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Home My WebLink About20183974.tiff T CDPffE COLORADO II CO Department of Public Health Et EnVirortnternt Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 RECEIVED Greeley, CO 80632 DEC 0 7 2018 November 30, 2018 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On December 6, 2018, the Air Pollution Control Division will begin a 30-day public notice period for Extraction Oil a Gas, Inc. - Kiteley. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-153O 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 / -- T:;\ John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer s:( , . -1 tt CC:PLO P),NLWT), I�0tAIC Pl'v►ew ?wC NectiCkkia) 12/-I 2018-3974 A CDPHE Air Pollution Control Division CO Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Kiteley - Weld County Notice Period Begins: December 6, 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: Kiteley Well Production Facility NWSW SEC21 T3N R68W Weld County The proposed project or activity is as follows: Separator and Vapor Recovery Tower Controlled Venting 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 publk 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 17WE1163 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 wilt 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: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-153O cdphe.commentsapcd@state.co.us 1 I tP�vtnt wx, �.mE k 'fnrv�st Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Timothy Sharp Packages: 371037.:' Received Date: 11/1/2017 Review Start Date: 1/4/2013 Section 01-Facility Information - - Company Name: Extractionail end Gas Inc Quadrant Section Township Range County AIRS ID: 123 NWSW 21 3N 68 Plant AIRS ID: :ef70 Facility Name: Kiteley Production Facility Physical Address/Location: NWSW quadrant of Section 21,Township 3N,Range 68W County: Weld County. Type of Facility: !Exploration&Praduct€on Well Pad What industry segment?Oil&NaturalGas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? LI Carbon Monoxide(CO) El Particulate Matter(PM) l� i- r Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRS Point s Emissions Source Type Equipment Name Permit# Issuance# Action Control? Required? Remarks Permit Initiat 001 SeparatorVentieg Produced`Gas Venting Yes 17WE1163 1 Yee$ lSsusnce' Permit Initial 002 Separator Venting VRT Venting Yes. 17WE1167 1 Yes. ,,Issuance Section 03-Description of Project New wellpad facility Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Greater than 2.5tOns per year in Non Aiainment Area ' - Section 05-Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? INo If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) r� l Title V Operating Permits(OP) J © ❑ Non-Attainment New Source Review(NANSR) - d Is this stationary source a major source? No If yes,explain what programs and which pollutants here SO2 NOx CO J-CO VOC(�'t�PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) - E] El O El Separator Venting Emissions Inventory 001 Separator Venting 7 7 (Facility Allis ID: ,.,,,. 123 „ .i� !I ,,,«,?3.11 'Ii II≥.� UA,. ba.�,» .. County Plant Point Section 02-Equipment Description Details - - - • - - "11141111,1E mte.ftssstl)e paiataruen `s- :t 1 ' ' "�"' , ,y`�I`, ...,O Detailed Emissions Unit Description: `'I,3. � ,`° .u�ei 111111111111,11111•1111,11•111� Si:��-��s ,1R '1'30003'.1 , Emission Control Device Description: �ffiEiV /�$ 33s wpfY 1 '1111,.':'v 3l 7 iY'aillg.- }rtv,1113 - 2"vd1f7 )11�, s - - ,,,,...M 31 4... ..ie iH11 033 313 ,1, ,,,i"i ..o`t»m F''Y.?,..11�13�11'3 „1.,3 • Requested`Overall VOC&-HAP Control Efficiency%: 3,: 4 ,x Limited Process Parameter _ - - - - Gas meter ,37, I...natertafirga Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator. °l9 7 - - ActualThroughput= tY: 3.212 MMscf per year ' Requested Permit Omit Throughput=vegitqfm4itzaiMMscf per year Requested Monthly Throughput= - 4 MMscf-per month • Potential to Emit(PTE)Throughput= 42 MMscf per year Process Control(Recycling) - Equipped with a VRU: e` is VRU process equipment: Secondary Emissions-Combustion Device(s)-for Air Pollution Control Separator Gas Heating Value: ?244i Btu/scf - .,",,,,,,,,,,,,,,j,,,,",,,,,,, - - Volume of waste gas emitted per BBL of Fgl W liquids throughput: f iy scf/bbl Section 04-Emissions Factors&Methodologies Descnption 7 i,s�s ff r 3 al-'113 pp : . 3 s 3 d>z 3 'I `.�'� Iii - k "illirofmr 7311133 '�,..J Fp,,"fuvL4 ..r a3- i3I'"m- 33�J�3 m A3. €,,.✓. .-s ed i. r 3W ,9 at,«..�1(iii,': MW I7iha<73l1111 -; �2225.ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C - - . 3� Weight% V Helium • ,.a 0:00 CO2 ;131rI11 j31 3 3.23'. N2 - J1 Off41i 2,s.. 0.65. '- methane 77ys ..._= 53.49 . ethane - - 0103030M4T44 - propane. i 3 ;13'0('. isobutane ,I;:.x.2;(le- - , - n-butane a2 „_ ,,,.;;r 2$,5'64'. • , ' isopentane MilliNMONm5'. n-pentane y 4 1i63'. • cyclopentan'e NEM i 195. n-Hexane' ,...111iM...d:36'. • _ - . cyclohexane 113�-3_ ,,36.Q4 . ' 3 Other hexanes .,%..'; ';0:00 ' heptanes �'1- *0,54'2 .. , methylcyclohexane plizi-prp8 • 224-TMP. Of 'if1P",,,;;,.,,,0{01. Benzene- I3i33':,..n<.`©^(k' V ' - V Toluene �:`�`0.07 „ Ethylbenzene ""0;03 Xylenes 3,a,,i3 ,:0104f CO*Heavies Total 100.00 • VOC Wt% 25.22 ECIEll Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) MIMMIES 14808.6999 740.4350 ( . 0:8859 IMIIMMIMIE 42.0417 i r .r ...;e3 2nfrbiliiiiiiegifaingbp 5.2009 1.2600 6.0256. Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source(Waste Heat Combusted) (Gas Throughput) •1„1,« », 0.000 .y'.. ti"'i :zottqfflolmering 0.000 INIMINIMMEMIMIEll „EMI I33( R 0.000 • - 0:0660 r 85.404 "°a3a.„�. ,/' MFG Email • .,...t,,,..0.05((0 3l'T. ii - g:;. MFG Email 3 of 10 - K:\PA\2017\17WE1163.CP1.xlsm Separator Venting Emissions Inventory Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 1.81 1.20 1.20 1.81- 1.81- 307 ' VOC 313.20 208.80 10.44 313.20 15.66 2660 CO 1.37 D.91 0.91 1.37 1.37 232 Potential to Emit Actual Emissions Requested Permit Limits HazardousAirPollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled - (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) . Benzene .-749 500 25 749 37 Toluene , 1778 1186 .59 1778 89 Ethylbenzene -640 426 21 640 32 Xylene 1066 711 36 1066 53 n-Hexane _ 9028 6019 301 9028 451 • 224 TMP 255 170 8 255 13 Section 06-Re,ulatmry Summary Analysis Regulation 3,Parts A,B - Source requires a permit 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 not subject to Regulation 7,Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance . Does the company use site specific emission factors based on a gas sample to estimate emissions? Thn 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. WIN 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? 11-44',04, 1''''j . 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 answer fAW'rg'z` i ii iaii i .,i /'r> ice.. ice:-.., _ " ill . .� �,1 " ,r : 7 r, v9 4 of 10 K:\PA\2017\17WE1163.CP1.xlsm Separator Venting Emissions Inventory • Section 08-Technical Analysis Notes '. Section 09-Inventory SCC Coding and Emissions Factors. - - - - Uncontrolled - - Emissions AIRS Point Process SCC Code Pollutant - factor Control% Units 001 01 3-10-001-80 Flares - PM10 0.00 0 lb/MMSCF PM2.5 0.00 0 Ib/MMSCF SOx 0.00 0 Ib/MMSCF NOx. 85.40 0 lb/MMSCF ' VOC 14808.70 95 lb/MMSCF CO.. 64.70 0 lb/MMSCF Benzene 17.72 95 Ib/MMSCF Toluene 42.04 95 Ib/MMSCF Ethylbenzene 15.12 95 lb/MMSCF Xylene 25.20 95 Ib/MMSCF n-Hexane 213.42. 95 Ib/MMSCF. 224 TMP- 6.03 95 lb/MMSCF 5 of 10 - K:\PA\2017\17WE1163.CP1.xism • • • • • Separator Venting Regulatory Analysis Worksheet - • • Colorado Rey u lation 3 Parts A and B-APEN and Permit Requirements 'Source is in the Non-Attainment Area ATTAINMENT 1. Are Uncontrolled actual emissions from any criteria poll utentfrom this individual source greater than 2 TRY(nnguletlorr 3,Pant A,Section ll.D.1.a)7 • 2. Am total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 1O TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.2.3)7ni (Not enough Information NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutant from this individual source greater than 1 TPY(Regulation 3,Part A,Section II,0,l.aI? FYhe 'Source^ Peg .. ' 2. Are total facility uncontrolled VOC emissions from the greaterthan 2 TPY,NOx greater than 5TPY or CO emissions greaterthan 1O TPY(Regulation 3,Part B,Section 11.1.2)? :.. Source Reg (Source requires permit • - Colorado Regulation?.Section XVII • ' 1. Was the well newly constructed,hydraulically fractured,or re<ampleted an or after Augustl,20147 (( •,-{Source is st .'Source is subject.Regulation 7,Secdon XVII.B.2,G v Section XVtI.B.2—GeneralProvislons for Air Pollution Control Equipment and Prevention of Emissions • • Section XVII.G.-Emissions Control Alternative Emissions Control(Optional Sectlant ' 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 'The control device for this separator is hot 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 AirACt,its ifnplemenbng regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control.The use of non-mandatory language such an tovemmnod/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. Separator Venting Emissions Inventory 002 Separator Venting Facility AIRS ID: County Plant Point • Section 02-Equipment Description Details 611:rlCSKe7r/�I i�Ss v. v alr,ErN �14 2 � v slap.% !1 .. Detailed Emissions Unit Description: SIC :1 may a',.,u,3 ride .oas.,2..`'"�,`rr,.,.. I,y z'fnfaP,«1y.1, ,13uh"*�„ „, I ,n, l„i31 (R1,r a :y.:`�'°l ra . ELTtE a r lal a, sr @�a7,'7v £s ;�3 Emission Control Device Descri tion: 1 4 :A . 'i : Ms M,L � I DLO( 1 'y�r31 r s r3 P :,,I,,.,,_ 'i..., a;, au;. ....:.: � . 1 3 ,,% ..:�s,s,� , ,,, :1 Requested Overall VOC&HAP Control Efficiency 5: 3 _.,1'�,.'. ,..___,,.. Limited Process Parameter Gas meter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= ,._,:,,y 301,'7!3 3 MMscf per year Requested Permit Limit Throughput= 3:;;r ,alhRj,MMscf per year Requested Monthly Throughput= • 1. MMscf per month Potential to Emit(PTE)Throughput= 11 MMscf per year Process Control(Recycling) Equipped Equipped with a VRU fy . ,..,"1; Go Is VRU process equipment: _ i.saj Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: i rl 3540::Btu/scf Volume of waste gas emitted per BBL of z,. liquids throughput: 'l scf/bbl Section 04-Emissions Factors&Methodologies Description 'r' r ' �r --"'*foci=.13r3 1,;3'e;ll:r T:,'4g:�::d - u _.: 3 d:7: ,n ly ,':,Hlir «3u" 1,3�'c u rr .. ,+" I,.z,. _. r w Io r S,arz"' v .... _ d... A a3`�,.,,' .115?:..;a - R3i�`i:..r3�a" -:-L�''` `.` ,: y, g'rA'� 4a lit�i .0 P `' .s.._ _ - ee�me.... I i Tom^: ___� :3,:::Ii:333,L'pfpz-T.= ,?"� o. ......I i�s'ia,..�;,�'�.r� �� 3 9 Iy ,3,: ° 33311 -:"» xa3 y�z��c a�.a-;,,,� 'f `�-�" ,, aa-ar;r;l°y"'a: ns a • • A r � � '� - - -�.�. 1 a I]� 1>3. a y ''a13 lmoi 1 g .ur k'9 1;.;°: uIS m- _ a llg`r s r f ,..:,= fi ° : 'h r s .E:. "° 3' �,,... i --axe:' .L ar - r 4101011A9 t .sy�'v a r bas ;uua ,., , I.�,.... '3;sr„?::..r 3,rilr ._._ Iy'w a..�,<511f'�11 ., i`:a13 �:�,.�_ s �� `e`a3 ...;., ,� a11a.(3xf._.:m Nez , ,, MW �]"a-a---' ,a' 49.5�I6/Ib-mol Displacement Equation Ex=E5 MW*Mr/C Weight% Helium C02 IVYr 1 sal 02f,s methane ethane rRl. 11 9 3J' propane �r r4,Yi. 29.19' lsobutane ,t, ..»24,...._i:.._7,25 n-butaner isopentane a- :a'.( ,`/"'7 n-pentane 928; cyclopentane r' tO n-Hexane °n,,,___.„.„e,;'<IL_<?�;�1i cyclohexane lf;:,,„:.,::„,.,;p,,;tY27 Other hexanes 000 heptanes methylcyclohexane Rala3.,r,r 'Or20. 224-TMP Benzene ;ill$BRIO:OrggAiiioli Toluene Ethylbenzene goton a -(I ! Xylenes C84-Heavies edgogniimaa Total 100.00 VOC Wt% 87.50 ECOMME Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) MMIMEMI 114350.6049 „„.GORWEIgnignIaln MIMMEIZEIMMEMMINI 7.3949 MESIMEIMME 108.9470 2354.7790 MNIMME ® 1.6568' Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMetu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) 0.000 MEMMMINE : 0.000KOMBENEEST _M NAVESEMENN 0,000 O.0BM 61-01 167.64010,018109., r1 MFG Email ..7.0100 127.000 ,,,,,,,,4,2101.Minaggeffloyj MFG Email 7 of 10 K:\PA\2017\17WE1163.CP1.xlsm • Separator Venting Emissions Inventory Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled • _ (tans/year) - (tons/year) (tons/year} . (tons/year) (tons/year) (lbs/month) PIvl10 0.00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0:00 0 Sox 0.00 0.00 0.00 0.00 0.00 0 • NOx 0.91 0.60 0.60 0.91 0.91 154 VOC 617.49 411.66 20.58 617.49 30.87 5244 CO 0.69 0.46 0.46 0.69 0.69 116 Potential to EmitActual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (Ibs/year) (Ihs/year) (lbs/year) Benzene 1597 1065 53 1597 80 Toluene 1464 976 49 1464 73 Ethylbenzene 375 250 12 375 19 Xylene 1155 770 39 1155 58 - n-Hexane 25432 16954 848 25432 1272 224 TMP 358 239 12 358 18 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVII.B,G Source is subject to Regulation 7,Section XVti.B.2,G Regulation 7,Section XVII.B.2.e The control device for this separator Is not subject to 3tegulation 7,Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements , Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID,and should have been collected within one year of the application received date.However,if 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 usethe"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. Does the company request a control device efficiency greaterthan 95%for a flare or combustion device? .._, "p 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 answer a d4 �{. ¢...x.. ,-f 4a f3 C £/f �1 Fr z { r!syg a 3r r1„ I / r fi r� 8 of 10 K:\PA\2017\17WE1163.CP1.xlsm • Separator Venting Emissions Inventory :. S ction 08 Tectmical An.hts.s Notes e. ,•. t r • Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units . 002 01 3-10-001-60 Flares PM10 0.00 0 Ib/MMSCF PM2.5 0.00 0 Ib/MMSCF 508 0.00 0 Ib/MMSCF 000 167.64 0 Ib/MMSCF VOC 114350.60 95 Ib/MMSCF: Co 127.00 0- Ib/MMSCF Benzene 147.90 95 Ib/MM5CF Toluene 135.58 95 Ib/MMSCF Ethylbenzene 34.72 95 Ib/MMSCF Xylene. 106.95 95 lb/MMSCF n-Hexane 2354.78 95 Ib/MMSCF' 224 TMP 33.14 95 Ib/MMSCF • • • • • • • 9 of 10 K:\PA\2017\17WE1163.CP1.xlsm. Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B-APEN and Permit Requirements 5ource is m tire Nen+Attainment Area ATTAINMENT 1. Are uncontrolled actual emissionsfmm any criteria pollutantsfrom this Individualsource greater than 2 TPY(R g t n3,Part A,Section 11.0.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10TPY or CO emissions greater than 10 TPY 3,Part B,Section II.0.3)? 'Not enough Infirmotion NON-ATTAINMENT 1. Are uncontrolled emissions from anycntetia pollutants from this individual source greater than 1 TPY(Regulation 3,Part A Section ll.O.1.a)? i5 Req 2. Are total facility uncontrolledVOC emissions from the greater than 2 TPY,NOx greater than 5TPY:or CO emissons greater than 10 TPY(Regulation 3,Part B,Section 11.0.21? ll li .Source Req 'Source requires permit Colorado Regulation 7,Section XVII 1. Was the well newly constructed,hydraulically fractured,or reccmpleted on or after August 1,2014? - Valel2lSource.is sr 'Source Is subject to Regulation 7,SectioeXVll.B.2,G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions. Section XVII.G-Emissions Control Alternative Emissions Control(Optional Sectlont Is this separator controlled by a back-up or alternate combustiond (i.e.,not the primary control device)that Is not enclosed? The control 'The trot device for thisseperetor is not subject to Regulation 7,Section XVII.B.2.e Section XVI1.B.2.e—Alternative emissions control equipment, - Disclaimer This document assists operators with determining applicability of certain requirements of the Clean kir 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 sftuation 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 descnbe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does net establish legally binding requirements in and of rbself. CDPHE COLORADO CO -tv- Air Pollution Control Division Department of Public Health€t Environment CONSTRUCTION PERMIT Permit number: 17WE1163 Issuance: 1 Date issued: DRAFT Issued to: Extraction Oil &t Gas, Inc. Facility Name: Kiteley Production Facility Plant AIRS ID: 123/9F70 Physical Location: NWSW SEC 21 T3N R68W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID 001 Low Pressure Separator 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, 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/cdphe/air/manage-permit. 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- coo COLORADO CO Air Pollution Control Division tvpartmprr.,5t rutt;r,n r rroAtor; Page 1 of 9 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.Rov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with-the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type 001 --- 1.9 15.7 1.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelvemonths' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) 4, cn�s�E LCOLORADS CoAir Pollution Control Division e E'vezrans of Fame :. �,�:x i�; e - Page 2 of 9 Facility AIRS Pollutants Equipment Point Control Device Controlled ID 001 Emissions from the Separator are routed VOC and HAP to an Enclosed Flare PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point 001 Natural Gas Venting 42.3 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions/as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. 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: co COLORADO co Air Pollution Control Division L r3,xaa Rctr F ar i Page 3 of 9 • 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. 14. 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 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0&tM) 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&tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or *1/4 DA COLORADO COthitiort ca tm1 Duds= ' � yrB u ;n sn Page 4 of 9 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. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a cnE COLORADO ( Air Polh l=Control Ditrision EX.Wra e. _bEnan Page 5 of 9 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Ft Gas, Inc. eovw� .C O L O R A D O CO ' Air Pollution Control.Dayssaon LVOrtrren° 91,ztr N.,Ph F, umen Page 6 of 9 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.goy/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 AIRS Uncontrolled Controlled Equipment Point Pollutant CAS # Emissions Emissions ID (lb/yr) (lb/yr) Benzene 71432 749 37 Toluene 108883 1778 89 Ethylbenzene 100414 640 32 001 Xylenes 1330207 1066 53 n-Hexane 11O543 9028 451 2,2,4- 540841 Trimethylpentane 255 13 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:. Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) NOx 0.0660 Manufacturer CO .Aix Pollution Control Division OPpartment of Pi tc-,ftgaRt t 1.'aF175?Y5"•.k^h: Page 7 of 9 Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) CO 0.0500 Manufacturer VOC Source 14808.6999 740.4350 (Promax/HYSYS) 71432 Benzene Source 17.7178 0.8859 (Promax/HYSYS) 108883 Toluene Source 42.0417 2.1021 (Promax/HYSYS) 100414 Ethylbenzene Source 15.1206 0.7560 (Promax/HYSYS) 1330207 Xylene Source 25.2009 1.2600 (Promax/HYSYS) Source 110543 n-Hexane 213.4233 10.6712 (Promax/HYSYS) 540841 2,2,4- Source Trimethylpentane 6.0256 0.3013 (Promax/HYSYS) 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendix A - Appendix I Appendixes Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories cne e COLORADO CO Air Paiixztton Control C7 visor krax m mr e z Page 8 of 9 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 DA COLORADO Co Air FoliutionControl Dirnsion at G1. 4nx; e Page 9 of 9 cDPHE COLORADO COs Air Pollution Control Division Department of Fubttic Health&Environment CONSTRUCTION PERMIT Permit number: 17WE 1 167 Issuance: 1 Date issued: DRAFT Issued to: Extraction Oil a Gas, Inc. Facility Name: Kitetey Production Facility Plant AIRS ID: 123/9F70 Physical Location: NWSW SEC 21 T3N R68W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID 002 Vapor Recovery Tower 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, ty 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/cdphe/air/manage-permit. 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- * cAPx COLORADO CO ` Mr Pollution Control Division • Di.pcleMVX1! Ftz,"Alr Fswtra; rtt Page 1 of 9 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/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section I II.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type 002 --- --- 30.9 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant 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.) #, coy" COLORADO Co Air Pollution Control Division l'a„.rarrerla at Kr+r maw t r s Page 2 of 9 Facility AIRS Pollutants Equipment Point Control Device Controlled ID 002 Emissions from the Vapor Recovery Tower VOC and HAP are routed to an Enclosed Flare PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point 002 Natural Gas Venting 10.8 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. 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: A COLORADO CO Air Pollution Control Division De,Witvry Raw +ue-: e+raormrv:: Page 3 of 9 • 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. 14. 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 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60; Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, 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 c�P E COLORADO Co Air Pollution Control Division DMInfrOre,A R..t, x Page 4 of 9 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. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a csa COLORADO CO Air Pollution Control DiViSiOrt t r €ItRota' R,'itmtoroer: Page 5 of 9 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. corer COLORADO Co Air Pollution Control Division E,L. rtr-er PALte iRil rrr'n Page 6 of 9 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/cd phe/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 AIRS Uncontrolled Controlled Equipment Point Pollutant CAS # Emissions Emissions ID (lb/yr) (lb/yr) Benzene 71432 1597 80 Toluene 108883 1464 73 Ethylbenzene 100414 375 19 • 002 Xylenes 1330207 1155 58 n-Hexane 110543 25432 1272 2,2,4- 540841 Trimethylpentane 358 18 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) NOx 0.0660 Manufacturer ,COLORADO �4 Air Pottution Control Division to uu s Pucur Hut b r rcmrne Page 7 of 9 Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF)- CO 0.0500 Manufacturer VOC Source 114350.6049 5717.5302 (Promax/HYSYS) Source 71432 Benzene 147.8987 7.3949 (Promax/HYSYS) Source 108883 Toluene 135.5815 6.7791 (Promax/HYSYS) Source 100414 Ethylbenzene 34.7158 1.7358 (Promax/HYSYS) Source 1330207 Xylene 106.9470 5.3474 (Promax/HYSYS) Source 110543 n-Hexane 2354.7790 117.7390 (Promax/HYSYS) 540841 2,2,4- Source Trimethylpentane 33.1353 1.6568 (Promax/HYSYS) 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendix A - Appendix I Appendixes Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories cprar ,COLORADO co Air Pollution Control Winston anw r .rr P:.mc w a mr s Page 8 of 9 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 a COLORADO Co Air Fc'lluti°3m Control Dwision Pt,wtmorr 74fragn � z Page 9 of 9 Kiteley Produced Gas Venting APEN I 101 ACDPHE P H E Natural Gas Venting APEN - Form APCD-211 pQ. u Air Pollutant Emission Notice (APEN) and CO � Application for Construction Permit All sections of this APEN and application must be completed for both new and",exis f i sing AP N updates. An application with missing information may be determined incomplOte an b r -. or result in • longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.Qov/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: tI,w 6.L0 AIRS ID Number: G 3 I F�0/ co [Leave blank unless APCD has already assigned a permit rr and AIRS ID] Company equipment Identification: Produced Gas Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Kiteley Production Facility Site Location Site Location: NWSW 21 T3N R68W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E-Mail Address2: ksteerman@extractionog.com 'Please use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by APCD via e-mail to the address provided. iCOLORADO Form APCD-2O5- Natural Gas Venting APEN - Rev 03/2017 �7 7+10 3 5 1 I �� r""1"'"'"'"' Kiteley Produced Gas Venting APEN Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] 11 Section 2- Requested Action ❑ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Please note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info£t Notes: Please issue individual permit for Produced Gas Venting. 3 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of Produced Gas to ECD when compression is unavailable. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 8 / 3 / 2017 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment ❑✓ Yes ❑ No area Is this equipment located at a stationary source that is ❑ Yes O No • considered a Major Source of(HAP) Emissions COLORADO Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 2 I ®'°" Kiteley Produced Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unles3 APCD has already assigned a permit#and AIRS ID] Section 4 - Process Equipment Information ❑� Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: Gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes ❑ No Maximum Vent 4576 SCF/hr Vent Gas 1294.1 BTU/SCF Natural Gas Venting Rate: Heating Value: Process Parameters4: Requested: 42.30 MMSCF/year Actual: 28.20 MMSCF/year -OR- Liquid Throughput Requested: N/A Bbl/yr Actual: N/A Bbl/yr Process Parameters4: 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth Molecular Weight: 22.25 lb/lbmol VOC(mole%) 10.751 VOC (Weight%) 25.225 Benzene(mole%) 0.009 Benzene (Weight%) 0.030 Toluene(mole%) 0.017 Toluene (Weight%) 0.072 Process Properties: Ethylbenzene (mole%) 0.005 Ethylbenzene(Weight%) 0.026 Xylene (mole%) 0.009 Xylene (Weight%) 0.043 n-Hexane (mole%) 0.094 n-Hexane (Weight%) 0.364 2,2,4-Trimethy4pentane 2,2,4-Trimethylpentane (mole%) 0.002 (Weight%) 0.010 Additional Required Information: • ❑Q 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) COLORADO Form APCD-2O5-Natural Gas Venting APEN- Rev 03/2017 3 I Al Kiteley Produced Gas Venting APEN Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information � ,x; TGeographical Coordinates (Latitude/Longitude or UTM) 40.208171, -105.015469 , S ��tack Qperator � , - , , Temp � Flow Rate � Ve[oc�ty cr : r '.�'°r.�`�S€'"ck ID ii0 t.rAtiO/e Ground ID No � feet , , N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) r❑ Circular Interior stack diameter (inches): Unknown ❑ Other (describe): Section 6 - Control Device Information Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency VRU Downtime or Bypassed % Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Questor Q3000 ❑ Combustion Requested Control Efficiency: 95% % Device: Manufacturer Guaranteed Control Efficiency 98% % Minimum Temperature: Waste Gas Heat Content Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating MMBtu/hr Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested � ,COLORADO Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 4 I 17,:' Kiteley Produced Gas Venting APEN Permit Number: AIRS ID Number: / / 4) [Leave blank unless APCD has already assigned a permit#and AIRS ID] It Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. . Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (%reduction): Overall Requested Control l. .. Pollutant • Control Equipment Description 'Efficiency M1:. (%reduction in emissions) PM SOX NOx VOC ECD 95% CO • HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission ,..: =r.. :.:::. ::'.•:: , `:: :Regiiested'Antival Oer diir Uncontrolled Emission Factor Actual Annual•Eriiissions • ,..:Em.sstontimi.'1•: :; Pollutant Emission Factor 'r.....:,.:"- • :; Source � � •�`� ` Factor Units (AP-42, Uncontrolled Controlled6 Uncontrolled .Controlled Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) PM SOX NO,, 0.066 lb/MMBtu Mfg. 1.20 1.20 1.81 1.81 VOC 14.795 Ib/lv1SCF Promax 208.61 10.43 312.92 15.65 CO 0.050 Ib/MMBtu Mfg. 0.91 0.91 1.37 1.37 Benzene 0.018 Ib/MSCF Promax 0.25 0.01 0.37 0.02 Toluene 0.042 Ib/MSCF Promax 0.59 0.03 0.89 0.04 Ethylbenzene 0.015 Ib/IV1SCF Promax 0.21 0.01 0.32 0.02 Xylenes 0.025 lb/MSCF Promax 0.35 0.02 0.53 0.03 n-Hexane 0.213 Ib/MSCF Promax 3.00 0.15 4.51 0.23 2,2,4- 0.006. Ib/MSCF Promax 0.09 0.004 0.13 0.01 Trimethylpentane ylp Other: 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6Arnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. COLOA Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 5 I � °`" `R""DO"` , M IP Kiteley Produced Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. h/a. y �e�z"" ��'z—. 10/31/2017 Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with$152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 https://www.colorado.gov/cdphe/apcd Make check payable to: Colorado Department of Public Health and Environment Telephone: (303)692-3150 Ay COLORADO Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 6 I " 7°HUHL6 Fnruan • Kiteley VRT Venting APEN 101 CDPHE Natural Gas Venting APEN - Form APCD-211 L) st16000 Air Pollutant Emission Notice (APEN) and CO Application for Construction Permit All sections of this APEN and application must be completed for both new and existing faciliti: l P updates. An application with missing information may be determined incomplete and may be . 'u longer application processing times. You maybe charged an additional APEN fee if the APEN incorrectly or is missing information and requires re-submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: J t j3 \\ AIRS ID Number:12 t f.4O/ U 0� [Leave blank unless APCD has already assigned a permit#and AIRS ID] Company equipment Identification: VRT Gas Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Extraction Oil 8, Gas, Inc. • Site Name: Kiteley Production Facility Site Location Site Location: NWSW 21 T3N R68W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th St. Suite 5300 Denver, CO 80202 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 E-Mail Address': ksteerman@extractionog.com 'Please use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 'Permits,exemption letters,and any processing invoices wilt be issued by APCD via e-mail to the address provided. 311034 p COLORADO Form APCD-205- Natural Gas Venting APEN - Rev 03/2017 1 I AV =7==, '.6 Kiteley VRT Venting APEN Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2- Requested Action r❑ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Please note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Please issue individual permit for VRT Gas Venting. 3 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Venting of VRT Gas to ECD when compression is unavailable. For existing sources,operation began on: • For new or reconstructed sources, the projected start-up date is: 8 / 3 / 2017 ✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment El Yes ❑ No area Is this equipment located at a stationary source that is ❑ Yes ❑✓ No considered a Major Source of(HAP) Emissions COLORADO Form APCD-205-Natural Gas Venting APEN- Rev O3/2O17 2 AM Kiteley VRT Gas Venting APEN Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Process Equipment Information 0 Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: Gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Slowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes ❑ No Maximum Vent 3688 SCF/hr Vent Gas 2756.8 BTU/SCF Natural Gas Venting Rate: Heating Value: Process Parameters4: Requested: 7.200 mMSCF/year Actual: 10.800 MMSCF/year -OR- Liquid Throughput 4 Requested: N/A Bbl/yr Actual: N/A Bbl/yr Process Parameters4: 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth Molecular Weight: 49.53 VOC (mole%) 77.343 VOC (Weight%) 87.500 Benzene (mole%) 0.072 Benzene (Weight%) 0.1 13 Toluene (role%) 0.056 Toluene(Weight%) 0.104 Process Properties: Ethylbenzene (role%) 0.012 Ethylbenzene(Weight%) 0.027 Xylene (mole%) 0.038 Xylene(Weight%) 0.082 n-Hexane (mole%) 1.036 n-Hexane (Weight%) 1.802 2,2,4-Trimethylpentane 2,2,4-Trimethylpentane (role%) 0.011 (Weight%) 0.025 Additional Required Information: ❑✓ Attach a representative gas analysis(including BTEX ft n-Hexane, temperature, and pressure) CI pressure) a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and pressure) COLORADOOAD Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 3 I �� '."gip +.AI Kiteley VRT Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical:-Coordinates.. (Latitude/Longitude or UTM) 40.208171, -105.015469 ` Operator ischarge Height° Temp Flow Rate Velocity Above Ground Level Stac{S ID No 4" ( F) (.4CFMJ (ftlsec) : ��_ N/A Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): Unknown ❑ Other(describe): Section 6 - Control Device Information Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency VRU Downtime or Bypassed Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: ECD Make/Model: Questor Q3000 ✓❑ Combustion Requested Control Efficiency: 95% % Device: Manufacturer Guaranteed Control Efficiency 98% % Minimum Temperature: Waste Gas Heat Content Btu/scf Constant Pilot Light: 2 Yes ❑ No Pilot burner Rating MMBtu/hr Pollutants Controlled: El Other: Description: Control Efficiency Requested ° lli .COLORADO Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 4 Kiteley VRT Gas Venting APEN Permit Number: AIRS ID Number: 5 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is arty emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Control Equipment Description Efficiency = - �" %'reduction in emissions PM SOX NO), VOC ECD 95% CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) • Emission Requested Annual`P`ermit Uncontrolled Emission . Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Emission Factor , Source • `" "` Factor limits (p-4z, Uncontrolled Controlled6 Uncontrolled Controlled Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year), PM SOX NO), VOC 114.27 Ib/MSCF Promax 411.36 20.57 617.04 30.85 CO Benzene 0.148 Ib/MSCF Promax 0.53 0.03 0.80 0.04 Toluene 0.135 Ib/MSCF Promax 0.49 0.03 0.73 0.04 Ethylbenzene 0.035 Ib/M'CF Promax 0.13 0.01 0.19 0.01 Xylenes 0.107 lb/MSCF Promax 0.39 0.02 0.58 0.023 n-Hexane 2.353 Ib/MSCF Promax 8.47 0.42 12.71 0.64 2,2,4 Trimethylpentane 0.033 ib/MSCF Promax 0.12 0.01 0.18 0.01 Other: 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. AAnnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 5 AA, COLORADO co,e�`,:a fA .fi Kiteley VRT Gas Venting APEN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] ,A Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 1� �'h�'�'� 10/31/2017 Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 https://www.colorado.gov/cdphe/apcd Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 COLOR Form APCD-205-Natural Gas Venting APEN- Rev 03/2017 6 I �� ADO �, Hello