storage tank is subject to Regulation 7, Section 501102 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60. Subpart 0000. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located eta facility in the onshore oil and natural gasproduction segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2- Was this produced water storage vessel constructed, reconstructed, or modified ed (see definitions 40 CFR, 60.2) between August 23, 2011 and September 58, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? (storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures §60.5395(g) -Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 -Control Device Monitoring Requirements Note: If a storage vessel is previously determined to be sublect to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] RACT Review RACT review is required If Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, 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 situa0on based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as"recommend,"'may," "should," and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulatons, but this document does not establish legally binding requirements in and of itself. Yes WORSE Source Req Go to next Source Req Continue-' Continue-' Go to then Source is sr Continue-' Storage Tat Permit number: Date issued: Issued to: Do ontrol Division Department of Public Health b Environment STRUCTION PERMIT 8WE0744 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil a Gas, Inc. Silverback 36-A Production Facility 123/9E67 NENW SEC .36 T12N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Crude Oil Tanks 002 Four (4) 500 barrel fixed roof storage vessels connected via liquid manifold and used to store crude oil Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 'COLORADO Air Pollution Conti Livision Page 1 of 8 3. his p ' mi s`" expi e o er r operator of the source for which this permit was issued: s n.,. co , e e co ruc n/ modification or operation of this source within 18 months a er eit er, the • a` e o 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 Div �: grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator sha omplete all initial compliance testing and sampling as required in this permit and submit the sults to the Division as part of the self -certification process. (Regulation Number 3, Part ction III. E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO Crude Oil Tanks 002 --- --- 4.1 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Crude Oil Tanks 002 Enclosed Flare VOC and HAP COLORADO iz Pollution Control Division Page 2 of 8 PROC T ND 8. our al it- • flowing 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 Facile ` "` Equipment I AIRS Point Process Parameter Annual Limit Crude Oil Tan 002 Crude Oil throughput 101,353 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of 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 COLORADO Aar Pollution Control Division I,Wi n& k R ptle waif & £smrnrsner. Page 3 of 8 approval prior to implementation. (Regulation Number 3, COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference M4 • 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions P, `Visible Emissions" means observations of smoke for any period or periods of duration greater han or equal to one minute in any fifteen -minute period during normal operation. (Regu ion Number 7, Sections XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 16. This permit replaces the following permit, which is cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point 16WE0337 123/9E67/002 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. 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 COLORADO Air Pollution Control Division Page 4 of 8 19. m a`- any ;.""': ' men.' ust be retained and made available for inspection upon ay b ;eiss „ -d to a new owner by the APCD as provided in AQCC Regulation umber , art :, ec ion :. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "fina '' • y for this activity or operation of this source. Final authorization of the permit must •e 5 cured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be grante Y until the operation or activity commences and has been verified by the APCD as conforming respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to -operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc for four 500 bbl COLORADO Air Pollution Control Division L aetmaYt ,t H L C t „tr; £r Emtror rn, Page 5 of 8 crude oil storage tanks (AIRS ID 002) COLORADO `r Pollution Pollution. Control Division rc Page 6 of 8 Notes mit issuance: 1) T it hfor the processing time for this permit. An invoice for these fees wilt 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 based on the con urn upon request of the control regulation or and complete applic terial processing limits and emission limits contained in this permit are io rates requested in the permit application. These limits may be revised ner or operator providing there is no exceedance of any specific emission y ambient air quality standard. A revised air pollution emission notice (APEN) on form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 300 15 Toluene 108883 211 11 Ethylbenzene 100414 30 2 Xylenes 1330207 48 2 n -Hexane 110543 1,986 99 2,2,4- Trimethylpentane 540841 14 1 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0055 0.0055 AP -42, Chapter 13.5 CO 0.0252 0.0252 AP -42, Chapter 13.5 V0C 1.6269 0.0813 Source 71432 Benzene 0.0030 0.0001 Source 108883 Toluene 0.0021 0.0001 Source 100414 Ethylbenzene 0.0003 0.00001 Source. 1330207 Xylene 0.0005 0.00002 Source 110543 n -Hexane 0.0196 0.0010 Source 540841 2'2'4 Trimethylpentane 0.0001 0.00001 Source 'COLORADO Air Pollution Control Division H.Y.n; =At_h Fos.rgriftWt Page 7 of 8 fo this point are based on the flare control efficiency of 95%. 6) I°`nc 5- -•ch 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 threquirement to hold a valid permit reflecting the storage tank and associated control device per a Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, 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, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Aar Pollution Control Division Emtromulw, Page 8 of 8 Permit number: Date issued: Issued to: DO ontrol Division Department of Public Health & Environment STRUCTION PERMIT Issuance: 1 Extraction Oil Et Gas, Inc. Facility Name: Silverback 36-A Production Facility Plant AIRS ID: 123/9E67 Physical Location: NENW SEC 36 T12N R62W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Produced Water Tanks 003 One (1) 500 barrel fixed roof storage vessel used to store produced water Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the tatter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the tatter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division Di -y rt, .≥hi OS C?,tr 4 YB::Y FAvi rtme§4 Page 1 of 8 3. his p mis- expi ' '° e o er•r operator of the source for which this permit was issued: n/ modification or operation of this source within 18 months a er eit er, the •ae o 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 Div ' F grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator sha complete all initial compliance testing and sampling as required in this permit and submit the 'i sults to the Division as part of the self -certification process. (Regulation Number 3, Part ction III. E. ) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO Produced Water Tanks 003 --- --- 1.8 2.3 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Produced Water Tanks 003 Enclosed Flare VOC and HAP COLORADO Air Pollution Control Division r1A 7f .:C rsr �a[ rr F,t,roY—s:'n::e Page 2 of 8 PROC T._ ND 8. our Rowing 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 Facili ; Equipment I r % AIRS Point Process Parameter Annual Limit Produced Wat Tanks ,y 003 Produced water throughput 273,997 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating property. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shalt install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t 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 COLORADO Air Pollution Control Division t:tartIrRnt Puitt Page 3 of 8 o g basis with the requirements of this permit. Revisions to on approval prior to implementation. (Regulation Number 3, art B, Sec ion I COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or shall demonstrate compliance with opacity standards, using EPA Reference Metho 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 han or equal to one minute in any fifteen -minute period during normal operation. (Reg o° '.n Number 7, Sections XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 16. This permit replaces the following permit, which is cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point GP05 123/9E67/003 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO), per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. 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). _:COLORADO Air Pollution Control Division Page 4 of 8 19.ust be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit lly states that final authorization has been granted,then the remainder of this condit •n n. applicable. Otherwise, the issuance of this construction permit does not provide "final" a gz` ority for this activity or operation of this source. Final authorization of the permit must be cured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer COLORADO Air Pollution Control Division Page 5 of 8 Is ? . Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc for one 500 bbl produced water storage tank (AIRS ID 003) COLORADO Poiiutior Control Division Page 6 of 8 mit issuance: 1) T 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 based on the con um upon request of the control regulation or and complete applic terial processing limits and emission limits contained in this permit are io rates requested in the permit application. These limits may be revised ner or operator providing there is no exceedance of any specific emission y ambient air quality standard. A revised air pollution emission notice (APEN) on form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 1,918 96 n -Hexane 110543 6,028 301 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0037 0.0037 AP -42, Chapter 13.5 CO 0.0167 0.0167 AP -42, Chapter 13.5 VOC 0.262 0.013 CDPHE, PS Memo 09-02 71432 Benzene 0.0070 0.0004 CDPHE, PS Memo 09-02 110543 n -Hexane 0.0220 0.0011 CDPHE, PS Memo 09-02 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. COLORADt. Air Pollution Control Division Page 7 of 8 8) Th a is Via' . ied ws: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, HAPs Synthetic Minor Source of: VOC 9) Full text of the Title °;; 0, Protection of Environment Electronic Code of Federal Regulations can be found at the websit ed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO PoltUtton Control Division Page 8 of 8 CONSTRUCTION PERMIT Permit. number: Date issued: Issued to: 18WE0746 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Ft Gas, Inc. Silverback 36-A Production Facility 123/9E67 NENW SEC 36 T12N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Hydrocarbon Loadout 001 Truck loadout of crude oil by submerged fill None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.Qov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 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 =COLORADO Aar Pollution Control Division R;L•zYrii tn,F:rr`nt Page 1 of 7 construction or activity wa associated with this permit; more; (iii) does not comple he per <; t application of eigh € -n months or e esti completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Hydrocarbon Loadout 001 --- --- 5.3 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for criteria pollutants OR 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. PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Hydrocarbon Loadout 001 Crude Oil Loaded 101,353 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 7. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) °CO1.OR_ADO .Aar Pollution' Control Division L?t ;_.5r rt...P F°alai 1,3�i Cr <t EeMte)f::^3r! It Page 2 of 7 STATE AND FEDERAL REGULATORY 8. Visible emissions shall not opanormal - .tion of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. a 4.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 11. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. The owner or operator shall inspect all compartment hatches at the facility (including thief hatches) at least monthly. Each inspection shall be documented in a log available to the Division on request. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. OPERATING Et MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL. REQUIREMENTS 14. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point GP07 123/9E67/001 15. 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: COLORADO taro' tarot Division Page 3 of 7 For sources of five (5) to ual emissions ast APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 16. 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. 17. 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. 18. 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. 19. 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. 20. 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 COLORADO Air Pollution Control Division anmem Pui .. hi43Zii': tT F'?_ Mil i'Y;E::S Page 4 of 7 Quality Control Commission QCC), lut g .°'lure t - _ :any �� '. r- s term condition of the permit. If the Division dies . rmi -' onions mpos upo permit a contested by the owner or operator, or - •''sion rem: _ " a , the perato source may request a hearing before the AQCC for review of the Division's action. 21. 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. 22. 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 Ft Gas, Inc for hydrocarbon loadout (AIRS ID 001). COLORADO r Pollution Control DiviS ozl Page 5 of 7 Notes to Permit Holder at the time o 1) The permit holder is required t�;,,� �� or d� o E.*-: me� it. An e for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 18 18 n -Hexane 110543 162 162 Note: ALL non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.1040 0.1040 CDPHE, PS Memo 14-02 Benzene 71432 0.00018 0.00018 CDPHE, PS Memo 14-02 n -Hexane 110543 0.0016 0.0016 CDPHE, PS Memo 14-02 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, HAPs COLORADO r Pollution Control Division Page 6 of 7 PSD Synt V0C S•' ce .: 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division .t; -rent/ Rai;3C i ed,tr:.t?4^,r," Aert Page 7 of 7 Silverback 36-A Liquid Loading APEN Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: 18WE0746 AIRS ID Number: 123 / 9E67 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Silverback 36-A Production Facility Site Location: NENW SEC 36 T12N R62W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Kelli Cox Phone Number: 720-354-4597 E -Mail Address2: kcox@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any charges 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. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I Silverback 36-A Liquid Loading APEN Permit Number: 18WE0746 AIRS ID Number: 123 / 9E67 / 00 1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source O Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Previously submitted permit application listed source as controlled. The source is not controlled and this APEN corrects the previous error. 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: Loading of condensate liquid onto tanker trucks for transport. Company equipment Identification No. (optional): For existing sources, operation began on: 12/11/2017 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? ■ Yes E2 No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No ■ MI Is this source located at an oil and gas exploration and production site? Yes No p ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • p Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ MI Does this source submerge fill less than 16308 bbl of condensate per year? Yes No • p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 21 Silverback 36-A Liquid Loading APEN Permit Number: 18WE0746 AIRS ID Number: 123 / 9E67 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: O Condensate 0 Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 101,353 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: Tank Trucks (e.g. "rail tank cars" or "tank trucks") 76,432 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: N/A Average temperature of bulk liquid loading: N/A °F True Vapor Pressure: N/A Psia @ 60 °F Molecular weight of displaced vapors: N/A lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year Product Density: N/A lb/ft3 Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 Silverback 36-A Liquid Loading APEN Permit Number: 18WE0746 AIRS ID Number: 123 /9E671001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information raphical Coordinates titude/Longitride ai N/A Indicate the direction of the stack outlet: (check one) N/A N/A N/A N/A N/A ❑ Upward ❑ Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): N/A 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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: Rating: Type: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: MMBtu/hr Make/Model: Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: O Yes O No Pilot Burner Rating: MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 7/2018 4I Silverback 36-A Liquid Loading APEN Benzene 71432 PM PM Permit Number: 18WE0746 AIRS ID Number: 123 I 9E67 /001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (4% reduction): an of controt Method veratl Requeste ontroi Efficienc reduction. in emis ions):? SOX NO. CO VOC HAPs Other: 9 Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane 0 Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL 9 Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected riteria Pollutant. Emissions lnvento uat=Annual Emission ncontroiled, mtsstons ` ons/year)_ ,`:; nested,Annua mission Limits 3.974 5.270 5.270 SOx NO. CO VOC 0.104 IbVOC/ bbl APCD Memo 14-02 3.974 on=Cnteria Reportable;Pollutanfi Emtssions'Invent° mission Fat ctual Annua mssiot Toluene 108883 Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 51 t>LGRAbt} fac<�rbw: Silverback 36-A Liquid Loading APEN Permit Number: 18WE0746 AIRS ID Number: 123 / 9E67 /001 [Leave btank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and wilt be operated in full compliance with each condition of General Permit GP07. 8/13/2018 Signature of Legally Authorized 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: El Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6! Silverback Crude Tank APEN Crude Oil Storage Tank(s) APEN - Form APCD-210 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 crude oil 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. condensate 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.Qov/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: AIRS ID Number: 123 / 9E67 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] L/C 18 Section 1 - Administrative Information Company Name: Extraction Oil & Gas, Inc. Site Name: Silverback 36-A Production Facility Site Location: NENW SEC 36 T12N R62W Mailing Address: (Include Zip code) 370 17th St, Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E -Mail Address2: ksteerman@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 384358 Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 1 I coiortxaa wy...mrrrr.- Silverback Crude Tank APEN Permit Number: AIRS ID Number: 123 / 9E67 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name o Change permit limit 0 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: Requesting coverage under new individual permit. 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: Storage of crude oil at E&P facility. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 12/11/2017 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: 0 Exploration Et Production (EEtP) site ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? • Yes El No Are Flash Emissions anticipated from these storage tanks? GI Yes ■ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No U O Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 4 • Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 21 CO O*Aoa Silverback Crude Tank APEN Permit Number: AIRS ID Number: 123 / 9E67 / 002 [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 4 - Storage Tank(s) Information n 84,461 101,353 From what year is the actual annual amount? Projected Average API gravity of sales oil: 39.2 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 9.8995 ❑ External floating roof age TD TankI # of ssels i Storage Ta Yesseis to Storage Tan1i Tota Doha e of Mora eTank g n411410; Date of Most ascent Store a masse in Storage Tek raopt7ar Da e of t irs Production inn Iyeaa � (m N/A 4 x 500 bbl 2000 10/2017 12/2017 z [s Srv�edy was Storage Tatak br Tank Battery 1;3 Satesy3� �� e 05 123 42283 Silverback 1 ■ 05 123 42282 Silverback 25N -20-3N 0 - ■ ■ _ ■ 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information 40.972567,-104.272202 ipe toe Stack fl sr is cftar e t el �171t.At ove i and ≥ el f gr'�h e aip � � few Rate �i _ ? '�- ; '- ` � eto se `> N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) I] Upward El Horizontal El Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular O Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Unknown Interior stack width (inches): Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 3 I C0t4Re.UC. liar= tsenetwart. Silverback Crude Tank APEN Permit Number: AIRS ID Number: 123 I 9E67 / 002 [Leave btank unless APCD has a„eady 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion Device: Pollutants Controlled: HAP, V®C Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (EELP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: VHLP Separator toiascAnu Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 4 Silverback Crude Tank APEN Permit Number: AIRS ID Number: 123 I 9E67 I 002 [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall �� c�Tlutant - D�scri tr0,11-19f Con trol t etl3odr ) verb ttequestednitoi Efficien �� 3a reduction in a Wish nsj . VOC ECD ss i NOx CO HAPs ECD ss r Other: From what year is the following reported actual annual emissions data? Projected *--PoilufanEm�ssons fnxentory, l}utani�� a --,-1.-nena Q Emission F ctor 3 Actual Annual.Emissions ested Ann;ra P rn1t am3557011 l imp §} Uncon rill d 8asts Units Source SAP 42 �1fg etc} i 3nc ntroiied fnussions ,moons/year) nfrolled Emissions � a year} i n ntrolied Emissions ons yeirr font oiled Eric scions VOC 1.6270 Ib/bbl Promax 68.709 3.435 82.451 4.123 NOx CO r ``` No feria Reporta�i Pollutant Emiss;onsinventor �- ,� �„.„,� `� ��emrcal Nam Lhermca A6str c" Sennce {CASE Dumber Emission Factor6 � Actual Annual Erim: - 7Jncontroile Basis Units Sour (AP -4 CO,Unrtrolled Emissr ns or}nc sfyear Con Tied Etnis ons Po yea Benzene 71432 0.00296 lb/bbl Promax 250.09 12.50 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.01959 lb/bbl Promax 1,654.59 82.73 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-210 - Crude Oil Storage_""ank(s) APEN - Revision 07/2017 5 I Silverback Crude Tank APEN Permit Number: AIRS ID Number: 123 / 9E67 / 002 [Leave bLank unless APCD has ai early assigned a permit r 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 GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Neig6vA Signature of Legally Authorized Person (not a vendor or consultant) � I .9 yo l ( I, Date Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ▪ Draft permit prior to issuance ❑Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 c6todcapd Form APCD-210Crude Oil Storage Tank(s) APEN Revision 07/20:7 6 I Silverback Produced Water APEN Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and JUN 2 5204 Application for Construction Permit D All sections of this APEN and application must be completed for both new and existing facilities, including APEN`'i ces updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/odphe/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: 1 YuoE a�k,s AIRS ID Number: 123 / 9E67 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Silverback 36-A Production Facility Site Location: NENW SEC 36 T12N R62W Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Site Location County: Weld NAICS or sIc Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E -Mail Address2: ksteerman@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 384359 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 1 I *ADC. cry Silverback Produced Water APEN Permit Number: AIRS ID Number: 123 / 9E67i 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name ❑ Change permit limit O Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source Additional Info Ft Notes: Requesting coverage under new individual permit. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Storage of Produced Water at E&P Facility. 12/11/2017 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week Storage tank(s) located at: 0 Exploration Et Production (EEtP) site 52 weeks/year O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? • Yes 0 No Are Flash Emissions anticipated from these storage tanks? 0 Yes • No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No SI Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes • No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 21 COLOOtAbei Silverback Produced Water APEN Permit Number: AIRS ID Number: 123 / 9E67 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information pga lues�i?c • 228,331 273,997 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof Projected ❑ Internal floating roof ❑ External floating roof tors ank ID �� » 1 gauid a fold Stow e ;Storage Vesse s in twge T -a rk ' ,. _ :� tat V ume of Tan -_ In illation gate c. most Recent Storage Vessel to Storage Tanrontear3ort/�rearj Date of First , P odt, tip N/A 1 x 500 bbl 500 10/17 12/2017 k or Tank Ba �4 �� ttStt ery es n ly� .e Name of We l ��.. s IVewiepofte� Vie[[ 5 - 123 - 42283 Silverback 1 • 5 - 123- 42282 Silverback 25N -20-3N • _ ■ ■ 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 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 40.972567,-104.272202 f�perator, ad ' True[ a Hew t b � mp � \ � r to tl- . � et i ce" wl ai N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) 0 Upward 0 Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) E Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches):. Unknown Interior stack width (inches): Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 - Siiverback Produced Water APEN Permit Number: AIRS ID Number: 123 / 9E67/ 003 [Leave blank unLess APCD has ad, assignedpermit d AIRS �� J 3.re _.-, ..isf� a r, 4'_ �N 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 98% % Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (EetP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: HLP Separator Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 Silverback Produced Water APEN Permit Number: AIRS ID Number: 123 / 9E67 / 003 [Leave blank unless APED has already assigned a permit 1 and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall Poiutal� z `cam ecrttto ©on1 Meth{�arten Q- e alt etlues-ted t CI- VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected �� I ttss o . A ItUa ttiss]C Di1 5 � �� ' � a - — , ncorttroiled -,.'131a5S onslyrat) „ trr�f ,0,- --z 557On ., . '� ��'7�SS1Q �7asfy or tro led � �1155�CpY35i�� onsear VOC 0.262 IbVOC/ bbl PS Memo 14-03 29.911 1.496 35.894 1.795 NOx CO 0.31 IbCO/MMBtu. AP -42 1.906 1.906 2.287 2.287 � 1n terJa eporta le Pollutant Em„ssao�as1nventory , ' �� 5S C1tetcHa e Y � E fission Factorb Act<uatAnn ��tntssto traz tae co t oil UO orttrotl i' basis ` tln�ts trotted. zi.�� f isms�os Benzene 71432 0.007 IbBenzene/bbl PS Memo 14-03 1598.314 79.916 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 ibn-Hexanerobi PS Memo 14-03 5023.272 251.164 2,2,4- Trimethyipentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 5 Silverback Produced Water APEN Permit Number: AIRS ID Number: 123 / 9E67/ 003 [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP05 or GPO8, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. (412-0 i20( Signature of Legally Authorized Person (not a vendor or consultant) Date Catie Nelson Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance ✓� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 CettOft Aoa Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 6 I Silverback 36-A Sales Gas Venting APEN po��,t v �7ci , , i'i f . 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 18WE0271 AIRS ID Number: 123 /9E67 /007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Silverback 36-A Production Facility Site Location: NENW SEC 36 T12N R62W Mailing Address: 37 (Include Zip Code) 0 17th St. Suite 5300 Denver, CO 80202 Site Location Weld County: NAICS or SIC Code: 211111 Contact Person: Kelli Cox Phone Number: E -Mail Address2: 720-354-4597 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. Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I Silverback 36-A Sales Gas Venting APEN Permit Number: 18WE0271 AIRS ID Number: 123 /9E67/007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source -OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name3 0 Add point to existing permit ❑✓ 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 - • Limit Hazardous Air Pollutants (HAPs). with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Permit modification to previous submittal, new permit limit requested. This point is addressed in the attached alternative emissions control request. 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: Combustion of sales gas. Company equipment Identification No. (optional): For existing sources, operation began on: 12/11/2017 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year O Yes Yes Yes ✓❑ No ❑✓ No ❑ No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2I Silverback 36-A LP Gas Venting APEN Permit Number: 18WE0272 AIRS ID Number: 123 / 9E67 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 4 - Process Equipment Information ✓❑ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5; Liquid Throughput Process Parameters5: Vented Gas Properties: 6 ❑ Yes ❑ No Vent Gas Heating Value: 2018.229 BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: N/A bbl/year Actual: N/A bbl/year Molecular Weight: 36.4543 Ib/Ibmol VOC (Weight %) 67.420 Benzene (Weight %) 0.228 Toluene (Weight %) 0.226 Ethylbenzene (Weight %) 0.035 Xylene (Weight %) 0.060 n -Hexane (Weight %) 1.751 2,2,4-Trimethylpentane (Weight %) 0.001 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3I Silverback 36-A LP Gas Venting APEN • Permit Number: 18WE0272 AIRS ID Number: 123 / 9E67 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.972567,-104.272202 Operator Stack ID No Discharge Height Above Ground Level (Feet) Temp ( ?« > low;Raie M e Velocr y (ta/ce N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Unknown Section 6 - Control Device Information El Check this box if noemission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: % Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: • Form APCD-211 - Gas Venting APEN - Revision 7/2018 41 Silverback 36-A Sales Gas Venting APEN PM Permit Number: 18WE0271 AIRS ID Number: 123 /9E67/007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM verall Requested ntrol Efficiern reductionin emissions SOX NO. CO VOC Open Tipped Flare 95% HAPs Open Tipped Flare 95% Other: From what year is the following reported actual annual emissions data? Projected ritena .Pollutant missions. Invento SO); NO. 0.068 IbNOXIMMBtu AP -42 Chapter 13.5 4.986 4.986 5.746 5.746 CO 0.31 IbCO/MSCF AP -42 Chapter 13.5 22.732 22.732 26.196 26.196 VOC 21.310 IbVOC/MSCF Site Specific Sampling 1155.765 57.788 .331.875 .66,594- 1536, 66-5 2,500.270 125.014 Benzene on-Criteria,ReportablePollutant Emissions Inventor 71432 0.023 mission`, lb Benzene/MSCF Site Specific Sampling ual.Annual,Emission Toluene 108883 0.034 lb TalueneiMSCF Site Specific Sampling 3,740.101 187.005 Ethylbenzene Xylene 100414 0.007 lb ENylbemenelUSC FSite Specific Sampling 728.278 36.414 1330207 0.009 lb XyleneaiMSCF Site Specific Sampling 1,001.410 50.070 n -Hexane 110543 0.252 lb n-HexenertdSCF Site Specific Sampling 27,313.150 1,365.657 2,2,4- Trimethylpentane Other: 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. ( 7'r1 sji Form APCD-211 - Gas Venting APEN - Revision 7/2018 5I Silverback 36-A Sales Gas Venting APEN Permit Number: 18WE0271 AIRS ID Number: 123 / 9E67 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 8/13/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Kelli Cox Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance ✓❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.cotorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 Silverback 36-A LP Gas Venting APEN 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 18WE0272 AIRS ID Number: 123 / 9E67 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Silverback 36-A Production Facility Site Location: NENW SEC 36 T12N R62W Mailing Address: 370 17th St. Suite 5300 (Include Zip Code) Site Location Weld County: NAICS or SIC Code: 211111 Denver, CO 80202 Contact Person: Kelli Cox Phone Number: 720-354-4597 E -Mail Address2: kcox@extractionog.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I Silverback 36-A LP Gas Venting APEN Permit Number: 18WE0272 AIRS ID Number: 123 /9E67/008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ✓❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft Notes: Permit modification to previous submittal, new permit limit requested. 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: Combustion of LP separator gas. Company equipment Identification No. (optional): For existing sources, operation began on: 12/11/2017 For new, modified, or reconstructed sources, the projected start-up date is: Ej Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? El days/week weeks/year Yes Yes Yes ❑✓ No ✓❑ No ❑ No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 Silverback 36-A LP Gas Venting APEN Permit Number: 18WE0272 AIRS ID Number: 123 / 9E67 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 -.Process Equipment Information Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting 6. b Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ✓❑ Yes ❑ No Vent Gas Heating Value: 2018.229 BTU/SCF Requested: MMSCF/year Actual: 0- MMSCF/year -OR- Requested: N/A bbl/year Actual: NA bbl/year Molecular Weight: 36.4543 ib/Ibmoi VOC (Weight %) 67.420 Benzene (Weight %) 0.228 Toluene (Weight %) 0.226 Ethylbenzene (Weight %) 0.035 Xylene (Weight %) 0.060 n -Hexane (Weight %) 1.751 2,2,4-Trimethylpentane (Weight %) 0.001 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 1 Silverback 36-A LP Gas Venting APEN • Permit Number: 18WE0272 AIRS ID Number: 123 / 9E67 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Indicate the direction of the stack outlet: (check one) N/A Geographical Coordinates' (Catitude/Longitude or',UTMJ 40.972567,-104.272202 Unknown Unknown I Unknown Unknown O Upward ❑ Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) 0 Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap Unknown Section 6 - Control Device Information O Check this box if noemission control equipment or practices are used to reduce emissions, and skip to the next section. O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: ECD MMBtu/hr Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 41 Permit Number: 18WE0272 Silverback 36-A LP Gas Venting APEN AIRS ID Number: 123 I 9E67 / 008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM verall Reque ontrol Efficiency reduction`.in emissions) SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected .r.teria. Pollutant Emissions ,Inventor PM ource etc. ncontrolle� Emissions (tons/year) nested Annual Permit mission Limit(s) 0.165 0.343 0.343 SOX NO), 0.068 IbNOx/MMBtu AP -42 Chapter 13.5 0.165 CO 0.31 IbCO/MMBtu AP -42 Chapter 13.5 0.751 0.751 1.564 1.564 VOC -65, • . IbVOC/MSCF SiteSpecific Sampling 78.336 3.917 X3.200 8.1CO. 4.5`14 1O.5 526.464 26.323 Benzene on -Criteria Reportable PollutantEmiissions Inventor stra Semce (C um 71432 0.219 fission lb Benzene/MSCF Site Specific Sampling al Annual Emissions.; Toluene 108883 0.217 lb Tcluene/MSCF Site Specific Sampling 521.688 26.084 Ethylbenzene Xylene 100414 1330207 0.058 @ Xylenes/MSCF Site Specific Sampling 139.142 6.957 n -Hexane 110543 1.682 lb n-Sexene/MSCF Site Specific Sampling 4,037.040 201.852 2,2,4- Trimethylpentane Other: 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. CL -'71 Form APCD-211 - Gas Venting APEN - Revision 7/2018 5I Silverback 36-A LP Gas Venting APEN Permit Number: 18W E0272 AIRS ID Number: 123 /9E67/008 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 8/13/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Kelli Cox Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6I Hello