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Home My WebLink About20181804.tiffWebsite Title: Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Extraction Oil a Gas, Inc. Notice Period Begins: June 7, 2018 - Mickey-Varra Production Facility - Weld County 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: Facility: Extraction Oil a Gas, Inc. Mickey-Varra Production Facility Oil and gas production facility SWNE Sec 5, T6N, R67W Weld County RECEIVED JUN 0 7 2018 WELD COUNTY COMMISSIONERS The proposed project or activity is as follows: Extraction proposes to operate a production facility that processes wellhead fluids from twenty-four (24) wells associated with two (2) separate production trains. Emission sources include storage tanks and combustion of gas from low pressure separators and vapor recovery towers. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 Permits 17WE1064, 17WE1065, 17WE1066, 17WE1067, 17WE1068, 17WE1069 and 17WE1070 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 r -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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us pad.Rekied Cc; FL(MMIT)), Han), PWCERI IJti&IGK) 06-o8-18 2018-1804 COLORADO COLORADO Department of Public Health Er 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 June 4, 2018 Dear Sir or Madam: On June 7, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil >:t Gas, Inc. - Mickey-Varra 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 a 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 Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package If: Received Date: Review Start Date: Bradley Eades '367262 8j8/201z:::E ..,. 12/4/2017"'' Section 01- Facility Information Company Name: Extraction Oil&0as,ihd.;.:' • County AIRS ID: Plant AIRS ID: 4F64 Facility Name: Mickey-Varra Production Facility Physical Address/Locatic SWNE quadrant of Section 5, Township 6N, Range 67WW, in Weld County, Colorado Type of Facility: 'Ezpjoration t'iAroduc€ion Weft Pad What industry segment7Dif& Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? •Yes If yes, for what pollutant? Don Monoxide (CO) Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range 67W ,SWNE 5 F3J Pa 'culate Maker (PM) nne (NOx N voC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tdhk andensate Tank - Micke Yes 17WE1064 E1064 Yes Permit Initial" .....Issuance Mickey. wells Perin Initial:; 4' 'Issuance Permit Initial €ssuance Perrnih Initial Isstmnce 002 Condensate Tank :ondensate Tank-Varr 17WE1065 Yes Varra wells ,',Produced Water Tank Produced Water Tank Yes 17 W E1066 All wells 004 005 : 006 007 066 ..'Separator Vein r-Ventitjg' Vapor Recovery Tower (VRT) '-Vapor Recovery Tower (VRT) parator Venting - Mick eparator Venting- Varr VRT Venting - Mickey VRT Venting - Varra Yes Yes..-; Yes s, 17WE1067 17WE1068 17WE1069 17W E1070 Yes Yes Yes initial:5 °'::Permit Initial Issuance Permit Initial= ,.;a>�Issuance Mickey wells udrra wells': Mickey wells Varra wells .. Cancelled Section 03 - Description of Project Extraction proposes to operate a production facility that processes wellhead fluids from twenty-four(24) wells associated with two (2) separate production trains„ Mickey wells and Varra wells. Each production train has separate emissions points for condensate storage, and separator venting. it shou€d be noted that the applicant has indicated thatcondensate is transferred fromthe storage tanks dieectly.to a sales pipeline via a lease -automated custody trasfer FACT) unit. Therefore, there is not a loadout emission point at this facility. •,, Vii„ ,,,(- - .. The control equipment used to combust gas from the low-pressure separators and VRTs is a thermal oxidizer._ to order to avoid NANSR requirements, Extraction is accepting a limit of a minimum 99% control of VOC- Prior to permitting, applicant conducted EPA reference method performance testing at the faciltiy and on the . proposed equipment Testing demonstrates 99%s destruction efficiency and will be used for permitting purposes. Permit contain s semi-annua) performance testing requirements to demonstrate ongoing compliance with the 99% control efficiency on the Thermal Oxidizers. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? 444 -questing Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants hen SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC ❑ ❑✓ PM2.5 PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory Section 01 -Administrative Information (Facility AIRs ID: County 9 Plan 40I ..... Section 02 - Equipment Description Details Detailed Emissions Unit .MICKEY WELLS .Twelc Description: Emission Control Device 'Enelesed;L Description: ...... (Xz bbl Dqwd marido iid condensate; Section 03 - Protesting Rate Information for Emissions Estimates Prhnary Emissions - Storage Tank(s) Actual Condensate Throughput= Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughpu Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = I.BSI scf/bbl Actual heat content of waste a outed to combustion device = Requested heat content of waste gm routed to combustion device = 1.062,819 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 1 15,819 Barrels (bbl) per year .160,520 Barrels (bbl) per year 2512; Btu/sct Potential to Emit (PTE) heat content of waxgrA routed to combustion device= Actual heat content of Pilot gas routed to combustion device (see section 08(= Requested heat content of Pllo�routed to combustion device (see section 08). Potential to Emit (PTE) heat content of Pilot gas routed to combustion device Section 04 - Emissions Factors & Methodologies Ethylbenzene Xylene Hexane 224 224 TMP 1.7E-06 Emission Factors Pollutant Benzene Toluene Pollutant Pollutant PM10 PM2.5 Condensate Tank Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) Section 05 - Emissions Inventory (Conden. Through 0.0086 3.5E-04 1.1E-05 Control Device (Waste gas) Uncontrolled Uncontrolled )lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) 0.0075 0.0000 0.0075 4,880 MMBTU per year 0.614080673 5,379 MMBTU per year 5,379 MMBTU per year MMBTU per year MBTU per year MBTU per year Emission Factor Source 0.0000 Control Device (Pilot Fuel) Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat (Condensate combusted) Throughput) )Ib/bbl) Emission Factor Source ilrov Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 99.7 90.4 4.5 99.7 4.98 0.0 0.0 0.0 0.0 0.02 0.0 0.0 0.0 0.0 0.02 0.2 0.2 0.2 0.2 0.18 0.8 0.8 0.8 0.8 0.83 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 Xyiene n -Hexane 224 TMP 1161 1053 53 1161 58 481 436 22 481 24 40 37 2 40 2 159 145 7 159 8 8124 7370 368 8124 406 262 238 12 262 13 Section 06 - Regulatory Summary Analysts Regulation 3, Parts A, B Regulation 7, Section XII.C, D, E, F Regulation 7, Section XII.G, C Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, SOPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 Regulation 8, Part E, MACT Subpart HH (See regulatory applicability worksheet for dotal ed analysis) Source requires a permit Storage tank is subject to Regulation 7, Section XII.C-F Storage Tank Is not subject to Regulation 7, Section XII.0 Storage tank Is subject to Regulation 7, Section XV II, B, C.1 & C.3 Storage tank Is subject to Regulation 7, Section XV II.C.2 Storage Tank Is not subject to NSPS Kb Storage Tank is not subject to NIPS 0000 Storage Tank is not subject to MAR HH 2 0)40 K:\PA\2017\17W 61064. CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per par? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor lased on guidelines In PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site-speclfic and collected within Oct year of theapplication 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 based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and Initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes J„estimated secondarycombastio issionsbased on combustion of tarkoapors In the original alculat ons, the applicant had added an apporUgoment of the pact uel combustion em&sons ba ed on b{ributlonofwst000e heat notitontroutedtotfieflaoe.fromPoin101,004,and 006 However, aft discusson.wth applicant i':was determined the; Etrect on would track and rep ftlbt fbe) as anine4nific�nt source ratbefthan ail otmg across Cult pie po CCs. AIRS Paint it 001 ple from the LP separator se DC MA3-T,k Fbrad Ro6t7 rti lie"/u.k y wells (sampled 7/14/17)_ W g end breathing losses verealculate Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 b/1,000 gallons condensate throughput PM2.5 0.00 0 b/1,000 gallons condensate throughput NOx 0.01 0 b/1,000 gallons condensate throughput VOC 4.1 95 b/1,000 gallons condensate throughput CO 0.03 0 6/1,000 gallons condensate throughput Benzene 0.02 95 6/1,000 gallons condensate throughput Toluene 0.01 95 6/1,000 gallons condensate throughput Ethylbenzene 0.00 95 6/1,000 gallons condensate throughput Itylene 0.00 95 6/1,000 gallons condensate throughput n -Hexane 0.17 95 b/1,000 gallons condensate throughput 224 TMP 0,01 95 b/1,000 gallons condensate throughput 3 of40 K,\PA\2017\17 W E1064.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements [Source it in the NemAttainment 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 (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPS, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? 'You have indicated that manner is in the Nnn.Attoinment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section li.D.l.e)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 end1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)7 'Source requiresa permit Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located In the B -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? 'Storage tank is subject to Regulation 7, Section XB.C-F Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII.C.2 —Emission Estimation Procedures Section XII.D —Emissions Control Requirements Section XII.E—Monitoring Section XII.F — Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non stabilized liquids) emissions end have uncontrolled actual emotions greater than or equal to 2 tons per year VOCT 'Storage Tank is not subject to Regulation 7, Section XI8.G Section XII.G.2 - Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located ate transmission/storage facility? 2. Is this condensate 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 condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC? Stnrag:i, tank is subject cu Regulation 7, Soctinn XVII. B, C.1 R 1.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only stabilized' liquids? Storage tank is roh/i:ct to Regulation 7, Section XVh.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m5) ("472 BBLsI? 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 m5 ("10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111h? 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 60.11167 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 50.111k? 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)1?; or b. The design capacity is greater than or equal to 151 ms [`950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.11oh(h))?; or c. The design capacity is greater than or equal to 75 Ma ['472 BBL] but less than 151 not ["950 BBL] and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b))? Storage Tank is not subject to SOPS Kb Subpart A, General Provisions §60.1126- Emissions Control Standards for VOC §60.1136 - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations Yes Ye, Yes rao Yes' • No Yes ilrn4 NA /1E 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located ate facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 2. Was this condensate 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 condensate storage vessel meet the definition of "storage vesselr" per 60.5430? 5. Is the storage vessel subject to and controlled In accordance with requirements for stora a vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HD? ISturoge Tank is nut subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC 460.5413 -Testing and Procedures 460.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements 460.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365)a)]2) even if potential VOC emissions drop below 6 tons per year] 40 CFR Part 63, Subpart MAR HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)i; 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 users (63.760(a)(3))? 2. Is the tank located at a facility that Is major' for HAPs? 4. bees the tank meet the definition of "001`6O V6446Ii° Ili 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? I Storage Tank is not sulsjeck to fv7ACT fill Subpart A, General provisions per §63.764 (a) Table 2 , 463.766 - Emissions Control Standards 563.773 - Monitoring 463.774-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 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,"ls 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. You WE, No Yes Condensate Storage Tank(s) Emissions Inventory Section 05 - Emissions Inventory Section 01 - Administrative Information Facility AIRs ID: 123 9F64 002: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Fourteen (14) 400 bbl liquid manifold condensate storage tanks. Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency%: _..... 95 Enclosed Combustor PEE, 1.10 ECD-40) Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput = ' Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2833; Btu/scf Volume of waste gas emitted per BBL of liquid produced = _. 1,04 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Actual heat content of Pilot gas routed to combustion device (see section 08)= Requested heat content of Pilot gas routed to combustion device (see section OS) = Potential to Emit (PTE) heat content of Pilot gas routed to combustion device= Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? 4 Ent sum Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) VOC 0.1807 Benzene Toluene 4.40E-04 .000-0 Ethylbenzene 300E-0 %ylene L470-04 n -Hexane 7.30E-03 224 TMP Pollutant 44E-04 Emission Factor Source (Condensate Throughput) 0.0090 5.0E-05 2.2E-05 1.5E-06 7.3E-06 -6E-04 2E-05 Control Device (Waste gas) Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat (Condensate combusted) Throughput) PM10 00075 PM2.5 _0.0075 NO 9:0680 Pollutant 0.0000 0.0000 0.0003 Control Device (Pilot Fuel) Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) Actual Condensate Throughput While Emissions Controls Operating = 4,650 MMBTU per year 4,811 MMBTU per year 4,811 MMBTU per year MMBTU per year MBTU per year MMBTU per year Emission Factor Source Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 89.1 86.1 4.3 89.1 4.46 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 -0.2 0.2 0.2 0.16 0.7 0.7 0.7 0.7 0.75 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 0ylene n -Hexane 224 TMP 987 953 48 987 49 434 420 21 434 22 30 29 1 30 1 145 140 7 145 7 7202 6960 348 7202 360 241 233 12 241 12 6 of 40 K:\PA\2017\17WE1064.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 06 - Regulators Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XII.C, D, E, F Regulation 7, Section 011.0, C Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 Regulation 8, Part E, MACT Subpart HH (See regulatory applicability worksheet far detailed analysis) Source requires a permit Storage tank is subject to Regulation 7, Section XII.C-F Storage Tank is not subject to Regulation 7, Section 511.8 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Storage tank is subject to Regulation 7, Section XVII-C-2 Storage Tank is not subject to NSPS Kb Storage Tank is not subject to NSPS 0000 Storage Tank is not subject to MACT NH Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it 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 based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes tle had'estimated secondary combust on ernissfonabasedon combuston of tankvapors. in the original calculations, theaapl:cap) had added an a pportionruento of the plot fueGcombostia "on the relative contribution of 'waste gas beatcontent rouged to the flare rem Point 002 005 and 007)However, , , ,.-, d'. u_s o With ,ppl cam t seas de.e amid Plat Eltracttonw ions frorrCgombustion of pilot fuel as an in ignificant source rather h t allorosy multiple icating p points. ts. n'. ProMaxjrun December 2017) using a pressurized liquid sample from the LPsepafatorservc'rig the "/1 welts (�a .,I. -I 7/2)"/'17).,c. „ dbreath.t�„es..e =cal, „v...rod � ProMax r'ta'nk-loss stencil_ AIRS Point # Process # SCC Code 002 01 Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.01 0 lb/1,000 gallons condensate throughput VOC 4.3 95 lb/1,000 gallons condensate throughput CO 0.04 0 lb/1,000 gallons condensate throughput Benzene 0.02 95 lb/1,000 gallons condensate throughput Toluene 0.01 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.00 95 lb/1,000 gallons condensate throughput n -Hexane 0.17 95 lb/1,000 gallons condensate throughput 224 TMP 0.01 95 lb/1,000 gallons condensate throughput 7 of 40 K:\PA\2017\17WE1064.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Nonhettainmont Aron 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 construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See P5 Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 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 11.0.3)? IYou have indicated that source is in the Nnn.Atteinment Area 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 (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo SS -01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOL emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)7 Source requires a permit Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? 'Storage tank in subject to Regulation 7, Section 011.0-E Section XII.C.1 —General Requirements for Alr Pollution Control Equipment— Prevention of Leakage Section X11.C.2 —Emission Estimation Procedures Section XII.D — Emissions Control Requirements Section %II.E—Monitoring Section %II.F—Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located ate natural gas processing plant? 3. Does this etorege tank exhibit "Flash" (e.g. storing non-stabllieed liquids) emissions end have uncontrolled actual emissions greater than or equal to 2 tans per year VOCT 'Storage Tank is not subject to Regulation 7, Section 011.0 Section XII.G.2 - Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII.C.2 —Emission Estimation Procedures ' Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate 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 condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII, B, C.11 0.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements _ 5. Does the condensate storage tank contain only "stabilized" liquids? 'Storage tank Es subject no Regulation 7, Section KV€I-C,2 Section SVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (ma) (-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 m' ['-10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.1116? 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 60.11167 5. Does the storage vessel store a "volatile organic liquid (VOL)"' 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 (60.110h(d)(2))?; or b. The design capacity is greater than or equal to 151 mu (`950 BBL] and stores 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 M' r472 BBL] but less than 151 m' (-950 88L] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(6))? 'Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §65.113b - Testing and Procedures §60.115b- Reporting and Recordkeeping Requirements §60.1166 - Monitoring of Operations Yes Yes Yes Yes Yes No No Yez Yes _. 40 CFR Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 1R, 2015? 3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for stare a vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HH? IStotage Tank is not subject to 05P5 0000 Subpart A, General Provisions per §60.5425 Table 3 660.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures 660.5395(g)- Notification, Reporting and Recordkeeping Requirements 660.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to he 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 6 tons per year] 40 CFR, Part 63, Subpart MAR HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(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 users )63.760(a))3))? 2. Is the tank located at a facility that Is major° for HAPs? 3. Does the tank meet the definition of "storage vessel"' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? IStorage Tank is not subject to MACT 611 Subpart A, General provisions per §63.764 (a) Table 2 §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 lithe 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 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 Alr 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 Yes Yes Produced Water Storage Tank(s) Emissions Inventory Section 01.- Administrative Information Facility AIRS ID: ;;-123 County 9F64 003 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Two (2) sets of liquid manifold vessels containing two (2) 400 barrel vessels each Enclosedcombustor (IES, LLC ECD-48) Description: Requested Overall VOC & HAP Control Efficiency%: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput= ,943,462'. Barrels (bbl) per year 1,987,3691, Barrels (bbl) per year 1,987,369Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2337! Btu/scf Volume of waste gas emitted per BBL of liquids produced = 0,9122; scf/bbl Actual heat content of waste gas routed to combustion device Requested heat content of waste gas routed to combustion device = Actual Produced Water Throughput While Emissions Controls Operating= 4,249 MMBTU per year 4,345 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 4,345 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) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 0.0039 4.0E-05 2.9E-05 1.1E-06 Z.0E-05 9.9E-05 5.9E-06 Benzene Toluene 7.9E-04 5.7E-04 2.3E-05 _.. Ethylbenzene Xylene n -Hexane 224 TMP 20E-03 1.2E-04 Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/bbl) (waste heat combusted) (Produced Water Throughput) PM10 PM2.5 0.0075 0.0075 0.0000 0.0000 0.0001 0.0007 NOx CO 0.3100 Section 05- Emissions Inventory Emission Factor Source dt Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 78.3 76.6 3.8 78.31 3.92 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 • 0.0 0.1 0.1 0.1 0.1 0.15 0.7 0.7 0.7 0.7 0.67 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 1575 1540 77 1575 -79 1140 1114 56 1140 57 45 44 2 45 2 784 767 30 784 39 3939 3852 193 3939 197 235 230 11 235 12 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 & C3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 7 44364 10 of 40 K:\PA\2017\17WE1064.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 one 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 she specific emissions factor. See PS Memo 14 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 5.9 and 5.12 for additional guidance on testing. Section OB - Technical Analysis Notes `Emission calculations arelased on pressurized watersampletaken from theseparator dump line at 42 psig and 118F:.The sample was then used in a ProMax simutatiorsta:gakula{e working breathing and flashing losses fromtheiproduced wetectark. itwas communicated to Extraction that the approved methods for d evelbpment of esite-specific emission factor arapresented in PS Memo 14-03, section S.9. However, I see no inclicatrons₹hatthesempling end enalyois of pressurized. producedwaterare ieaccurate.Therefore,l will use my discretionto allow ₹his methodatthis facility provided that the assumptions used w the ProMaxsimolation are accurate. Since the liqud being modeled is produced water, it would not be a ccuratelymodeled if assumptionsof an ideal mndure are made. I reached eottolfR&E (Developer of ProMax saflware}pp this topic. and was informed that the tank loss stencil contains a checkbox called "Use AP42 Raoult's Law Vapor Pressure?".Snce you are modelipg produced water, where two liquid phases are present, this boo should he "unchecked". When unchecked, Protax w0tusethe defaultthermodynamics package instead of Raou(t'"s Law to calculate the mixtures vapor pressureand vapor composition. Thiswill preventan undemstitnation of the mfj}ture's propthi .Arepresentetive from BR&E indicated that the simulator should'. produce a reasonably accurate result provided mat tli''e-pressurieed-sampling was done correctly. '... .. `.-. ' Extraction, provided a revs d ProMax model usng PtuMax sthermodynamics package (eatheithan Raoul{'s Law) along with revised calculations. *since the sample vras pulled from the facility being permitted, there will notbeartinttialsampiingrequirement e heatconteet of the waste gas and G W R used in the analysis above are based on the ProMa%simulation. APEN submitted {qr this paint indicates that stoeogetank co taino less than 196crude, ojt una. annual average bass. However, source S requesting atreditionaI 0nstruction permi Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point S 003 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control' Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.00 0 lb/1,000 gallons liquid throughput VOC 1.9 95 lb/1,000 gallons liquid throughput CO 0.02 0 lb/1,000 gallons liquid throughput Benzene 0.02 95 lb/1,000 gallons liquid throughput Toluene 0.01 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.01 95 lb/1,000 gallons liquid throughput n -Hexane 0.05 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 11 of 40 K:\PA\2017\17 W E1064. CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.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 B, Section II.D.1.M) 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 11.0.3)? 'You have indicated that source is in the Non -Attainment Area 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 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 B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'Source requires a permit 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 station 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 per year VOC? No Yes 'Storage tank is subject to Regulation' 7, Section XVI€, 0, C.1 & C,3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control 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 nubiect to Regulation 7, Section KVII.C.2 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 at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) 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 produced water storage vessel meet the definition of "storage vessel"' per 60.5430? Yes '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) - Cnver and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to N5P5 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 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. Separator Venting Emissions Inventory Section 01- Administrative Information 'Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Venting of gnu Detailed Emissions Unit Description: paratareton thermal oxidizerduring co section sysxem Adwntim 'attestor modef,^ S000thermal oxidizer Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: 99 Limited Process Parameter*14a<Asif Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 2.93 MMscf per year Requested Permit Limit Throughput= 3112 MMsrf per year Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU Is VRU process equipment: 3.12 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) 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 HIP se a,wapd„r, 1371: Btu/scf scf/bbl receive fluid from thirteen (13) wells -(Mickey Wells), Gas Is separated from liquids in the high-pressure separator and routedto sales Gas i separated from Rquidsis, the low-pressure separatorand rooted', limit(VRtf)and subsequently to sales. When high-pressure gas cannot go in to the sales line, the stream is combusted=ln the thermaloxidizer. When low-pressureseparatorgas bypassesaheVVROU itix also,_''. e thermal oxidizer. Stream composition is based on an extended gas analysis taken from the low pressure separator at pslg (satopled:2/23/18 a - Displacement Equation Ex=Q"MW'Xo/C Weight % Helium CO2 N2 methane ethane (0908 i'.14.89 31-i2 -33:40 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 4.99' 4° 2-36 0:23 S_G 15 13 0 33 0. _...000 0.os 0';00 0.02 0.25', 99.9 Total VOC Wt % 61.1602 Ib/Ib-mol 13 of 40 K:\PA\2017\17W E1064.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 55822.1700 558.2217 Benzene Toluene 84.2100 46.3800 3.9200 14.8300 559.6093 0.8421 0.4638 0.0392 0.1483 5.5961 0.0030 Ethylbenzene Xylene n -Hexane 224 TMP 0.3000 Emission Factor Source Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) PM10 PM2.5 (Gas Throughput) 14.686 DOT 0006,x.`.'; 14.686 1.159 SOx NOx CO 130.086 98.550 0.0500` 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) PM10 PM2.5 SOx NOx VOC CO 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.00 0.00 0.00 0.00 0.00 0.20 0.19 0.19 0.20 0.20 87.08 81.64 0.82 87.08 0.87 0.15 0.14 0.14 0.15 0.15 Hazardous Air Pollutants potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/yearl Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 263 246 2 263 3 145 136 1 145 1 12 11 0 12 0 46 43 0 46 0 1746 1637 16 1746 17 1 1 0 1 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G I Source is subject to Regulation 7, Section XVII.6.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.0.2.e (See regulatory applicability worksheet for detailed analysis) 14 of 40 Ki\PA\2017\ 17WE1064.CP1.xlsm Separator Venting Emissions Inventory tit tit equat `report *Appficanth - assumingtliot,. pressure andfo 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 emissiors? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and shrald 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 appropriateno 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? w%rsa\aw If yes, the permit will contain: -An "Initial Testing Requirement" to collect a she -specific gas sample from the equiprneat 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 R 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? `Yea 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 answe Section 08 - Technical Analysis Notes ial front Questor (thermal oxidizer gtannfactufer) Where tiranpfactruer tepresentlne, provided .Questor seen axeasonabiysimilar toAP-42factorsand,TtV&Ct=factordforflares,eniitl-42does 'got zoyideam7sslasi licant used the weight %resuItsfront the exSeridedgas analystexxttlected 2/23/in 0outde inpu tithe, he software), As suchEtheweigltt%values input ohmic tretbase thatcorrespond to calcualted* gnificant and may be -attributed to rounding. • ... - ton.caiculet ions using an higtr pressure sales gas.(@ 357 psig). €iawever, aft LP gas (@ 41 psig) as representative for all gas muted to the Inevtirnal rntidii ,rdt'ory, *Sincethethertna€ oxidizer usedfor this point (lhli°c� sim(6rstreadueomposition;the initial, and periodidt compliance -test conducted per17WE1068 i n esfdlt!,.y. periodirtestmy regmremerat=toc this point only regirires; the testing snnitions Was isdussedwfth the APCRStai* Ye Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # 004 Process# SCC Code 01 3-t0-009-60 Flares 3 CW"000o flOx 8066, 1x(MM%TU and C ber dt cu itemattonwdfbereguired. PrnMax and used the software to calnalafe;lbjh atom trnM ax . It was determined t itin the ,HLP'separat to -oxidizer wll( inch rmal oxidizerttsedto control emissions fnom Pwttt QUft Werra LP SeparatorSL,a_nd since ibis located at the same fagpti minihtuxia 0#99%) indsdes referenceto the testing requirement ity1@WE1068, Point O05.Tbis is intended to indicate that rr greater, then compliamemaybe.asumedforthispomt [Point 00-9,27WETDb.7(.and.fonthistherma("zt,er mtfo_,The Limey and does nU includes°requiremetrtto:demonstrate comprcince with the emission Hnn`%fThe-"cross-referencing TriclFMedln� ding of the testitigregtiuements, as wtitttteptsass.asdescntbad'ab'c ie, ' Uncontrolled Emissions Pollutant Factor Control % Units PM10 14.69 0 Ib/MMSCF PM2.5 14.69 0 lb/MMSCF SOx 116 0 Ib/MMSCF NOx 130.09 0 Ib/MMSCF VOC 55822.17 99 Ib/MMSCF CO 98.55 0 Ib/MMSCF Benzene 84.21 99 Ib/MMSCF Toluene 46.38 99 Ib/MMSCF Ethylbenzene 3.92 99 Ib/MMSCF Xylene 14.83 99 Ib/MMSCF n -Hexane 59.61 99 Ib/MMSCF 224 TMP 0.30 99 Ib/MMSCF 15 of 40 K:\PA\2017\ 17WE1064.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRs ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 1.00 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell 831) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator Is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total ligrnd throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput may be limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream to be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissionsthat result from emissions controls that combust VOC and HAP emissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A30 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (Le. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled +flow rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A32 16 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory Comment: This section establishes the process rates that are the basis for, actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment: Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/2017) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Burner". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 Comment: This equation may be referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10- Displacement Equation (10.4-3). Where: Ex = emissions of pollutant x O= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas =SG of gas MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Cell: B42 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: -select the entire row that includes "C8+ Heavies" in the spreadsheet by right clicking on the row # next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row # next to column A -select "insert" from the drop down menu Cell: A65 Comment: This must be 100% Cell: B70 Comment: When cell indicates "(Ib/MMscf)": EF = Xxx MW x 10^6/C where: EF = emission factor (Ib/MMscf) MW = Molecular weight of gas = SG of gas' MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-moll at 60F and 1 atm When cell indicates "(lb/bbl)": EF = Xxx MW x GLR/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas MW of air Xx = mass fraction of x in gas GLR =volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D79 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: 982 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of Ib/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C82 Comment: This column automatically converts emission factors from Ib/MMBtu to Ib/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The Ib/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A89 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E92 Comment: Secondary emissions from control devices are listed in the uncontrolled and controled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A111 Comment: cdmoney: This section will be automatically populated based on the regulatory analysis worksheet. Cell: A140 Comment: cdmoney: 17 of 40 K:\PA\2017\17 W E1064.CP1.xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. 18 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 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 pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. 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)? You have indicated that source is in the Non -Attainment Area 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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is subject to Regulation 7, Section XVII.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 Section) a. Is this separator controlled bye 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. Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: County Plant Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU:' Is VRU process equipment: a. Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control e% 14+31: MMscf per year 1341 MMscf per year 154.7 MMscf per year Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description HEP separators reset vapor recovery;pin'-' cambusteds. mai oxidizer. Displacement Equation Ex=QaMWn Xx/C mpositro 2226- Btu/scf Ib/Ib-mol Weight % Helium CO2 N2 methane ethane 0.00 314 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane ) .1 ;;.;.1,41 cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene ) ............0.23: Toluene Ethylbenzene Xylenes C8+ Heavies 28.44 7', 0. 0`J d5 Total VOC Wt % 99.9 71.0657 scf/bbl iquids in in to the sala he high-pressure separator and routed to safes. Gas is One, the stream combusted in the thermal oxidizer analysis taken from the low-pressure; side. of the HIP separator. = 20 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (Ib/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 73072.8100 730.7281 Benzene Toluene 234.1100 155.6500 12.0300 46.1700 2.3411 1.5565 0.1203 0.4617 14.5121 0.0090 Ethylbenzene Xylene n -Hexane 224 TMP 1451.2100 0,9000 Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) Ih/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 SOx NOx CO 0.007' 0Aw75NgP 16.586 16.586 1.309 146.916 111,300 Section 05 - Emissions Inventory Emission Factor Source Emission Factor Source Criteria Pollutants - Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 SOx NOx VOC CO 1.28 1.03 1.03 1.28 1.28 1.28 1.03 1.03 1.28 1.28 0.10 0.08 0.08 0.10 0.10 11.36 9.13 9.13 11.36 11.36 5652.00 4541.84 45.42 5652.00 56.52 8.61 6.92 6.92 8.61 8.61 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 36216 29102 291 36216 362 24078 19349 193 24078 241 1861 1495 15 1861 19 7142 5739 57 7142 71 224495 180400 1804 224495 2245 139 112 1 139 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.8.2.e (See regulatory applicabilityworksheet for detailed analysis) Section 07 - 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 XVIl.B.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 mortified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit wil 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% fora 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 21 of 40 K:\PA\2017\17WE1o64.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes *Applicant provided emial from Questor (thermal oxidizer manufacturer) where manufactruer representive provided Questor's recommended -emission factors for the Q5006 as NOx = 0.066 Ib/MMBTU and Co 0.05 Ib/MMBFU. Since these emission factors are reasonablysimilar to AP.-42factors and TNRCC factors for flares, and AP -42 does not provide emission fectorsforThermal .Oxidizers, nofurtherdocumentation will be required. "It should be noted that the applicant used the weight % results from the extended gas analysis collected. 2/24/1B. Source input the weight fractions into PreMax and used the software to calculate lb/hr emission rates (using built in equations and assumptions from the softward). As such, the weight % values input above are those that correspond to calculated mass emission rates from ProMax. It was determinedthat the resulting variation from the weight %'s reported on the analysis were Insignificant and may be attributed to rounding. I, "Applicant had'provided emission calculations using only high-pressure sales gas (@357 psig). However, after some discussion it was determinedthat. Extraction would estimateemissions from the HLP separatorby conservatively a ssumingthe composition of the LP gas (@ 47 psig) as representative for all gas routed Lathe thermal oxidizer (since. LP gas has higher VOC content). The actual waste gas stream to the thermal oxidizer will include gas from both the if pressure and low pressure separators. *An initial and periodic compliance testis required on the thermal oxidizer controlling emissions from this point. In additbn, the initial compliance test is required to demonstrate compliance with the VOC emission Omit in the permit. included clarifying language in the intial compliance test to indicate that if emissions are routed to the thermal oxidizer from point 007, the emission rate may take intoaccoantthe emission limitfroie Permit 17WE107O. The annual performance test is intended to only demonstrate compliance with a destruction efficiency of 99%. This into avoid complications that may arise if the equipment covered under 17WE1070 (Varra VRT) is modified and to simplify the compliance demonstration since Extraction has agreed to test the combustor on a semi-annual basis. An annual extended gas analysis is included on this gas stream to ensurethat the VOC composition does not change significantly. AIRS Point ft 005 Process a SCC Code 01 3-10-001-60 Flares Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control % Units PM10 16.59 0 lb/MMSCF PM2.5 16.59 0 lb/MMSCF SOx 1.31 0 lb/MMSCF NOx 146.92 0 lb/MMSCF VOC 73072.81 99 Ib/MMSCF CO • 111.30 0 lb/MMSCF Benzene 234.11 99 lb/MMSCF Toluene 155.65 99 lb/MMSCF Ethylbenzene 12.03 99 lb/MMSCF Xylene 46.17 99 lb/MMSCF n -Hexane 1451.21 99 Ib/MMSCF 224 TMP 0.90 99 Ib/MMSCF 22 of 40 g:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total - emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: 012 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineers judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: 014 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput maybe limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream to be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A30 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled +flow rate to flare) / (number of barrels used in the model run) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A32 23 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory Comment This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/2017) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Burner". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 Comment This equation may be referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Where: Ex = emissions of pollutant x O = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas' MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Cell: 842 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: select the entire row that includes "C8+ Heavies" in the spreadsheet by right clicking on the row fl next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row X nest to column A -select "insert" from the drop down menu Cell: A65 Comment This must be 100% Cell: 870 Comment: When cell indicates "(lb/MMscf)": EF=Xx x MW x 1006/C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gas MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm When cell indicates "(lb/bbl)": EF=XxxMWxGLR/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas' MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Note: GLR is referenced from the value input In Section 03 Cell: D79 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 maybe used only when a thermal oxidizer is used to control emissions. Cell: B82 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of lb/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C82 Comment: This column automatically converts emission factors from lb/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A90 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E93 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A112 Comment: cdmoney: This section will be automatically populated based on the regulatory analysis worksheet. Cell: A141 Comment: cdmoney: 24 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. 25 of 40 K:\PA\2017\ 17WE1064.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 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 pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. 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)? 'You have indicated that source is in the Non -Attainment Area 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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is subject to. Regulation 7, Section XVIi.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 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 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. Yes WON Yea..,,,'. Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: County 9F64 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Venting of gas from one (1) separ recovery tower '(that vents to a thermal ax)tliter during calleetie questor model: 05000 thermal oxid'i er Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter :erisruriently In5t 0d '.. Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Separator Actual Throughput =' Requested Permit Limit Throughput = Potential to Emit (PIE) Throughput = 99 13.62: MMscf per year '3.91 MMscf per year 3.91 MMscf per year Process Control (Recycling) Equipped with a VRU: ; Is VRU process equipment: - Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) 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 VRT receives fluid from HLPseparators. Gas is separated from liquids in the high/low-pressure separator and routed to sales. When gas from; oxidizer. . Stream composition is based on an extended gas analysistaken from the VR7 at 6 psig118F (sample date:7124/17) 697:Btu/scf scf/bbl Displacement Equation Ex=Q•MW• Xx/C MW Helium CO2 N2 methane ethane Weight % 1':0.00 0'.52 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcydohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes COO Heavies 23.4. 812 -4 93 Total VOC Wt % 99.9 85.1 Ib/Ib-mol 27 of 40 K:\PA\2017\17W E1064.CP1xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (Ib/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 109878.75 176.6097 134.5097 19.3028 31.8931 1098.7875 Benzene Toluene 1.7661 1.3451 0.1930 0.3189 24.5816 0.4184 Ethylbenzene Xylene n -Hexane 224 TMP 2458.1625 41.8403 Emission Factor Source Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 0.0075:.:.-:. 0.0075 0.0006 0';06 0.0500 20.094 20.094 1.586 SOx NOx CO 177.994 134.844 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) PM10 PM2.5 500 NOx VOC CO 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0,04 0.04 0.04 0.00 0.00 0.00. 0.00 0.00 0.35 0.32 0.32 0.35 0.35 214.70 198.61 1.99 214.70 2.15 0.26 0.24 0,24 0.26 0.26 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) )Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 690 638 6 690 7 526 486 5 526 5 75 70 1 75 1 , 125 115 1 125 1 9606 8886 89 9606 96 164 151 2 164 2 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 7, Section XVII.8.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e 28 of 40 K:\PA\2017\ 17WE1064.CP1.xlsm Separator Venting Emissions Inventory 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?,jT,//,�;;, 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 we 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 operatonal (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 Section 08 - Technical Analysis Notes 'Applcantprovided em ail from Questor(thermal ocidoer manufacture.) where manufacturer representative provided Quetors recommended emission factors for the 0.0000 as NOR = 0.065 lb/MM570 and CO 0.05. these emission factors are removably similar to AP -42 factors and TNRCC factors for flares, and AP 42 does not provide emission factors for Thermal Oxidizers, no further documentation will be required. `It should he noted that the applicant used the weight % results from the extended gas analysis collected 7/24/17. Source in pu t the weight fractions into ProMax and used thesoftware to calculate lb/hr emission rates (using built in c nations and assumptions from the software). As such, the on ght %values input above are tlwse that currespono. to calculated mass emission rates from ProMax It was determined that the resulting van .. "r' ir(."V the weight ,t s reported on the analts.s is ere insignificant and may be attributed to rounding. The source has estimated secondary combustion emissions based on combustion or ventedget. in the original calculations, the applicant had added an apportionment xa in pi oz 'u'I combi contribution of waste gas heat content routed to the flare from Pont 001, 004, and 006 k,owever.after discussion with applicant it was determined that Extraction would rock and report emission 5 ron comb s. on or pilot fuel as Insignificant source tathertlaan allocating across multiple points. - - - - - *Since the thermal oxidizer used for this point (Mickey VRT) is the same make and model -fr n^ ul oxidizer used to control emissions from Point 005: (Varra LP Separators) and since a is !names) o, Me c ame faniltiy and for a very similar sr reamcomposition, the ., t ;I and periodic testing're rernent for VOC destruction efficiency -::;-minimum of 99%) includes reference to the testing requirement in ?WE10i;0, Point 005 This is intended to indicate that if a compllancetesr: conducted per 17WE10E;S uccessiull demonrrraies VOC destruction efficiency of 99," or gazer-. ,...en compliance may be assumedtor this point (Point 006, 17W`r1p69). The initial and periodic testing requirement for this point only ?. requires demonstration of tompliancewth destruction efficiency and does not include arequirement t.o demonstrate compliancewth the emission limit. The 'cross-referencing" included iv the testing conditionsaos discussed with the APCD Sack Test Coordinator who indicated that his understanding of the testing requirserveras, as, written, ac as described above. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 006 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 20.09 0 lb/MMSCF PM2.5 20.09 0 lb/MMSCF SOx 1.59 0 Ib/MMSCF NOx 177,99 0 lb/MMSCF VOC 109873.75 99 lb/MMSCF CO 134.84 0 Ib/MMSCF Benzene 176.61 99 Ib/MMSCF Toluene 134.51 99 lb/MMSCF Ethylbenzene 19.30 99 Ib/MMSCF Xylene 31.89 99 lb/MMSCF n -Hexane 2458.16 99 Ib/MM5CF 224 TMP 41.84 99 lb/MMSCF 29 of 40 K: \ PA\2017\ 17 W E 1064. C P 1.x l sm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: 410 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. If the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: 412 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Venting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Squids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput may be limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream to be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP emissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the pre -combustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A30 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. If a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used in the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled +flow rate to flare) / (number of barrels used in the model ran) If operator is measuring gas flow using a meter, this cell is left blank. Cell: A32 30 of 40 K:\PA\2017\ 17WE1064.CP1.xlsm Separator Venting Emissions Inventory Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment: Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/2017) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Burner". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 Comment: This equation may be referenced In EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 -Displacement Equation (10.4-3). Where: Ex = emissions of pollutant x O = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas " MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 601 and 1 atm Cell: 642 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: If pollutant is a VOC: -select the entire row that includes "C8* Heavies" in the spreadsheet by right clicking on the row 0 next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row p next to column A -select "insert" from the drop down menu Cell: A65 - Comment: This must be 100% Cell: B70 Comment: When cell indicates "(lb/MMscf)": EF = Xx MW x 10^6/C where: EF = emission factor (Ib/MMscf) MW = Molecular weight of gas = SG of gas " MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 601 and 1 atm When cell indicates "(lb/bbl)": EF=Xxx MW x019/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas " MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D79 Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: B82 Comment: The operator should provide emissions factors for NOx, CO and PM30/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of lb/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C82 Comment: This column automatically converts emission factors from lb/MMBtu to Ib/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A90 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E93 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can be more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A112 Comment: cdmoney: This section will he automatically populated based on the regulatory analysis worksheet. Cell: A130 Comment: cdmoney: 31 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. 32 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Nen-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. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greaterthan 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 'You have indicated that source Is in the Non -Attainment Area 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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part (3, Section II.D.2)? 'Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is subject to Regulation 7, Section XVII.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 Section' a, Is thla separator aentrelleal ley a baeli-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 30 811 Yes .•f Niff Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 123 9POM1 Counts Plant 047 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates one,(I) vapor recovery g50p0;thermal oxidizer �3at#nafi6a�S7e[ Primary Emissions - Separator Actual Throughput =-? Requested Permit Limit Throughput = , Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU Yi Is VRU process equipment: Y. .46 MMscf per year MMscf per year 7.46 MMscf per year er (VRT) that vents to a thermal oxidizer duringcoflection system do Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control liquids throughput: scf/bbl Description oxidizer.. Stream composition is basedon an extended gas analysis takenfrom the VRT at G psig, 118F (sample date: 7/24/17) Displacement Equation Ex=Q*MW*0x/C MW 47.3812 Weight Helium -0.00 CO2 0.62 N2 1:18 methane -- 2.08 ethane 11.47 propane 32.87 isobutane 6.78 n -butane -- 22.88 isopentane 6.29 n -pentane ''. 7.97 cyclopentane 0.41 n -Hexane 1.97. cyclohexane 2 57'. Other hexanes heptanes 2.21 rnethylcyclohexane 0118 224-TMP 0.02 Benzene 0,11 Toluene -. 0.08 Ethylbenzene 0.02 Xylenes 0.03 C8+ Heavies 0.16 Total VOC Wt 999 4, 5 Ib/Ib-mol 34 of 40 K:\PA\2017\17WE1064.CP1.tlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (Ib/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 10568024 1056,8084 140.5859 1.4059 98.3333 0.9833 20.7019 0.2070 33.8505 0.3385 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2457.1418 24.5714 28.5954 0.2860 Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 0.0075 0.0075......... 0.0006 0.0660 ................ 19.637 19.637 1.550 500 NOx CO 173.943 131.775 .0500 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) PM10 PM2.5 SOx NOx VOC CO 0.07 0.06 0.06 0.07 0.07 0.07 0.06 0.06 0.07 0.07 0.01 0.00 0.00 0.01 0.01 0.65 0.54 0.54 0.65 0.65 394.24 328.61 3.29 394.24 3.94 0.49 0.41 0.41 0.49 0.49 Hazardous Air Pollutants Potential to Emit Uncontroled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year( Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1049 874 9 1049 10 734 612 6 734 7 154 129 1 154 2 253 211 2 253 3 18333 15281 153 18333 183 213 178 2 213 2 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) 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 XVII.0.2.e 35 of 40 K:\PA\2017\ 17WE1064.CP1.xlsm Separator Venting Emissions Inventory 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? �f 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 gW 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. *Or -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/bhl) 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 ahove that the monitored process paramete is natural gas vented. The following ques ons do no ellSW Section 08 -Technical Analysis Notes Applicant provided madfromo Questor(thennal.00idlzer manufacturer) whereimanufectnter representive providod<luasfor`s recommended em ¢sion feelers -for the 05000 as NO0 = 0.46f1Si/MMBTU anid CO DASIb/MMBTU, Since these erhis§idit factors are roasortably:similar to AP -42 factors and TNRCC factors for flures„an'd AP 42 does not provide emission factors for Thermal Oxidizers, no further documents horuwill=be regwred • *1# should be noted that the applicant used the weight % results from the extended gas analysis collected 7/24/27. Source input the weight freetions into ProMax and used the software to calculate lb/hr emission. rates (using built in equations. andassumptionsfromthesoftware). As such, the weight% values input above are those that correspond to calculated mass emission Yates from ProMax It was determined that the resulting variation:from the:Weight orted nthe anal is were ins nificant and ma hea i , dta rounding. f. -gyp � i'S g Y attributed -e, -- - - -- lilltittbe source has estimated secondary combustion emissions -based on combustion of tank vapors. In the original', calculations, the -applicant hadadded an a ppottionmeno of the pilot fuel combustion emissions based on the relative contribution of waste gas heat content routed to the flare from Point 002, 0^v5, anti 007. However, after discussion with applicant it was determined that Extraction would track and report emissions from combustion of pilot fuel as an insignificant source rather than allocatng across multiple points, - Since this is the same thermal oxidizer used to control emissions frare Point 005 (Varna Lpe Separators), the initial and periodickedingnequirementfor VOC destruct cat efficiency•(minimum of 09%) includes reference to the iesnng . requirement in 17WE1060, Point 000. This is intended to indicate that if a campLance test conducted per 17WE1068 successfully demonstratesVOC destruction effc en_y or` 99% or greater, then compliance may be assumed for this point (Point 007, 17WE1070). The initial and periodic testing requirement for this point only requires.demonsmation of compliance with destra n,efficiency and -does not nclude:a _requirementto demonstrate compliance with the emission 5mitzThe "cross-referencing" included in the testing conditions was discussed with the APCD Stack Test Coordinator who indicated that his understanding ofthe testing-egokements, as inn tten, are as described above. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 007 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 19.64 0 Ib/MMSCF PM2.5 19.64 0 Ib/MMSCF SOx 1.55 0 Ib/MMSCF NO% 173.94 0 lb/MMSCF VOC 105680.84 99 Ib/MMSCF CO 131.78 0 Ib/MMSCF Benzene 140.59 99 Ib/MMSCF Toluene 98.33 99 Ib/MMSCF Ethylbenzene 20.70 99 Ib/MMSCF Xylene 33.85 99 lb/MMSCF n -Hexane 2457.14 99 lb/MMSCF 224 TMP 28.60 99 lb/MMSCF 36 of 40 K:\PA\2017\17W E1064.CP1xlsm Separator Venting Emissions Inventory Cell: A2 Comment: cdmoney: Enter the facility AIRS ID number (County/Plant/Point) if previously assigned by the Air Pollution Control Division (APCD). If you are reporting a new point at a site with an existing County and Plant ID, fill in the known information. Cell: A7 Comment: cdmoney: - Enter a detailed description of the emission unit (how many separators, type (high pressure, low pressure, vapor recovery tower (VRT), etc.) so this information can be copied directly into the equipment description in the permit. For example: One (1) low-pressure separator Cell: A9 Comment: cdmoney: Examples: Enclosed Flare during VRU downtime Enclosed Flare Open Flare Thermal Oxidizer Cell: A10 Comment: cdmoney: This value represents the requested overall control efficiency for a single control device. if the source is requesting a more complex control scenario, such as permitting for control device downtime or permitting for a backup control device with different control efficiency than the primary control device, this PA needs to be edited to address the unique control scenarios. One option is to create a worksheet for each control scenario and an additional worksheet for total emissions. Another option is to create additional tables within this worksheet for the other control scenario and total emissions. Cell: Al2 Comment: Use the appropriate Process Parameter based on how the emissions are estimated and engineer's judgment. Use Natural Gas Vesting as a process parameter if: • The point has a PTE greater than 100 tpy of VOC, AND • the point includes a HP/HLP/LP separator OR Use Natural Gas Venting as a process parameter if: • The owner.operator is requesting Natural Gas Venting as a process parameter, AND • The owner operator is willing to use a flow meter Use Liquids Throughput as a process parameter if: • the point has a PTE less than 100 tpy of VOC, or • the point is a VRT permitted by itself Cell: A14 Comment: This selection indicates whether or not the operator will have a gas meter installed and operational upon issuance of the permit. If not, the operator shall agree to install a meter within 180 days of startup. If the operator will not have a meter installed and operational upon startup, the "volume of waste gas emitted per BBL of liquids throughput" (i.e. the value specified in cell B31) shall be used to monitor gas volume. Cell: A19 Comment: This value represents the actual throughput Cell: A20 Comment: This value represents the requested separator gas volume or corresponding liquid throughput the operator will accept as a permit limit and the basis for the permitted emissions in a traditional construction permit. The requested limit must be based on the volume of liquid throughput (BBL per year) if the operator is not required to install a gas flow meter. If the operator is required to install a gas flow meter, the requested limit must be based on volume of gas. The operator can request a throughput limit less than the gas production rate of the separator or total liquid throughput but this value will be the enforceable permitted limit and will be the basis for calculating requested emissions for the separator. For example, if a portion of the separator stream is being recycled as part of the process (e.g. via a VRU), then the requested throughput may be limited to the gas volume routed to flare or liquid throughput while emissions are routed to flare. If the source does not want to take credit for recycling (or the recycling is determined to not be part of the process), then the requested separator gas volume is the maximum vent rate at requested operating hours or total liquid throughput. Cell: A21 Comment: This value represents requested throughput. The "Potential to Emit (PTE) Throughput" is the same as the "Requested Permit Limit Throughput" for this source type. Cell: A23 Comment: The information provided in this section will establish the portion of the gas stream to be recycled. Cell: A25 Comment: The vapor recovery unit (VRU) is considered process equipment if 100% collection is assumed while the VRU is operating. If source is requesting less than 100% collection efficiency while the VRU is operational, it is likely the VRU is not considered process and should be addressed as a control device. Refer to PS -Memo 99-03 for additional guidance. Cell: A27 Comment: The information provided in this section will establish the basis to estimate secondary emissions that result from emissions controls that combust VOC and HAP omissions from the separator Cell: A29 Comment: Gas heating value is the amount of heat produced from the complete combustion of a unit of fuel. The higher (or gross) heating value is obtained when all products of combustion are cooled to the precombustion temperature, water vapor formed during combustion is condensed, and necessary corrections have been made. This value represents the maximum heat content of the separator gas emitted. This value is based on the site -specific gas sample if available, the modeled value, or the weighted average if this point represents more than one gas stream such as LP separator gas plus VRT gas. Cell: A30 Comment: This value represents the ratio of the volume of waste gas emitted from the separator(s) per barrel of condensate/crude oil produced. ff a process simulator (i.e. ProMax, HYSYS, etc.) is used, then the volume of waste gas produced should be based on the TOTAL gas flow from the separation equipment as predicted by the model. This waste gas volume is then divided by the number of barrels used is the model run. For example, if the gas stream from the separator is recycled, then the scf/bbl ratio is: (flow rate recycled + flow rate to flare) / (number of barrels used in the model run) if operator is measuring gas flow using a meter, this cell is left blank. Cell: A32 37 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory Comment: This section establishes the process rates that are the basis for; actual emissions and will be reported to the Division's emissions inventory system; requested permitted emissions that will become a limit in the permit issued; and the potential to emit used to establish if the facility should be considered a true minor, synthetic minor or major source under Colorado Regulation 3 permitting programs. Cell: A35 Comment: Enter a detailed description of basis for emission calculations. Include details of the process setup and any sample analyses used (include where the sample was pulled, date of the sample, etc.). If a model is used, indicate which type of model and basis for model inputs. For example: This VRT is located downstream of an inlet (high pressure) separator and low pressure separator where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid sample was taken from the low pressure separator at 32 psig; 90.3 deg F (sampled: 2/15/2017) and modeled, using ProMax Ver 4.0, through the VRT. The mass fractions, molecular weight (MW), and vent rate of the waste gas stream are derived from the modeled VRT gas stream "VRT Vapors to Burner". The ProMax model was run based on 1 bbl/day condensate throughput. Cell: A38 Comment: This equation maybe referenced in EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Where: Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60E and 1 atm Cell: B42 Comment: The values input to this table represent the % by weight in the gas stream (i.e. if the value is 40%, then "40" must be input here) If additional pollutants must be added to this table based on the reported stream composition, the user can insert a row as follows: if pollutant is a VOC: -select the entire row that includes "C8+ Heavies" in the spreadsheet by right clicking on the row # next to column A -select "insert" from the drop down menu If pollutant is not a VOC: -select the entire row that includes "propane" in the spreadsheet by right clicking on the row # next to column A -select "insert" from the drop down menu Cell: A65 Comment: This must be 100% Cell: B70 Comment: When cell indicates "(Ib/MMscf)": EF=XxxMW 1006 /C where: EF = emission factor (lb/MMscf) MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm When cell indicates "(lb/bbl)": EF = Xxx MW x GLR/C where: EF = emission factor (lb/bbl) MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas GLR = volume of waste gas emitted per barrel of liquids throughput (scf/bbl) C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Note: GLR is referenced from the value input in Section 03 Cell: D79 • Comment: NOx and CO emissions factors from AP -42 Table 1.4-1 may be used only when a thermal oxidizer is used to control emissions. Cell: B82 Comment: The operator should provide emissions factors for NOx, CO and PM10/PM2.5 which represent the post combustion emissions resulting from the emissions control device (e.g. secondary emissions). Ensure the emission factors are in the correct units of lb/MMBtu (convert within the cells to establish correct units if needed). Leave NOx, CO and PM10/PM2.5 E.F. blank if the unit is not controlled. Cell: C82 Comment This column automatically converts emission factors from lb/MMBtu to lb/MMscf waste gas combusted since ongoing compliance demonstration for actual emissions will be calculated using actual waste gas volume multiplied by an emission factor. It is more straightforward to convert all emission factors into units correlating to the process limit. The lb/MMscf emission factors for NOx, CO and PM should be listed in the Notes to Permit Holder section of the permit. Cell: A90 Comment: All values contained in the emissions inventory section are automatically calculated based on the information provided in the preceding sections. Cell: E93 Comment: Secondary emissions from control devices are listed in the uncontrolled and controlled columns in this emissions inventory table. While secondary emissions are not generated until the emitting unit is controlled, the secondary emissions are not actually being controlled so it is appropriate to list the secondary emissions as uncontrolled. Also, by listing the secondary emissions under uncontrolled and controlled, facility emissions can he more clearly summarized and the facility source classification regarding true minor/synthetic minor/major status can be more logically assessed. Cell: A112 Comment cdmoney: This section will be automatically populated based on the regulatory analysis worksheet. Cell: A141 Comment: cdmoney: 38 of 40 K:\PA\2017\17WE1064.CP1.xlsm Separator Venting Emissions Inventory This section should include discussion to support decisions made throughout this document if there are anomalies or unique circumstances or any area that warrant a more thorough evaluation and/or explanation. For example, if unique modeling was performed to develop the emission factor or if there is a unique process set-up that impacts emission factors and/or regulatory applicability. 39 of 40 K:\PA\2017\ 17WE1064.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 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 pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. 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)? You have indicated that source is in the Non -Attainment Area 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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Source is subject to Regulation 7, Section XVII.R.2, G Section XVIl.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVII.E.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 "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 Yes Y Permit number: Date issued: Issued to: lth b• Environment CONSTRUCTION PERMIT 17WE1064 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Ft Gas, Inc. Mickey-Varra Production Facility 123/9F64 SWNE SEC 5 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-01 - TK- 12 001 Twelve (12) 400 barrel fixed roof storage vessels used to store condensate produced from Mickey wells. Enclosed Combustor 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 Mr Pollution Control Division Page 1 of 8 3. ner =r operator of the source for which this permit was issued: tion odification or operation of this source within 18 months suance f this construction permit or the date on which such ruc :on r tivi w• sched <-d to commence as set forth in the permit application ssocia - • wi is p i ii) di "co tinues 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,t VOC CO TK-01 - TK-12 001 --- --- 5.0 --- 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 TK-01 - TK-12 001 Enclosed Combustor(s) VOC and HAP COLORADO AirPoilution Control Division v ci.₹ Pub I eetn v E v¢o-nratent Page 2 of 8 8. he fo ..wing maximum processing rates as listed below. Monthly ing rat shall be maintained by the owner or operator and made abpectpon request. (Regulation Number 3, Part B, I I.A.4. ) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-01 - TK-12 001 Condensate Throughput 1,160,524 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. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section COLORADO Air Pollution Control Division Dap rtment R. `wt c fieftWft 6 E^triron to t Page 3 of 8 inspections for a period of two years, made available to requirement must be met within 90 days of the date that 14. "" st. ov • this . m.=F, it are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING & 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 XII.C, 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 (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. COLORADO Air Pollution Control Division t)eparhne,',t-.fi t» Verith G E;^voor:rnertt Page 4 of 8 19. tion No. 3, Part D shall apply at such time that any n bec es a major stationary source or major modification solely y enfor able limitation that was established after August 7, 1980, or mod ; ication to otherwise emit a pollutant such as a restriction ce: ' _ •u ation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Air Pollution Control Division Dwttstn:t, E vvmrvrtertt Page 5 of 8 Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. COLORADO Air Pollution Control Division ,:attn! nt of Pbu€ : 44£uth & E viroY;meni Page 6 of 8 Notes •jam it c'°'rat Fes; ime .> E is p- it issuance: 1) Thi d t•4'a fees •r the processing time for this permit. An invoice for these few e u u of F -r th pen it is iss d. The permit holder shall pay the invoice within 30 days pt h jic e to =.aka: 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 1,161 58 Toluene 108883 481 24 Ethylbenzene 100414 40 2 Xylenes 1330207 159 8 n -Hexane 110543 8,124 406 2,2,4- Trimethylpentane 540841 262 13 Note: All non -criteria reportable pol utants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.1718 0.0086 ProMax 4.0 71432 Benzene 1.0E-3 5.0E-5 108883 Toluene 4.1E-4 2.1E-5 110543 n -Hexane 7.0E-3 3.5E-4 540841 2'2'4 Trimethylpentane 2.3E-4 . 1.1E-5 Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. COLORADO Aix Pollution Control Division rrxt? t •t l%.t6Pi�_ tfe0.h y E'Aror,rner t Page 7 of 8 6) In th A th a iated t ,.1 . `rml o at (303)-692-3150. 7) This permit fulfills the requirement control device per the Colorado applicable. 8) This facility is classified as follows: Air Pollutant Emission Notice (APEN) associated with from the date it was received by the Division. A revised ays before the five-year term expires. Please refer to rmine the APEN expiration date for each emissions point ions regarding a specific expiration date call the Division to hold a valid permit reflecting the storage tank and associated Oil and Gas Conservation Commission rule 805b(2)(A) when Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX !COLORADO Air Pollution Control Division ^Depanri_nt f PttNi,z. Sier3Yh'v E;vn�rame�;C Page 8 of 8 Permit number: Date issued: Issued to: Environment CONSTRUCTION PERMIT 17WE1065 Issuance: 1 Extraction Oil 8t Gas, Inc. Facility Name: Mickey-Varra Production Facility Plant AIRS ID: 123/9F64 Physical Location: SWNE SEC 5 T6N R67W 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 TK-15 - TK- 28 002 Fourteen (14) 400 barrel fixed roof storage vessels used to store condensate produced from Varra wells. 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 Control Division "Deosst :, xor Public [ieuk L E•mirclment Page 1 of 8 3. This ,-r ,all a, if t= ner '-r r operator of the source for which this permit was issued: edification or operation of this source within 18 months f this construction permit or the date on which such d to commence as set forth in the permit application ssocia wl "` is p- l ii) di .$''tinues 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 TK-15 - TK-28 002 --- --- 4.5 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-15 - TK-28 002 Enclosed Combustor(s) VOC and HAP COLORADO Air Pollution Control Division , u_prtt?'tt.:.f hita€_ Hkz;4h'v G^>vvor;r:unt Page 2 of 8 8. a.0 „e`� all •" "�ted.>'�• `'he fo .wing maximum processing rates as listed below. Monthly ing rat shall be maintained by the owner or operator and made ab: t isi - .: ,pect'= pon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-15 - TK-28 002 Condensate Throughput 986,639 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. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section `COLORADO Air Pollution Control Division Uzcert : a:rt..: f Pubic Fie:wsn'v E^risorament Page 3 of 8 inspections for a period of two years, made available to requirement must be met within 90 days of the date that 14. stov this tx it are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 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 XII.C, 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 (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. COLORADO Air Pollution Control Division st" ent �P }fie fi}3:_ F+eii3°^. U E':iRLliiYtYE't;(. Page 4 of 8 19. Reg " . tion No. 3, Part D shall apply at such time that any bec es a major stationary source or major modification solely y enfor able limitation that was established after August 7, 1980, or mod ication to otherwise emit a pollutant such as a restriction on hou oo. `'i ion ce: ' - > u ation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO AirPatiutiort Control Division i 3 t*partmerti zer Pbu€ic S eAti G+^rir�mnxHeit Page 5 of 8 Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. COLORADO Mr Pollution Control Division teiPh is tryvor;relvtt Page 6 of 8 Notes ;� ' - it • rat . ime -� ' is p- it issuance: 1) Th a s t 1. is ra'. r the processing time for this permit. An invoice for these fe .e u of F -r th pe : it is iss-d. The permit holder shall pay the invoice within 30 days pt = .s. hwA icy e to . _- . 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) 002 Benzene 71432 987 49 Toluene 108883 434 22 Ethylbenzene 100414 30 1 Xylenes 1330207 145 7 n -Hexane 110543 7,202 360 2,2,4- Trimethylpentane 540841 241 12 N 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 V0C 0.1807 0.0090 ProMax 4.0 71432 Benzene 1.0E-3 5.0E-5 108883 Toluene 4.4E-4 2.2E-5 110543 n -Hexane 7.3E-3 3.6E-4 Note: The controlled emissions factors for this point are based on the enclosed 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 COLORADO Air Pollution Control Division partu E t "i Public liletilth & E'tklrbr:rnecit Page 7 of 8 th as at rmine the APEN expiration date for each emissions point ons regarding a specific expiration date call the Division 7) T ' it lfil th; re• a nt to h.,i a valid permit reflecting the storage tank and associated c•io devi p-` e ..: Oil an 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, Benzene, Toluene, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-616175 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 ;)epartt,v2nt Pmblir Hera^.v Fair-Onr:ser;t Page 8 of 8 Permit number: Date issued: Issued to: Division Environment CONSTRUCTION PERMIT 17WE1066 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Mickey-Varra Production Facility 12319F64 SWNE SEC 5 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-13-14, TK-20-30 003 Four (4) 400 barrel fixed roof storage vessels 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 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 shalt 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 Mr PoRuUon Control Division Page 1 of 8 3. This . m expi :,the • � or o• rator of the source for which this permit was issued: ication or operation of this source within 18 months s construction permit or the date on which such uctlcommence as set forth in the permit application associate: with i per ii •iscon 1 ues 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 TK13-14, TK20-30 003 --- --- 4.0 --- 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 TK13-14, TK20-30 003 Enclosed Combustor(s) VOC and HAP COLORADO Air Pollution Control Division Depotmea ewer nmet Page 2 of 8 8. maximum processing rates as listed below. Monthly be maintained by the owner or operator and made equest. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK13-14, TK20-30 003 Produced Water Throughput 1,987,369 barrels 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. COLORADO Air Pollution Control Division epvhhetMkoth & e'vu'&ht.h&5t Page 3 of 8 14. ar p thes.. ner • operator shall follow the most recent operating and cord ke•ing format approved by the Division, in order to nst c• ce , oing with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). COLORADO Air Poliutiort Control Division ?tit), erS l ibti bieaYth *'s e^virorrrer;t Page 4 of 8 19. This • r ; • an hm is ` ust t- retained and made available for inspection upon ed to a `` w owner by the APCD as provided in AQCC Regulation er - r' s " . ti • :. on a r `r st for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer Permit History COLORADO Air Pollution Control Division "itit t fierPtn & Erwimrirrit,,It Page 5 of 8 COLORADO Air Pollution Control Division AT, Description ssued to Extraction Oil Et Gas, Inc. Page 6 of 8 Notes Per N' H t: t th - - oft s...termlt suance: 1) Th perm hod a req ;'' .. pa eds for t - processing time for this permit. An invoice for these fe will "- is ed ter he p mil issued e permit holder shall pay the invoice within 30 days t •. -. ..s4 pay 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 (ib/yr) 003 Benzene 71432 1,575 79 Toluene 108883 1,140 57 Ethylbenzene 100414 45 2 Xylenes 1330207 784 39 n -Hexane 110543 3,939 197 2,2,4- Trimethylpentane 540841 235 12 Note: Alt non -criteria reportable pollutants in the table above with uncontrolled emiss'on 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 V0C 0.0788 0.0039 ProMax 4.0 71432 Benzene 7.9E-4 4.0E-5 108883 Toluene 5.7E-4 2.9E-5 1330207 Xylene 3.9E-4 2.0E-5 110543 n -Hexane 2.0E-3 9.9E-5 540841 2'2'4 Trimethylpentane 1.2E-4 5.9E-6 Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. COLORADO Air Pollution Control Division •zfrrr,et•t .t₹r€=Hcu';i .G Emirn,rnesr:t Page 7 of 8 6) In cord yce R S 114 x .ch Ai Pollutant Emission Notice (APEN) associated with th <perm � is �r for a F •f fiv: y rs fr.,> the date it was received by the Division. A revised APR sha be . b e 'tted� o efore the five-year term expires. Please refer to th :m• ece a al ee in ice • determ. e the APEN expiration date for each emissions point a s'' ated his • `" it. • y• estio -garding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division ti,zpuvnertt car Public E iet3M is vo ;rnert Page 8 of 8 Permit number: Date issued: Issued to: AD n Contr c Heal CONSTRUCTION PERMIT 17WE1067 Issuance: 1 Extraction Oil &t Gas, Inc. Facility Name: Mickey-Varra Production Facility Plant AIRS ID: 123/9F64 Physical Location: SWNE SEC 5 T6N R67W 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 Mickey Separator Venting 004 Venting of gas from thirteen (13) low pressure (LP) separators to a thermal oxidizer while gas collection system is unavailable Oxidi zer Thermal (Make: Qr, Model: Q5000) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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 COLORADO Mr Pollution Control Division Page 1 of 9 online at •lorado o, < /cd•he/alrx3e rmit-self- r 3, Part B 3. =:s permit 4y l expi rator of ource which this perms s issued: comm ,;>> .tru 3z , -. - ration t - _ .is source >.' onths 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 Mickey Separator Venting 004 --- --- 0.9 --- 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.) OLORADO Air Pollution Control Division Page 2 of 9 Separator Venting A P4 004 Device the L uted to a Thermal Oxidizer while the gas collection system is unavailable lutants ntrolled 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.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Mickey Separator Venting 004 LP Separator gas vented to thermal oxidizer 3.12 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 gas vented from the separator(s) covered by this permit to the thermal oxidizer using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. ICOLORADO Air Pollution Control Division p ;r['x t i Pub Hohh's t_,wironretent Page 3 of 9 13. - separato ere. ` it is subj toe; • ulation 7, . XVII.G. (St " Only). On 201 -a ing off a soduced d ng n mat operat y from any d, h . ; aulic fractures or recleted o nd gas well, mu <'either be s gath _• line m ontr. -d from th gate of .t •roduction b •ollution equipment � = :' hiev- . ge h .. . ` •o • ".1 efficien . .. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record -keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner 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) 16. A source initial compliance test shall be conducted to measure the emission rate for Volatile Organic Compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 99% for VOC. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The volume of gas throughput and thermal oxidizer combustion chamber temperature shall be monitored and recorded during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. A performance test used to comply with the Initial Testing Requirements in Permit No. 17WE1068 Issuance 1 for the equipment covered by AIRS point 123/9F64/005 may be used to demonstrate compliance with this testing requirement. (Regulation Number 3, Part B., Section III.G.3) 17. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). COLORADO Air Pollution Control Division Deprr nentof Pubfit 3iud"h'v E^Mr6nrrtetlC Page 4 of 9 18. a semi an 4l bas a so' - complia - - ."" = l be con L'r led n this emisV point to issionte fo atile O, anic Co nds (Vi in order to dem trate the izer (T"'., , , es estru :. 99% for VO n== erator shall determine the mass emission rates of VOC at the inlet and outlet of the control device to determine the destruction efficiency of the TO. The volume of gas routed to the TO from this point and the TO combustion chamber temperature shall be monitored and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted less than one hundred fifty (150) days subsequent to any performance test used to demonstrate compliance with any Periodic Testing Requirements in this permit. No compliance test shalt be conducted without prior approval from the Division. A performance test used to comply with the Periodic Testing Requirements in Permit No. 17WE1068 Issuance 1, for the equipment covered by AIRS point 123/9F64/005, may be used to demonstrate compliance with this testing requirement. (Regulation Number 3, Part B, Section III.E.) 19. On an annual basis, the owner/operator shall complete a site -specific extended gas analysis ("Analysis") of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 20. 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. !COLORADO Air Pollution Coritral Division girt ad t tctYet6 eviimnmet,,t Page 5 of 9 r the er ne �° ontrol pment an e in the o s installe of con erator ofty, process activity; a different ty• : •f control • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 22. 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. 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 COLORADO Air Pollution Control Division E'srir�r;r±rer Page 6 of 9 Bradley Eades Permit Engineer ons 25-7- �4 :,.rcement) njunctions) X122 (civil lties), C.R Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Ft Gas, Inc. !COLORADO Air Pollution Control Division DeP.arttnent �f ct@.riw Heathh Ermrorr,tea Page 7 of 9 Notes tpermit iss 1) The. <rrmit holde requi to • ees for the i time f. 's pe ` it. An invo for these fees' 11 be iss - fter t ssued a perms lder sh .ay the invoicen 30 days e inv.' �.�.� �'3 ure ,�. �r_�invoi �. e, Y >. evocation ermit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) Mickey Separator Venting 004 Benzene 71432 263 3 Toluene 108883 145 1 Ethylbenzene 100414 12 <1 Xylenes 1330207 46 <1 n -Hexane 110543 1746 17 2,2,4 Trimethylpentane 540841 1 <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 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source V0C 55822.17 558.22 ProMax 4.0 71432 Benzene 84.21 0.84 110543 n -Hexane 559.61 5.60 Note: The controlled emissions factors for this point are based on the thermal oxidizer control efficiency of 99%. 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 COLORADO Air Pollution Control Division 1 D,p rtr,, :n[ Ri€aE C Hen, N.o U;abnrrrter,t Page 8 of 9 determine N expiratit • •r each emi •ns point questions r y specific lra i date callDivision Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO 1 Air Pollution Control Division "Depsrrf.tent of PtAbt teat &invir6nrfleflt Page 9 of 9 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1068 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil &t Gas, Inc. Mickey-Varra Production Facility 123/9F64 SWNE SEC 5 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Varra Separator Venting 005 Venting of gas from eleven (11) low pressure (LP) separators to a thermal oxidizer while gas collection system is unavailable Thermal Oxidizer (Make: Questor, Model: Q5000) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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 ICOLORADO Air Pollution Control Division # Uemirtment r Publit Health sE„rrcrrn<<nt Page 1 of 9 online at 3, Part B I. f /cdphe/air ��s permit ��l expi f the rator of :. ource which this permi as issued: commtru ation s source w . onths 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 Varra Separator Venting 005 --- 11.4 56.6 8.7 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 shalt 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.) • COLORADO Air Pollution Control Division Oh Emrttoriment Page 2 of 9 A P Separator Venting 005 evice E • the outed to a Thermal Oxidizer while the gas collection system is unavailable tants C rolled 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.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Varra Separator Venting 005 LP Separator gas vented to thermal oxidizer 154.7 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 gas vented from the separator(s) to the thermal oxidizer using a 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.) I. 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 )0/II, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution COLORADO ( Air Pollution Control Division n L> L'rar/Arnert Page 3 of 9 s an aver ocarbon `-fficiency • 5%. If a ust have estructioici cy of at l t 98% for OPE 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner 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) 16. A source initial compliance test shall be conducted to measure the emission rate for Volatile Organic Compounds (VOC) in order to demonstrate compliance with the emission limits specified in this permit and to demonstrate a minimum destruction efficiency of 99% for VOC. The test shall determine the mass emission rates of VOC at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The volume of gas throughput and thermal oxidizer combustion chamber temperature shall be monitored and recorded during the test. If gas from the Vapor Recovery Tower (VRT) covered by AIRS point 123/9F64/007 is routed to the thermal oxidizer during the compliance test, the source shall use the measured outlet emission rate for VOC to demonstrate compliance with the sum of the emission limits specified in this permit and the emission limits specified in Permit 17WE1070. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results, in units of lb VOC/MMSCF waste gas, by the allowable waste gas volume for that averaging period as indicated in the process limits section of this permit. (Regulation Number 3, Part B., Section III.G.3) 17. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). COLORADO Air Pollution Control Division ;2 Bets th. s En'amrnvnt Page 4 of 9 18. a semi any l bas com lia - l be con ted n this emis ` p � - point to ission fo atile O anic Co nds (Vr - in order to demtrate the izer (T es .' : estruc 99% for VO erator shall determine, using EPA approved methods, the mass emission rates of VOC at the inlet and outlet of the control device to determine the destruction efficiency of the TO. The volume of gas routed to the TO from this point and the TO combustion chamber temperature shalt be monitored and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test manual and shalt be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted less than one hundred fifty (150) days subsequent to any performance test used to demonstrate compliance with any Periodic Testing Requirements in this permit. No compliance test shall be conducted without prior approval from the Division. (Regulation Number 3, Part B, Section III.E.) 19. On an annual basis, the owner/operator shall complete a site -specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site - specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 20. 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 COLORADO Air Pollution Control Division Deper:ment 1ie4tne;rrorrnr:t Page 5 of 9 ion must . mo > eed; or ore the e . ing expires. 21. " ents • • ado • l ;� No. 3, . s : • • ly at such .�, i at any stationary source or moil ication ecomes a major stationary source or major mo.i ication solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 22. 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. 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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: ICOLORADO Air Pollution Control Division DepoTt=rkrt of Yuh€w Beatth& Enrirsa:tent Page 6 of 9 Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. COLORADO Air Pollution Control Division + -v.:rtfrfk tai' PtsbU,tact <<s Envir.,..Vrvelt Page 7 of 9 Notes t•' -rmit Hold 3 t they permit iss 1) The X rmit holde equi to • ees for th ` • - time f. s pe it. An invo for these fee<,.%II be iss -.fter t •ermi ssued. ` e permi 1 = lder sh .ay the invoice w n 30 days e invure invoievocation , :. „'ermit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Varra Separator Venting 005 Benzene 71432 36,216 362 Toluene 108883 24,078 241 Ethylbenzene 100414 1,861 19 Xylenes 1330207 7,142 71 n -Hexane 110543 224,495 2,245 2,2,4- Trimethylpentane 540841 139 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 005: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (Ib/MMSCF) Source V0C 73,072.81 730.73 ProMax 4.0 N0x 146.92 146.92 CO 111.30 111.30 71432 Benzene 234.11 2.34 108883 Toluene 155.65 1.56 100414 Ethylbenzene 12.03 0.12 1330207 Xylenes 46.17 0.46 110543 n -Hexane 1,451.21 14.51 COLORADO Air Pollution Control Division De pot,ne tt Cif Pub(it', Hea: h s E vr3rr3vnt Page 8 of 9 for this poi and CO from sion facto gas H ed on the t mal k'' idizer contro ficiency of of the wa earn were ca °'lated using MMbtu N�:'``:nd I"""I5 lb/MMbtu ': Emissions f. 6) In accor•ance with C.R. -114.1, eac �ir'ollutan mission o ice (APEN) associa es with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date, call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division t)epOrttnent or Nublio Heave„ s Environment Page 9 of 9 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1069 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Mickey-Varra Production Facility 123/9F64 SWNE SEC 5 T6N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Mickey VRT Venting 006 Venting of gas from one (1) vapor recovery tower (VRT) to a thermal oxidizer while gas collection system is unavailable Thermal Oxidizer (Make: Questor, Model: Q5000) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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 startupof 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.) 3COLORADO Air Pollution Control Division 1 ;>:!,Dcirtm_"l Gi FOAt 3 kmtt & E-; vimrirr ' t Page 1 of 8 3. s permit s does not c er either, stru • with thin more; (iii) does not complete date. The Division may grant III.F.4.) er or oper e source this perms as issued: tion/modifperation iswource withl 8 months ce of t >1 constrk' 'on per or the date on ich such uled commen s set th in the perms I • • lication (ii) • : " ° r -s cons • • - •od of eigh - - • the or construction within a reasonable time of the estimated completion extensions of the deadline. (Regulation Number 3, Part B, Section 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 Mickey VRT Venting 006 --- --- 2.2 --- 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 Mickey VRT Venting 006 Emissions from the VRT are routed to a Thermal Oxidizer while the gas collection system is unavailable VOC and HAP COLORADO Air Pollution Control Division nr Page 2 of 8 PROCES 8. be li ed t e followi ctual cessi •tes sh '' be main he Di iinspeque Process Limits ate e' :s listed be . Monthly owner or operat nd made ber 3, Par .) Facility Equipment ID - AIRS Point Process Parameter Annual Limit Mickey VRT Venting 006 VRT gas vented to thermal oxidizer 3.91 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 gas vented from the vapor recovery tower to the thermal oxidizer using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to COLORADO Air Pollution Control Division _pstt e .t.:,€ Page 3 of 8 to implem; . (Regulatio umber 3, ni is ` esting Requiremen s 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) 16. A source initial compliance test shall be conducted to measure the emission rate for Volatile Organic Compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 99% for VOC. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The volume of gas throughput and thermal oxidizer combustion chamber temperature shall be monitored and recorded during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. A performance test used to comply with the Initial Testing Requirements in Permit No. 17WE1068 Issuance 1 for the equipment covered by AIRS point 123/9F64/005 may be used to demonstrate compliance with this testing requirement. (Regulation Number 3, Part B., Section III.G.3) 17. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Periodic Testing Requirements 18. On a semi-annual basis, a source compliance test shall be conducted on this emission point to measure the emission rate for Volatile Organic Compounds (VOC) in order to demonstrate the thermal oxidizer (TO) achieves a minimum destruction efficiency of 99% for VOC. The operator shall determine the mass emission rates of VOC at the inlet and outlet of the control device to determine the destruction efficiency of the TO. The volume of gas routed to the TO from this point and the TO combustion chamber temperature shall be monitored and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted less than one hundred fifty (150) days subsequent to any performance test used to demonstrate compliance with any Periodic Testing Requirements in this permit. No compliance test shall be conducted without prior approval from the Division. COLORADO Air Pollution Control Division »eoar ?x t v' Puht i le@ M 6 Erwimnrrier,t. Page 4 of 8 ply with .dic Testi uipment cf.. IRS Poin • testin equirem . (Regul rements in 64/005 ma n Number 3, Pa rmit No. e used to , Section 19. On an annual basis, the owner/operator shall complete a site -specific extended gas analysis ("Analysis") of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 20. 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 1OO 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 1OO 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 1OO 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. 21. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS COLORADO Air Pollution Control Division t),4x,rt,rtr,tot Pu43Heat':'v E:^xrcronrret t. Page 5 of 8 22. s must be ued to a n on a re and mad .le for ins• M ion upon the APC s pr.'ided in AQC Regulation sfer of • .n ership and the s ittal of a 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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: Bradley Eades Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Ft Gas, Inc. COLORADO Air Pollution Control Division Notes tpermit iss 1) The rmit holde requi to • ees for thtime fo s pe it. An invo for these fee „ Ube issu .fter t•ermie ssued .. e permi lder sh ay the invoice w :y n 30 days ure invoie evocationermit. (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. N per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) Mickey VRT Venting 006 Benzene 71432 690 7 Toluene 108883 526 5 Ethylbenzene 100414 75 1 Xylenes 1330207 125 1 n -Hexane 110543 9,606 96 2,2,4- Trimethylpentane 540841 164 2 5) The emission levels contained in this permit are based on the following emission factors: Point 006: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source V0C 109,878.75 1098.79 ProMax 4.0 71432 Benzene 176.61 1.77 108883 Toluene 134.51 1.35 110543 n -Hexane 2,458.16 24.58 Note: The controlled emissions factors for this point are based on the thermal oxidizer control efficiency of 99%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised 'COLORADO Air Pollution Control Division Drprr ”ler;t Pltbl e )-iott t' Ss G ; ir6nmer.t Page 7 of 8 APE the ass at hall be sub st recent a ted with t -69 - 7) This facility is classified as follows: 30 days b • "x five-year i sires. Pleas fer to o determi ,.� expirati•_= •a a .r each emi€.ns point uestions ; -garding :;specific iration date call ' '? Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX !COLORADO 1 Air Pollution Control Division '.«,,p:rt, rx or Publz Heahh '61,mir,Dnrrient Page 8 of 8 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: n Contro c Heal 17WE1070 Issuance: 1 Extraction Oil &t Gas, Inc. Facility Name: Mickey-Varra Production Facility Plant AIRS ID: 123/9F64 Physical Location: SWNE SEC 5 T6N R67W 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 Varra VRT Venting 007 Venting of gas from one (1) vapor recovery tower (VRT) to a thermal oxidizer while gas collection system is unavailable Thermal Oxidizer (Make: Questor, Model: Q5000) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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 Mr Pollution Control Division 1,,ipaittrivv ut Public; Hea,ith s G Mr6r,rite.t Page 1 of 8 3. expi er or oper = or •: a source s . i this permi enc o tion/modif ource withi e da °•f is �.ce of t , constre : on per or t e date on r activ was s. • uled commen r s set h in the permi t _9• • lication e with thl ;.... (ii) s cons r • • - lod of eigh = - � ' " • ' the or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit atone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: s permit s does not c er either, stru s issued: 8 months ich such Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Varra VRT Venting 007 --- --- 4.0 --- 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 Varra VRT Venting 007 Emissions from the VRT are routed to a Thermal Oxidizer while the gas collection system is unavailable VOC and HAP ;COLORADO Air Pollution Control Division i r ay ru rsc ar Pubk Oft & nVi,,Dnn ee:e Page 2 of 8 8. e followi cessi = ' . tes sh I be main insp, eque Process Limits ate listed be . Monthly owner or operat nd made ber 3, Par .) Facility Equipment ID AIRS Point Process Parameter Annual Limit Varra VRT Venting 007 VRT gas vented to thermal oxidizer 7.461 MMSCF Compliance with the annual throughput limits shalt be determined on a rotting 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 the vapor recovery tower to the thermal oxidizer using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O£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 JCOLORA O { Air Pollution Control Division «•U :its -:t ,;r P thLL c Page 3 of 8 to implem ; : (Regulatio r umber 3, i a esting Requiremen s 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) 16. A source initial compliance test shall be conducted to measure the emission rate for Volatile Organic Compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 99% for VOC. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The volume of gas throughput and thermal oxidizer combustion chamber temperature shall be monitored and recorded during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. A performance test used to comply with the Initial Testing Requirements in Permit No. 17WE1068 Issuance 1 for the equipment covered by AIRS point 123/9F64/005 may be used to demonstrate compliance with this testing requirement. (Regulation Number 3, Part B., Section III.G.3) 17. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Periodic Testing Requirements 18. On a semi-annual basis, a source compliance test shall be conducted on this emission point to measure the emission rate for Volatile Organic Compounds (VOC) in order to demonstrate the thermal oxidizer (TO) achieves a minimum destruction efficiency of 99% for VOC. The operator shall determine the mass emission rates of VOC at the inlet and outlet of the control device to determine the destruction efficiency of the TO. The volume of gas routed to the TO from this point and the TO combustion chamber temperature shall be monitored and recorded during this test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted less than one hundred fifty (150) days subsequent to any performance test used to demonstrate compliance with any Periodic Testing Requirements in this permit. No compliance test shall be conducted without prior approval from the Division. COLORADO Air Pollution Control Division hbt Page 4 of 8 ply with .•dic Testi quipment C IRS poin testin . (Regul rements in 4/005, ma n Number 3, Pa mit No. e used to , Section 19. On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS !.COLORADO Aix Pollution Control Division itiEN Heathv L;virrn:rnert Page 5 of 8 22. nd the uired 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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. s must be ued to a n on a re and mad le for ins • ' ion upon the APC s pr.;ided in AQC egulation sfer of .-, , ership and the s i ittal of a By: Bradley Eades Permit Engineer 0 Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil 8 Gas, Inc. COLORADO Air Pollution Control Division PuW!^ t {e<:<,n (, &-wr r\ment Page 6 of 8 Notes t•:-rmit Hold t the .` permit iss 1) The rmit holderequi to ees for th = time fo ms's pe it. An invo j for these fee �� 1I be issu ' fter t ermi ssued e permi lder sh. ay the invoice w n 30 days e invureinvoi eevocation :_ ermit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) Varra VRT Venting 007 Benzene 71432 1,049 10 Toluene 108883 734 7 Ethylbenzene 100414 154 2 Xylenes 1330207 253 3 n -Hexane 110543 18,333 183 2,2,4- Trimethylpentane 540841 213 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 007: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source V0C 105,680.84 1,056.81 ProMax 4.0 71432 Benzene 140.59 1.41 108883 Toluene 98.33 0.98 1330207 Xylenes 33.85 0.34 110543 n -Hexane 2,457.14 24.57 Note: The controlled emissions factors for this point are based on the thermal oxidizer control efficiency of 99%. COLORADO Air Pollution Control Division r:ep,,,tr"#"'A Erwironne;t Page 7 of 8 6) Ina rdance wit <> .R.S. this rmit is vali Ntr a t APE hall be su•;-t` ted n the st re nual fe a Y"` •with this pe at (303)-692-3150. 7) This facility is classified as follows: ,' each Air P years fro ter , 30 days .> eforeth voice eter 4 e the AP any •u- •` -gardin Emission ''EN) associ • with t was rec e • the Divisio revised ye -year ≥;m expires. Pleas fer fer to iratiate for each emi ins point f = •i tion date c. P ision Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, Benzene, Toluene, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix 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 Wepart of ui Public t ;e a. Yt ss evir6elri zr;t Page 8 of 8 Condensate Storage Tank(s) APEN - Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loadings, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE 1064 AIRS ID Number: 123 / 9F64 / 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: Mickey-Varra Production Facility Site Location: SWNE Sec 5 T6N R67W Mailing Address: (Include Zip code) 370 17th Street, Suite 5300 Denver, Colorado Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Phone Number: Kelli Cox (720) 557-8300 E -Mail Address': 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 APCD via e-mail to the address provided. ALTO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 1 I Permit Number: 17WE 1064 AIRS ID Number: 123 / 9F64 / 001 [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 a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source Additional Info a Notes: 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: Twelve (12) - 400 bbl Condensate Storage Tanks (Mickey) For new or reconstructed sources, the projected start-up date is: 05/10/2017 Normal Hours of Source Operation: Storage tank(s) located at: 24 hours/day 7 ❑✓ Exploration & Production (E&P) site days/week 52 weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ■ No Are Flash Emissions anticipated from these storage tanks? • Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? • Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.0004 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual• emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 AV. ICOLaRADO 2 1 Permit Number: 17WE 1064 AIRS ID Number: 123 / 9F64 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Condensate Throughput Annual Amount (bbl/year) 1,052,819 From what year is the actual annual amount? Projected Average API gravity of sales oil: 60.6379 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof ues I Annual Permit Limit4 (bbl/year) 1,160,524 RVP of sales oil: 11.095 O External floating roof Storage `Tank ID'`. # of Liquid Manifold Storage Vessels'in Storage Total Volume o Storage Tank, (bbl) Installation Date of Most ecent Storage Vessel in orage Tank (month/year) Date of First Production (month/year) TK-01 -TK-12 12 4800 05/2017 05/2017 et' API Number Se ced by this Storage: Tank or Tank Battery5 (EF&P. Sites'. Name d my Newly geported' Well See Form APCD-212 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The E&P 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 eographical Coordinates Latitude/Longitude or UT 40.4313963, -104.92409 Operator Stack ID No. ;Discharge Height Above ... Ground Level (feet) Te€np. f (°F) Flow Rate , (ACFM):. Velocity (ft/sec) ECDs -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) LI Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): TBD Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 3 I RAD° Permit Number: 17WE 1064 AIRS ID Number: 123 / 9F64 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD MMBtu/hr Make/Model: I ES / ECD-48 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: TBD Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2512 TBD 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 (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -5 psig Describe the separation process between the well and the storage tanks: 3 -phase separator, HLP Separator, VRT, Condensate Storage Tanks Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 Permit Number: 17WE 1064 AIRS ID Number: 123 / 9F64 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant escription of Con Overall Requested Control,.. Efficiency' (% reduction' in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emons Inventor Pollutant' Uncontrolled Basis 0.0.1718 lb/bbl ource AP -42, fg. etc) Uncontroled EmisSf dif Joni/y 90.44 t' • Emissiai s, ontrolled lssionY Requested Annual Permit Emission Limit{s)4 Uncontroltea Emissions (Tonslyeorj• Controlled Emissions (Tons/year) VOC Promax 4.52 99.69 4.98 NOx 0.068 Ib/MM Btu AP -42 0.17 0.18 CO 0.31 lb/MMBtu AP -42 0.76 0.83 Chemical Name n -Criteria Reportable"Pollutan lernical": Abstract ._• Service'{CAS) °,Number Emission Facto ncontrolte Bans lb/bbl sstans inventory Source (AP 2, Mfg etc) Actual Annual Uncontrolled Emissions (Pounds/year) Emissions ontrolted,' missions? (Pounds/year) Benzene 71432 0.001 Promax 1052.82 52.64 Toluene 108883 0.0004 lb/bbl Promax 436.18 21.81 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.007 lb/bbl Promax 7369.73 368.49 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 w C©lOgA Da /\ Permit Number: 17WE1064 AIRS ID Number: 123 / 9F64 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 5/10/2018 Sigrilaature 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: 0✓ 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-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd COL Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 6 Condensate Storage Tank.(s) APEN - Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loadings, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE 1065 AIRS ID Number: 123 / 9F64 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Extraction Oil & Gas, Inc. Mickey-Varra Production Facility Site Location: SWNE Sec 5 T6N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kelli Cox Phone Number: (720) 557-8300 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 APCD via e-mail to the address provided. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 cax.R .rx ;... Permit Number: 17WE 1065 AIRS ID Number: 123 / 9F64 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source I Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Fourteen (14) - 400 bbl Condensate Storage Tanks (Varra) For new or reconstructed sources, the projected start-up date is: 05/10/2017 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: ❑✓ Exploration Et Production (E&P) site weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? El Yes • No Are Flash Emissions anticipated from these storage tanks? Ii Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? IO Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.0004 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)O 805 series rules? If so, submit Form APCD-105. Yes No ■ 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-205 - Condensate Storage Tanks) APEN - Revision 02/2017 21 ert LORADO Permit Number: 17WE1065 AIRS ID Number: 123 / 9F64 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 4 - Storage Tank(s) Information Condensate Throughput:' Actual Annual Amount (bbl/year) 953,489 Requested Annual Permit Umit4 986,639 From what year is the actual annual amount? Projected Average API gravity of sales oil: 60.6379 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 11.095 ❑ External floating roof Storage Tank ID TK-15 - TK-28 # of Liquid Manifold St Vessels in Storage : - 14 Total Volume of Storage Tank (bbl)'', 5600 Installation Date of Most ecent Storage Vessel in orage Tank tmonth/year) 05/2017 Date of First Production (month/year) '! 05/2017 ell API Number Se ced by this Storage Tank or Tank Battery Name of Weil P Sites O Newly Reported Well See Form APCD-212 El El El El 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEP 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 eographical Corifi Latitude/Longitude or UTM 40.4313963, -104.92409 Operator Stack , ID No. Discharge,HeighyAbove Ground Level feet) ;": Temp. (°F) Fiow Rate =.,,.: (ACFM) Velocity rftlsec) ECDs -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal El Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): TBD Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 3 I AWCOLOIlM>O nemntat Permit Number: 17WE1065 AIRS ID Number: 123 / 9F64 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 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: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: TBD MMBtu/hr Make/Model: I ES / ECD-48 95 98 % Waste Gas Heat Content: Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 2513 TBD Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig Describe the separation process between the well and the storage tanks: 3 -phase separator, HLP Separator, VRT, Condensate Storage Tanks CADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 4 Permit Number: 17WE 1065 AIRS ID Number: 123 / 9F64 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant' escrtption of Control '.:Overall Requested Control Efficiency , (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutari Emission Factor Uncontrolled Basis Ib/bbl Source. (AP -42, AAfg, etc) Actual Annual Emissions,;,, Uncontrolled Emissions' (Tans/year): VOC 0.1807 Promax 86.15 4.31 Requested Annual Permit Emission Limitts) f;...,< Uncontrolled Emissions :irons/year) Controlled Emissions (Tons/year) 89.14 4.46 NOx 0.068 Ib/MMBtu AP -42 0.16 0.16 CO 0.31 Ib/MMBtu AP -42 0.72 0.75 tit Reportable Po[lutan MI lions vent`bry' Chemical Name Chemical Abstract Service(CAS)`. Number Emission Factor -6 Uncontrolled Basis Units Source (AP -42} Mfg etc) Actual Annual Emissions Uncontrolled Emissions (Pounds/year) Controlled Emissions? (Pounds/year) Benzene 71432 0.001 lb/bbl Promax 953.49 47.67 Toluene 108883 0.0004 lb/bbl Promax 419.82 20.99 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0073 lb/bbl Promax 6960.47 348.02 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 �v,COLORADO 5 �iii�� ::::::iiiiii «.,,sc 6.`E..umpows Permit Number: 17WE 1065 AIRS ID Number: 123 / 9F64 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 5/10/2018 Sig ture of Le ally 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: 0 Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017 6 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) wars. 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: 17WE1066 AIRS ID Number: 123 / 9F64 / 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: Mickey-Varra Production Facility Site Location: SWNE Sec 5 T6N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Phone Number: E -Mail Address2: Kelli Cox (720) 557-8300 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 APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 1 I ATF c0 II Permit Number: 17WE1066 AIRS ID Number: 123 / 9F64/ 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 ❑ Request coverage under a General Permit ❑ 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 ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Four (4) - 400 bbl Produced Water Storage Tanks (Mickey & Varra) For new or reconstructed sources, the projected start-up date is: 05/10/2017 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ❑✓ Exploration Et Production (EEtP) site 52 weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? Yes No SI • Are Flash Emissions anticipated from these storage tanks? p Yes • No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • p Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? Yes 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 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualSI emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 2I saga nEW W1, Permit Number: 17WE 1066 AIRS ID Number: 123 / 9F64 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount bbllyear) - Requested Annual Permit Limit4 '; (bbtyear) Produced Water Throughput:' 1,943,462 1,987,369 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof Projected ❑ Internal floating roof D External floating roof Storage TankID TK-13 - TK-14 # of Liquid Manifold Story Vessels in Storage Tank 2 al Volume o orage Tank (bNit 800 alatior Date of`. cent Storage Vesselin'' orage Tank (month/year 05/2017 late cif First Production . month/.year) 05/2017 TK-29 - TK-30 2 800 05/2017 05/2017 ►etts'Service is Storage Tan or Tank Batten (EffP Sites Only) API Number Name o Newly Reported Well See Form APCD-212 CI 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The E£tP 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 aphical C tatie/Lortgitad 40.4313963, -104.92409 Operator Stack' ' ID No. Discharge Height Above Ground Level•, (feet) : ; , Temp .. , rah , °', Flow. Rate (AGFM) . ; .. Velocity ..; (ft%sec)...... ECDs -20' TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑r Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 48" Interior stack width (inches): Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 3 I AyCOLOR A DO Dtm«s,��, Permit Number: 17WE 1066 AIRS ID Number: 123 I 9F64 I 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. 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: TBD Type: ECD MMBtu/hr Make/Model: I ES / ECD-48 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: TBD Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2,397 TBD Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 42 psig Describe the separation process between the well and the storage tanks: Separator, Produced Water Tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 4 Benzene Permit Number: 17WE1066 AIRS ID Number: 123 / 9F64 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Pollutant Uncontrolled Basis Units Criteria Pollutant Enitssions Inventory, t icontrdt Emission (�C711S/y�'Ctl'. ontrolled missions? onslyear) Requested Annual Permit ., Emission Linait(s)4. Uncontrolled Emissions ::.(Tons/year,k Controlled Emissions (Tonslyear),,: VOC 0.07881 lb/bbl Promax 76.58 3.83 78.31 3.92 NOx 0.068 Ib/MMBtu AP -42 0.14 0.15 CO 0.31 Ib/MMBtu AP -42 0.66 0.67 Non -Criteria Reportable`Potititant Emissions lnYentory hen cl Abstract- Service {CAS Number Emission facto Uncontrolled Basis Units Source: AP -42,::.; Mfg. etc) Actual Annual Emissions Uncontrolled Emissions (Pounds/year) Contrc Emissions . • (Pountslyear): 71432 0.0007923 lb/bbl Promax 1539.81 76.99 Toluene 108883 0.0005734 lb/bbl Promax 1114.38 55.72 Ethylbenzene 100414 Xylene 1330207 0.0003946 lb/bbl Promax 766.89 38.34 n -Hexane 110543 0.001982 lb/bbl Promax 3851.94 192.6 2,2,4- Trimethylpentane 540841 0.0001182 lb/bbl Promax 229.72 11.49 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 5I Permit Number: 17WE1066 AIRS ID Number: 123 / 9F64/ 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Sig 5/10/2018 ture of Le ally 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: E 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 $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 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 6 RAt3O n vuvv� Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE1067 AIRS ID Number: 123 / 9F64/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: LP Separator Venting - Mickey [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. Mickey-Varra Production Facility Site Location: SWNE Sec 5 T6N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado E -Mail Address'-: kcox@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kelli Cox Phone Number: (720) 557-8300 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 I A. Permit Number: 1 7W 1067 AIRS ID Number: 123 /9F64/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR • APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Ili Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: LP Separator Venting Emissions For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 05 / 10 / 2017 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year ❑✓ Yes ❑ No ❑ Yes ❑✓ No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 COLORADO HCnH'Rfr6' umf^xa3 Permit Number: 17WE1067 AIRS ID Number: 123 /9F64/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 100 000 SCF/hr Vent Gas Heating Value: ,� 971 BTU/SCF Requested: 3.12 MMSCF/year Actual: 2.93 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mote %) 41.3815 VOC (Weight %) 61.2241 Benzene (mole %) 0.0409 Benzene (Weight %) 0.0923 Toluene (mole %) 0.0191 Toluene (Weight %) 0.0508 Ethylbenzene (mole %) 0.0014 Ethylbenzene (Weight %) 0.0042 Xylene (mole %) 0.0053 Xylene (Weight %) 0.0164 n -Hexane (mole %) 0.2464 n -Hexane (Weight %) 0.6139 2,2,4-Trimethylpentane (mole %) 0.0001 2,2,4-Trimethylpentane (Weight %) 0.0003 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX £t n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX 8 n -Hexane, temperature, and pressure) COLORADO Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 31 Permit Number: 17WE1067 AIRS ID Number: 123 /9F64/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Q5000 eagraphical Coordinates titude/Lon e' or i1TM)' —30' 40.4313963 -104.92409 TBD TBD TBD Indicate the direction of the stack outlet: (check one) I] Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) I] Circular Interior stack diameter (inches): LI Other (describe): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed % ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD MMBtu/hr Thermal Oxidizer Make/Model: Questor/Q5000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: TBD 99 0/0 >99 % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 1,971 Btu/scf TBD MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 LORADO Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 41 PM PM Permit Number: 17WE 1067 AIRS ID Number: 123 / 9F64/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): nt Description Overall Requested Control Efficiency reduction in emissions) SOx NOx VOC Thermal Oxidizer 99 CO HAPs Thermal Oxidizer 99 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.) ntrolled ission` td Emission Factor Emission Factor Source (AP -42, Mfg. etc) lied Controlled6.: (Tons/year) lied'. 5ntrolled onsiyear) nc year sox NOx 0.066 lb/MMBtu Manuf. 0.19 0.20 VOC 55,822.17 Ib/MMscf Eng. Est. 81.64 0.82 87.08 0.87 CO 0.05 Ib/M M Btu Manuf. 0.14 0.15 Benzene 84.21 lb/MMscf Eng. Est. 0.12 0.001 0.13 0.001 Toluene Ethylbenzene Xylenes n -Hexane 559.68 lb/MMscf Eng. Est. 0.82 0.01 0.87 0.01 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I C�aLtT�d65 �Y> w u Permit Number: 1 7W 1067 AIRS ID Number: 123 /9F64/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 5/10/2018 Signature of Legly 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 El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd ORADO Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 6 Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE1068 AIRS ID Number: - 123 / 9F641 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: LP Separator Venting - Varra [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: Mickey-Varra Production Facility Site Location: SWNE Sec 5 T6N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado E Mail Address'-: kcox@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kelli Cox Phone Number: (720) 557-8300 '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. °RAO* Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 I Permit Number: 1 7WE 1068 AIRS ID Number: 123 /9F64/ 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source - OR - MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of 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: 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: LP Separator Venting Emissions For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 05 / 10 / 2017 O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year O Yes ❑ Yes ❑ No 2 No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 Permit Number: 17WE1068 AIRS ID Number: 123 /9F64/ 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information El Gas/Liquid Separator ❑ Welt Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: Yes ❑ No Maximum Vent Rate: 100 000 SCF/hr Vent Gas Heating Value: 2 226 BTU/SCF Requested: 154.7 MMSCF/year Actual: 124.31 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 50.7698 VOC (Weight %) 71.1416 Benzene (mole %) 0.1137 Benzene (Weight %) 0.2279 Toluene (mole %) 0.0641 Toluene (Weight %) 0.1517 Ethylbenzene (mole %) 0.0043 Ethylbenzene (Weight %) 0.0116 Xylene (mole %) 0.0165 Xylene (Weight %) 0.0450 n -Hexane (mole %) 0.6389 n -Hexane (Weight %) 1.4129 2,2,4-Trimethylpentane (mole %) 0 0003 2,2,4-Trimethylpentane (Weight %) 0.0009 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 Lik "Mg COLORADO Permit Number: 17WE1068 AIRS ID Number: 123 /9F64/ 005 [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) Q5000 ❑✓ Upward ❑ Horizontal hical Coordinates elktiiigf#ude or ()TM) 40.4313963 -104.92409 ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): TBD TBD ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑✓ VRU: Pollutants Controlled: Size: Requested Control Efficiency VRU Downtime or Bypassed Make/Model: % ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD MMBtu/hr Thermal Oxidizer Make/Model: Questor/Q5000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: TBD 99 >99 % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 2,226 Btu /scf TBD MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 41 PM PM Permit Number: 17WE 1068 AIRS ID Number: 123 / 9F64i 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): of Equipment Description' Overall Req Effi dtron m emissions) C introl SOX NO. VOC Thermal Oxidizer 99 CO HAPs Thermal Oxidizer 99 Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission, Factor Emission Factor Units Emission Factor Source Uncontrolled (Tans/year) Controlled (Tans/year) P-42,..: g. etc) Uncontrolled ' Controlled (Tans/year) (Tons/year)' SOX NO. 0.066 Ib/MMBtu Manuf. 9.13 11.36 VOC 73,072.81 lb/MMscf Eng. Est. 4,541.84 45.42 5652.0 56.52 CO 0.05 lb/MMBtu Manuf. 6.92 8.61 Benzene 234.11 lb/MMscf Eng. Est. 14.55 0.15 18.11 0.18 Toluene 155.65 lb/MMscf Eng. Est. 9.67 0.10 12.04 0.12 Ethylbenzene 12.03 Ib/MMscf Eng. Est. 0.75 0.01 0.93 0.01 Xylenes 46.17 lb/MMscf Eng. Est. 2.87 0.03 3.57 0.04 n -Hexane 1,451.21 lb/MMscf Eng. Est. 90.20 0.90 112.25 1.12 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. .......................... asats Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I Permit Number: 17WE1068 AIRS ID Number: 123 /9F64/ 005 [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. 5/10/2018 Signture of Le 'ally Authorized Person (not a vendor or consultant) Kelli Cox Name (please print) Date Air Quality Coordinator Title Check the appropriate box to request a copy of the: Q✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 6I Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE1069 AIRS ID Number: 123 /9F64/ 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: VRT Venting - Mickey [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Site Location: Extraction Oil & Gas, Inc. Mickey-Varra Production Facility Site Location SWNE Sec 5 T6N R67W County: Weld Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado E -Mail Address'-: kcox@extractionog.com NAICS or SIC Code: 211111 Permit Contact: Kelli Cox Phone Number: (720) 557-8300 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 I A DO 3e Permit Number: 1 7W 1069 AIRS ID Number: 123 / 9F64 / 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of 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: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: VRT Venting Emissions For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 05 / 10 / 2017 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year 0 Yes ❑ Yes ❑ No O No Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I Permit Number: 17WE1069 AIRS ID Number: 123 /9F64/ 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 7 637 SCF/hr Vent Gas Heating Value: 2 697 BTU/SCF Requested: 3.91 MMSCF/year Actual: 3.62 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 75.66 VOC (Weight %) 86.19 Benzene (mole %) 0.0858 Benzene (Weight %) 0.1385 Toluene (mole %) 0.0554 Toluene (Weight %) 0.1055 Ethylbenzene (mole %) 0.0069 Ethylbenzene (Weight %) 0.0151 Xylene (mole %) 0.0114 Xylene (Weight %) 0.02502 n -Hexane (mole %) 1.0825 n -Hexane (Weight %) 1.9282 2,2,4-Trimethylpentane (mole %) 0,0139 2,2,4-Trimethylpentane (Weight %) 0.032819 Additional Regt red Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 Co 10 31 nADO Permit Number: 17WE1069 AIRS ID Number: 123 /9F64/ 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information ►phical Coordil ngitudi or, u Indicate the direction of the stack outlet: (check one) -30' 40.4313963 -104.92409 TBD TBD TBD ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information El VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed % ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD MMBtu/hr Thermal Oxidizer Make/Model: Questor/Q5000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: TBD 99 % >99 % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 2,697 Btu /scf TBD MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 41 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 PM Permit Number: I7WE 1069 AIRS ID Number: 123 /9F64/ 006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): all Requested , iciency % reduction in emis SOX NO„ VOC Thermal Oxidizer 99 CO HAPs Thermal Oxidizer 99 Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Pollutant Emission Factor H_ � efarK: Units ..........................______. Emission ct; SourceFaor (A 42, 0.32 0.35 ontrolle ans/year.) Controll (1 onslyes PM SOX NOx 0.066 lb/MMBtu Manuf. VOC 109.88 lb/Mscf Promax 198.61 1.99 214.70 2.15 CO 0.05 Ib/M M Btu Manuf. 0.24 0.26 Benzene 0.1766 lb/Mscf Promax 0.32 0.003 0.35 0.003 Toluene 0.1345 lb/Mscf Promax 0.24 0.002 0.26 0.003 Ethylbenzene Xytenes n -Hexane 2.4582 lb/Mscf Promax 4.44 0.044 4.80 0.048 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. ............................ osAcao Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 mx.3.4 Permit Number: 1 7W 1069 AIRS ID Number: 123 /9F64/ 006 [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. 5/10/2018 Sighature of Legally Authorized Person (not a vendor or consultant) Kelli Cox Date 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) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Law r 3LoftADo 6I Lail =717,,=, Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE1070 AIRS ID Number: 123 / 9F64/ 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: VRT Venting - Varra [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: Mickey-Varra Production Facility Site Location: SWNE Sec 5 T6N R67W Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado E -Mail Address': kcox@extractionog.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kelli Cox Phone Number: (720) 557-8300 '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. CO ORADO Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 Permit Number: 1 7W 1070 AIRS ID Number: 123 /9F64/ 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ 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: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: VRT Venting Emissions For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 05 / 10 / 2017 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year • Yes ❑ Yes ❑ No El No ............. _............. a��lau Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 Permit Number: 17WE 1070 AIRS ID Number: 123 /9F64/ 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information 0 Gas/Liquid Separator ❑ Well Head Casing El Pneumatic Pump Make: Model: El Compressor Rod Packing Make: Model: El Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑✓ Yes ❑ No Maximum Vent Rate: 6 061 SCF/hr Vent Gas HeatinR Value: 2636 BTU/SCF Requested: 7.461 MMSCF/year Actual: 6.219 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 73.11 VOC (Weight %) 84.65 Benzene (mole %) 0.0683 Benzene (Weight %) 0.1126 Toluene (mole %) 0.0405 Toluene (Weight %) 0.0788 Ethylbenzene (mole %) 0.0074 Ethylbenzene (Weight %) 0.01658 Xylene (mole %) 0.0121 Xylene (Weight %) 0.0271 n -Hexane (mole %) 1.082 n -Hexane (Weight %) 1.9679 2,2,4-Trimethylpentane (mole %) 0.0095 2,2,4-Trimethylpentane (Weight %) 0.0229 Additional Required Information: El Attach a representative gas analysis (including BTEX Er n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 31 Permit Number: 17WE 1070 AIRS ID Number: 123 /9F64/ 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information eographical.Coordinates .''. otitudelLongae or UT)a 40.4313963 -104.92409 Q5000 -30' TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑✓ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed % ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: Thermal Oxidizer Make/Model: QueStOr/Q5000 Requested Control Efficiency: 99 % Manufacturer Guaranteed Control Efficiency Minimum Temperature: TBD >99 % Waste Gas Heat Content 2,636 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating TBD MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 41 Putisc nu PM Permit Number: 17WE1070 AIRS ID Number: 123 /9F64/ 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): PM geen n... :e in en sox NOx VOC Thermal Oxidizer 99 CO HAPs Thermal Oxidizer 99 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.) Uncontrolle+ Emission' Factor. Emission Factor Units emission s' Factor Source (AP -42, Mfg. etc) Uncontrolled (Tonstyenr) •Controlted6 (Tons/year) Uncontrolled (Tonslyear) Controlled, (Tonsfyegr) SOX NOx 0.066 lb/MMBtu Manuf. 0.54 0.65 VOC 105.68 lb/Mscf Promax 328.61 3.29 394.24 3.94 CO 0.05 lb/MMBtu Manuf. 0.41 0.49 Benzene 0.1406 lb/Mscf Promax 0.44 0.004 0.52 0.005 Toluene 0.0983 lb/Mscf Promax 0.31 0.003 0.37 0.004 Ethylbenzene Xylenes 0.0339 lb/Mscf Promax 0.11 0.001 0.13 0.001 n -Hexane 2.4571 lb/Mscf Promax 7.64 0.076 9.17 0.092 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I Permit Number: 17WE1070 AIRS ID Number: 123 /9F64/ 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. 5/10/2018 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: ❑✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd ..........._.._.._. Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 6 Pat*. Hello