The URL can be used to link to this page

Browse Search

Home My WebLink About20183385.tiff A cDPHE COLORADO co Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 6 , Greeley, CO 80632 4 r 09 October 11, 2018 Dear Sir or Madam: On October 18, 2018, the Air Pollution Control Division will begin a 30-day public notice period for Extraction Oil Et Gas, Inc. - RBF/Stromberger Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, P > Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure of �t 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe a John W. Hickenlooper, Governor 1 Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer „ , Pub( ic RA/ie,c.o cc PLCTP3, HLCYT), few C ER/CH/Um/Ck) 2018-3385 IC) rDcl O/ealig- 4K, CDPHE Air Pollution Control Division co Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - RBF/Stromberger Production Facility - Weld County Notice Period Begins: October 18, 2018 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Extraction Oil Et Gas, Inc. Facility: RBF/Stromberger Production Facility Exploration Et Production SENE Sec 22 T6N R67W Weld County The proposed project or activity is as follows: New well production facility. VRT and HLP separators are controlled by VRUs, and thermal oxidizers when VRUs are not available. Condensate and water tanks are controlled by enclosed flares. Tanks are connected directly to oil sales line, so no loadout emissions occur. 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 18WE0137, 18WE0138, 18WE0139, and 18WE0140 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Betsy Gillard Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us AVIV COLORADO 1 I LtiN z.r Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: BetsyGillard Package it: 374908 Received Date: 2/12/2018 Review Start Date: 8/2/2018 Section 01-Facility Information Company Name: Extraction Oil&Gas,Inc. Quadrant Section Township Range County AIRS ID: 129 SENE 22 6N '-.67 Plant AIRS ID: 9F9B Facility Name: RBF/StrornbergerProduction Facility Physical Address/Location: SENE quadrant of Section 22,Township 6N,Range 67W County: Weld County l Type of Facility: Exploration&Production Welt Pad What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? yes If yes,for what pollutant? El Carbon Monoxide(CO) ❑ Particulate Matter(III) €✓ Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point# Emissions Source Type Equipment Name Permit# Issuance# Action Control? Required? Remarks 001 Natural Gas RICE COMP-001 yes GP02 1 002 Natural Gas RICE •- COMP-002 yes - GP02 1 003 .;Natural Gas RICE COMP-003 yes GP02 1 ' Permit initial 004 Condensate Tank Condensate Tanks yes 18WE0137 1 yes Issuance Permit Initial 005 Produced Water Tank - Produced Water Tanks yes 18WE0138 1 yes Issuance Permit Initial 006 Separator Venting VRT Separator Venting yes 18WE0139 1 yet Issuance Permit Initial 007 Separator Venting LP Separator Venting yes 18WE0140 1 yes issuance Section 03-Description of Project New well production facility.VRT and HIP separators are controlled by VRUs,and thermal oxidizers when VRUs are not available.Condensate and wa ter tanks are controlled by enclosed flares.Tanks are connected directly to oil sales line,so no loadout emissions occur. ` Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? no If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? no Is this stationary source a synthetic minor? yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM1© TSP HAPs Prevention of Significant Deterioration(PSD) —— ❑ Title V Operating Permits(OP) J ✓ Non-Attainment New Source Review(NANSR) ✓ Is this stationary source a major source? no Condensate Storage Tank(s)Emissions Inventory 004 Condensate Tank 123 9F9B 004 Facility AIRs ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Eight(t)490-bbl condensate storage tanks connected via liquid manifold Description: .»„ , Emission Control Device Enclosed flares 33 dl 1. Description: lllill Requested Overall VOC&HAP Control Efficiency%: Ip05 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) _ Actual Condensate Throughput= 2,894,3241 Barrels(bbl)per year Actual Condensate Throughput While Emissions Controls Operating= 84"4i3ii Barrels(bbl)per year Requested Permit Limit Throughput= :;134730189:;Barrels(bbl)per year Requested Monthly Throughput= 294983 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput , 8,47318 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= p � 7507;Btu/scf Volume of waste gas emitted per BBL of liquidsJl f _ produced= 41iSgb 0BBd scf/bbl Actual heat content of waste gas routed to combustion device= 3,668 MMBTU per year Requested heat content of waste gas routed to combustion device= 4,402 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 4,402 MMBTU per year Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? rest° Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC "0,1232 6.16E-03 E.F urdgdes Benzene 2.10E-04 1.05E-05 £E;iadudeallasft , Toluene 1.80E-04 9.00E-06 �P jf0.Clnde5 r� e: Ethylbenzene '1.006435 5.00E-07 E.F;inuhtdes ftash;t Xylene 600E-OS 3.00E-06 .44 ¢,Hash n-Hexane 1.86E-03 9.30E-05 224 TMP 2.00E-05 1.00E-06 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (16/661) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 1 o.p000 / " PM 2.5 "- 0.0000 NOx 11,0690 8.62E-05 -42Cisof 1'Z"5''5lod1f5#1'f6`C CO 0,3I00 3.93E04 42,,°,,,,£14a"ptet``13.S 7'ilustfe('t esjCF3 „"f Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 213.9 178.3 8.9 213.9 10.7 - 1817 PM10 0.0 0.0 0.0 0.0 0.0 0 PM25 0.0 0.0 0.0 0.0 0.0 0 NOx 0.1 0.1 0.1 0.15 0.15 25 CO 0.7 0.6 0.6 0.7 0.7 116 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 729 608 30 734 37 Toluene 625 521 26 612 31 Ethylbenzene 35 29 1 42 2 Xylene 208 174 9 208 10 n-Hexane 6460 5383 269 6474 324 224TMP 69 58 3 77 4 • Section 06-Regulatory Summary Analysis • Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XII.C,D,E,F Storage tank is subject to Regulation 7,Section XII.C-F Regulation 7,Section XII.G,C Storage Tank is not subject to Regulation 7,Section XII:G Regulation 7,Section XVII.B,C.1,C.3 Storage tank is subject to Regulation 7,Section XVII,e,C.1&C.3 Regulation 7,Section XVII.C.2 Not enough information • Regulation 6,Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6,Part A,NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8,Part E,MACi Subpart HH Storage Tank is not subject to MACF HH (See regulatory applicability worksheet for detailed-analysis) 2 of 4 K:\PA\2018\18WE0137.CP1.xlsm Condensate Storage Tank(s)Emissions Inventory Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes,are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? 1111 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 s - 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. s. If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in P5 Memo 05-01. Does the company request a control device efficiency greater than 95%for a flare or combustion device? ost 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 Anatysts Notes "Frz5surizedllggid 9aj pl$44J(CCtCdil'p43t Cx,b`4MMbzTg 04e`csp4Ctfi #0 7,140 I,tc Stith preFsilr rick tai nmPp gfPr�5MaXs�.14i and ti#Faiittzsaimgla,Pt'nFl4 taboreaisutnol�e�a.6d661e pomtanalysrstavect. mpt ��grt� I€' 'I- 3r,,, �ry3 ' �I 1��i i � �� a 1 3 13 333 3h 3r a�� a � � 113'113 € 3��€. 1 131133 31 j!i:r € v111131 111,r,. h E itei11 .��-- "" z a,.; �1 11133 311 S c ,' 3 _a33 1 d1 111 mm p1;313 � 9111n � c �.M_ r� Section 09-Inventor/SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point N Process 0 SCC Code _ Pollutant Factor Control% Units 004 Dl .0.kr `oofT EA`, Ytd_�` r ` PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.00 0 lb/1,000 gallons condensate throughput VOC 2.9 95 lb/1,000 gallons condensate throughput CO 0.01 0 lb/1,000 gallons condensate throughput Benzene 0.01 95 lb/1,000 gallons condensate throughput Toluene 0.00 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 0.04 95 16/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 4 K:\PA\2018\18WE0137.CP1.xlsm • Condensate Tank Regulatory Analysis Worksheet • Colorado Regulation 3 Parts A and 8-OPEN and Permit Requirements 'Source Is In the Non-Attainment Area NON-ATTAINMENT 1. Areuncontroled embsions from any criteria pollutants from Lh,Individual sonrcegreaterthan l TPY(Regulation 3,Part A,Section ll.D.1a)? "SSM.NSSM Source Req 2. Is the construction date(service date)priorto 12/302002 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)? Go to next• 3. Are total facility uncontrolled VOC emissionsgreaterihen 2TPY,NOx greatenthan 5 TPY or CO emissions greaterthan 10 TPY(Regulation 3,Part B,Section lin.2)? 50 ,.:i Source Req 'Source requires a permit Colorado Regulation 7,Section XII.C-F 1. Is thiisetoregetank loaned in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue-' 2, Is this storage tank loafed at an oil and gas exploration and production operations,natural gas compressor station ornaturatgas drip station? Yes - Continue-' 3. Is this storage tank located upstream of a natural gas processing plant? Yee..:.... Source isa 'storage tank Is subject to Regulation 7,Section 011,0-F Section X31.03—General Requirements for Air POiM1on Control Equipment—Prevention of Leakage Section 101.02-Emission Estimation Procedures Section AIM—Emissions Control Requirements Section%II.E—Monitoring Section LOIS—Recordkeeping and Reporting Colorado Regulation 7,Section 011.0 - 1. Isthisstotaga tank located in the 8-hr ozone controlara or any ozone non-attainment area or attainment/maintenance area? Yes Continue-' 2. Is this storageta nk located at a natural gasproc.sixg plant? No St0ageTat 3. Dog this storage tank eshibk (e.g storing non-stabilized liquids)emissions and have uncontrolled actual emissions greater than or equal to 2 tons peryear 0002 SARA 'Storage Tank Is not subjectto Regulation 7,Section 011.0 Section XIl.G1-Emissions Control Requirements Section XII.C3—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section Xll.C1—Emission Estimation Procedure Colorado Regulation 7,Section XVII 3. K this tank looted at a transmeion/stoagehtllhy7 - No Continue-' 2. Is this condensate storage tanks locatedat an ail and gas exploration and production operation,web production facility',natural gas compressoroetIon.or natural gas processing plant? Yes Go to then 3. Is this condensate storage tank a fixed roof storage tank? Xes�'r4.1/Go to then 4. Are uncontrolled actual em'swns'ofthls storage tank equal to orgraterthan6tonsPer year VOC2 yes3 .0Sourceisa Storage tank is subject to Regulation 7.Section XVII,8,0.1&C3 Section XVII.e—General Provisions for Alr Pollution Control Equipment and Prevention of Emissions Section XVII.C.1-Emissions Control and Monitoring Provisions Section X31103-Recordkeeping Requirements 5. Does the condensate storage tank contain only°stabilized"liquids? ...Sti 'Not enough Information Section XVIl.C2-Capture and MonitoringforStoage Tanks tinted with Air POlMien Control Equipment 40 CFR.Pmt 60.Subpart Kb.Standards of Performance for Volatile Organic Gould Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cube meters(ma)(-472 BBIa1? Storage Tat 'Storage Tank Is not collect to NIPS Ill 40 CFR,Part 60,Subpart 0000,Standards of Performance for Crude OR and Natural Gas Production,Transmission and DiOrlbutlon 1. Is this condensate storage vessel looted 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? Yes Continue-' 2. Was this condenate storage vessel constructed,recogtmcted,or modified(sa definitions 40 CFR,6o1)between August 23,2013 and September 18,2015? ... Stooge Tar 'Storage Tank is not subject to NSPS 0000 40 CFR,Part 63,Subpart MAR HH,Oil and Gas Producton Facilities 1. K the storage tank located at an on and natural gas production facility that meets either of the following criteria: 'Yes 'Continue-' a.Afacliity that processes,upgrades or stores hydrocarbon liquids`(63.760(a)(2)1;OR b.A facility that processes,upgrade or eons natural gas prior to the point at which natural gas enters the natural gas transmission and enrage source category ors delivered to a final end user'(63.760(a)(3))? ff:: 2. K the tank located at a facilty that s majors for HAps? fxre., Storage Tai 'Storage Tank is not subjecttm MAC'HH RACE 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 mitede,then review PACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing tagulatious,and Air Quality Control Commission regulations.This document is rote rule or regulation,and the analysis d 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 bicdug requirement and a not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its lmp'emenbig regulations,and Air Qualify Control Commission regulations,Etna language of the statute or regulation will control.The use of nommandatory language such as"mcommend"may,"should'and tan,'is intended to describe APCD interpretations end recommendations.Mandatory terminology such as'muse and'required'are intended to describe controlling requirements under the tents of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. C H �y a lit sr PO n Ct Vii: 1 Di ,stmt " 'mart erlt c Ibl c r alth&E-wt. rment ,>" CONSTRUCTION PERMIT Permit number: 17WE0137 Issuance: 1 Date issued: Issued to: Extraction Oil &t Gas, Inc. Facility Name: RBF/Stromberger Production Facility Plant AIRS ID: 123/9F9B Physical Location: SENE SEC 22 T6N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Condensate 004 Eight (8) 400-barrel fixed-roof storage vessels Enclosed Flare Tanks used to store condensate This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air 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.) Divv COLORADO Air Pollution Control Division Page 1 of 8 3. his m sh4 expir l the :ior'Ir of the source for which this permit was issued: (i) do n men `.stru modi ation or operation of this source within 18 months after ith' , e da.e o q,issu c of th construction permit or the date on which such cons cti o actiity sc duled t commence as set forth in the permit application date .'t • ler 'sconti construction for a period of eighteen months or more; (iii)does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type Condensate 004 -- -- 10.7 -- Point Tanks Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Control Device Equipment ID Point Controlled Condensate 004 Enclosed Flare VOC and HAP Tanks CDP}3S COLORADO HJ/ C, v, Air Pollution Control Division ;: = Page 2 of 8 PROC LIMIATf NS ND RI DS 8. his sd rc s l be li to the fgllowin g maximum processing rates as listed below. Monthly recor of he"., tua_` pro sinOates shat be maintained by the owner or operator and made & va9 le t;- th ivi on fo inspection upo request. (Regulation Number 3, Part B, II.A.4.) ?y Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Condensate 004 Condensate throughput 3,473,189 barrels Tanks The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that 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 eDM COLORADO CO Air Pollution Control Division Page 3 of 8 1, 2014. e s's rce stfatt h inspection requirements of Regulation Number 7, Section XVII.C .d maint corder" he ins ctions for a period of two years, made available to he Di si u^ req est: his ntrol req rement must be met within 90 days of the date that the s ""ragt'ta cons nenc% op ""ation 14. e stor fan ' ereV h°S perms 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 (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen-minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) 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 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 oelf5 COLORADO CO Air Pollution Control Division Page 4 of 8 a • N at ' than ys beArm he e4ting APEN expires. GENE' L TERMS 0NDITO 19. his ,- rmg ant an/attar mertrs'must bed retained and made available for inspection upon If pet�ay i i ' to a Downer by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard, PE Permit Engineer nrk¢ COLORADO CAir Pollntinn Control D3vxsaon O �_,. .,. . Page 5 of 8 a' :...Perm i Hi��. ,s t ` Da 4 Description ssu c- s Issance sued to Extraction Oil Et Gas, Inc. r0PH COLORADO co 1 Air Pollution Control Division E_ . Page 6 of 8 v N Notes t,, Per H der -t the nhe of th p"rmit i uance: 1) Th%permi?ho e i' requ 9 pay _, e for thprocessing time for this permit. An invoice for these fee will is ed ;.,_fter the prmit �'issued. e permit holder shall pay the invoice within 30 days of ecei of the _ voile Fall re o pay th invoice will result in revocation of this permit. (f�etaon e *if A;' •6ctTorfVl B ) r- : 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. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (Ib/yr) (lb/yr) Benzene 71432 734 37 Toluene 108883 612 31 Ethylbenzene 100414 42 2 004 Xylenes 1330207 208 10 n-Hexane 110543 6474 324 2,2,4- 540841 77 4 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 0.123 6.16E-03 71432 Benzene 2.10E-04 1.05E-05 Promax simulation based on site- 108883 Toluene 1.80E-04 9.00E-06 110543 n-Hexane 1.86E-03 9.30E-05 specific sample Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point DPHE COLORADO co Air Pollution Control Division Page 7 of 8 rp * rrrasciatec ",ermi r any: uetions . garding a specific expiration date call the Division at03) 63C 7) Th "permf fu Ill,- pe requir ent s) hold a v id permit reflecting the storage tank and associated co rol d"evic ; pet\the' Colodo ril and G"' Conservation Commission rule 805b(2)(A) when a r -.age. ay . zaim viiin 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, benzene, n-hexane, total HAPs NANSR Synthetic Minor Source of: VOC MACT HH 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 nr £ COLORADO CO Air Pollution Control Division Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: RetsyGillard,- Package#: 374508.1'' - Received Date: 2/1212018 ' Review Start Date: B 2 6 Section 01-Facility Information Company Name: Extractions Oil:&Gas;Iron, Quadrant Section Township Range County AIRS ID: 123 ,. ii;„" ; 22 Plant AIRS ID: SF56 ' Facility Name: RBF/StrombergerProductionFacility - 13 )3Y"3313 Physical Address/Location: SENE quadrant of Section 22,Township 6N,Range 67W County: Weld County Type of Facility: Exploration&Produktj (Well What industry segment?Oi£&Natlrral'Gas Production&Processing 1. Is this facility located in a NAAQS non-attainment area? -yes If yes,for what pollutant? O Carbon Monoxide(CO) ❑ Particulate Matter(PM) E Ozone(NOx E VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRS Point 6 Emissions Source Type Equipment Name Permit# Issuance 6 Action Control? Required? Remarks -.., ,X01 :. Natuca>?fa RICE �-" COMP D0�„,:--��; �" yes:: �:.;.:GP02 __ ' ._. �. 002 ¢ •Natural Gas RICE €QMP 002 .. yes GP02 1 O03" Natural Gas lCE-...,::. COMB 003 yes GP02 • ,.S:.,, - r- Perm t Inittal - 004 andensateTank Condensate Tanks;_: :yea 18WE0137 1 •; tyres tea... Perm it.£nit£al • >Produced WaierTante _ �. c ,.,.-Produced Water Tanks` yes 18WE0138 :;1 , �";yes ;`E:-'_Lssuanee ,:. P te ,. � 006" 4, ..S, paYatotVen m,ting, .; VRTSeparatorVenting tye ,k;Etir,,,,,{ t:18WE0139. W Pernirt[mfta �� €a . Separator Venting ; LP Separator Venting� yes? 18WED140 �� .1 ayes,3�3,;::;,-£ssuartce ' Section 03-Description of Project New well producfi©e fadtity,VRT and HLP separators are controlled by-VRUs,and thermal oxidizers when VRUS are not available Condensate"and wa ter tanks are controlled by enclosed flares.Tanks are connected directly to oil sales line so no loadout emissions occur • Section 04-Public Comment Requirements Is Public Comment Required? :yes If yes,why? Re assT n Y q gSYn#heYicMinor�peTEnrt • Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? na If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? no, Is this stationary source a synthetic minor? e r If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) _ ✓ El El Non-Attainment New Source Review(NANSR) ✓ Is this stationary source a major source? Produced Water Storage Tank(s)Emissions Inventory 005 Produced Water Tank 123 4F9B 005 Facility AIRs ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Two{2)400-bbl fixed root produced,late;storage tanks connected via liquid manifold. Description: Emission Control Device Enclosed;I.:, Description: Requested Overall VOC&HAP Control Efficiency%: Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Produced Water Throughput= k 948`,18 Barrels(bbl)per year Actual Produced Water Throughput While Emissions Controls Operating= K4$l)Rtf Requested Permit Umit Throughput= 1,138,8O(j(Barrels(bbl)per year Requested Monthly Throughput= 96720 Barrels(bbl)per month Potential to Emit(PTE)Produced Water 4 Throughput= ,,.:,.4.;-,4**4 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= A496t Btu/scf Volume of waste gas emitted per BBL of liquids € S produced= 3 scf/bbl Actual heat content of waste gas routed to combustion device= 51,109 MMBTU per year Requested heat content of waste gas routed to combustion device= 61,331 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 61,331 MMBTU per year Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Uncontrolled Controlled (Ib/bbl) (lb/bbl) Emission Factor Source Pollutant (Produced (Produced Water Water Throughput) Throughput) VOC 0.262.. 0.013100 F#EduY V � h'" Benzene 0.007 0.000350 RrWdfl, 5t Toluene 0000000 r7 Ethylbenzene _ 0..000000 Xylene 0.000000 f � n-Hexane 0.022 0.001100 224 TMP 0.000000 '..,, pry s .�i ._..- �._ . Control Device Uncontrolled Uncontrolled Pollutant (lb/MMetu) )lh/bbl) Emission Factor Source (Produced (waste heat Water combusted) Throughput) PM10 0.0000 PM2.5 0.0000 NOx -0.0680 0.0037 ie'alithap CO ,."f.31U0 0.0167 �Sapterri5.S fu f , Section 05-Emissions Inventory - - Potential to Emit Actual Emissions Requested Permit Umits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tans/year) (tans/year) (tons/year) (lbs/month) VOC 149.2 114.3 6,2 149.2 7.5 1267 PM10 0,0 0.0 0.0 0.0 0.0 0 PM2.5 0.0 0.0 0.0 0.0 0.0 0 NOx 2.1 1.7 1.7 2.1 2.1 354 CO 9.5 7.9 7.9 9.5 9.5 1615 Potential to Emit Actual Emissions Requested Permit Umits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled- Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 7972 6643 332 7972 399 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n-Hexane 25054 20878 1044 25054 1253 224TMP - 0 0 0 0 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVII.B,C.1,C.3 Storage tank is subject to Regulation 7,Section XVII,B,C.1&C.3 Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation 7,Section XVII.C.2 Regulation 6,Part A,NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 2 of 4 K:\PA\2018\18WE0138.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? r. s If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor.See PS Memo 14-03,Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 Technical Analysis Notes (s d�iaz emssslonfac ors GOR a ndvapoTheatcontehtfrom Stdem G 4" _ m5 Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point 9 - Process# SCC Code Pollutant Factor Control% Units 005 01. 4-04-003-15 Fixed Roof Tank,Produced Water,working+breathing+flashing losses PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 16/1,000 gallons liquid throughput Toluene 0.00 95 16/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 Ib/1,000 gallons liquid throughput n-Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 IMP 0.00 95 lb/1,000 gallons liquid throughput 3 of 4 K:\PA\2018\18WE0138.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 aeviewing ere at one of these facilities,please review NSPS Kb. Colorado Regulation 3 Parts A and a-APEN and Permit Requirements 'Source is in the Non-Attainment Ares NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPf(Regulation 3,Part A,Sectionll.D.1.a)? yes,-- ---Source Req 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 0,Section ll.D.1.M) ;IIA3;y,�'"; •Go to next .. 3. Are total facility uncontrolled VOC emissions greater than 2TPy,NOx greater than 5 Try or CO emissions greater than 10 TPY(Regulation 3,Part 0,Section Il.D.2)? 'iy.a i, Source Req 'Source requires a permit Colorado Regulation 7,Section tout - 1. Isthis tank located at a transmission/storage facility? No Continue 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? Yes Continue-' 3. Is this produced water storage tank a fixed roof storage tank? yon'fi y,A Go to the n 4. Are uncontrolled actual emssions°of this storage tank equal to or greater than 6 tons per year VOC? Sc? , Source is st (storage tank is subject to Regulation 7,Section XVII,Er,C.1&C.3 Section XVII.e—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"stabilised"liquids?If no,the following additional provisions apply. k[Ad : 4Source is st 'Storage tank is subject to Regulation 7,Section XVII.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 bested 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? One 'Continue ' 2. Was this produced water storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 1g,2015 ne "Storage Tar 'Storage Tank is not subject to NSPS 0000 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 Arc 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. Pii)1K Ckl)joY ' iif% tijdontrIl A } Division rtmtic 1-fea -nvironment CONSTRUCTION PERMIT Permit number: 18WE0138 Issuance: 1 Date issued: Issued to: Extraction Oil &t Gas, Inc. Facility Name: RBF/Stromberger Production Facility Plant AIRS ID: 123/9F9B Physical Location: SENE SEC 22 T6N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Produced 005 Two (2) 400-barrel fixed-roof storage vessels Enclosed Flare Water Tanks used to store produced water 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.) car E COLORADO co Air Pollution Control Division Page 1 of 7 ]ThisPhIll • 3. exp•M1 the or o.-rator of the source for which this permit was issued: (i) dogS n c ,merte c stru ion/mod ication or operation of this source within 18 months t e • e of construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type Produced Water 005 -- 2.1 7.5 9.5 Point Tanks Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled Produced 005 Enclosed Flare VOC and HAP Water Tanks "PE. COLORADO CO Air Pollution Control Diva on Page 2 of 7 PROC LIMI AND - , DS `: r 8. his urc shi be, mit : to e follow * maximum processing rates as listed below. Monthly ords O` e pr i tes sfigt be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Produced 005 Produced Water 1,138,800 barrels Water Tanks throughput The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING a 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 DP E COLORADO 0., Air Pollution Control Division rz_ ",,. ,.,ant Page 3 of 7 demos`tr' mpli n an≥ ing b ;is with the requirements of this permit. Revisions to the • M n e s jec o D> sion app✓ival prior to implementation. (Regulation Number 3, ) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference 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, 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. GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the cnree COLORADO CO, Air Pollution Control Division Page 4 of 7 permit m sec om PCD writing in accordance with the provisions of 25-7- 114. 2). ) .5. rid " CC gulation umber 3, Part B, Section III.G. Final authorization n ,k it t ' p 1Xion orittivity 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. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. DP COLORADO co Air Pollution Control Division Page 5 of 7 ‘: '''r,k Notes Per !at th oft ermit suance: 1) Th per ho ?er ` re ired pa ees fort processing time for this permit. An invoice for these f be =d - e r issued. - permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS# Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 7972 399 005 n-Hexane 110543 25,054 1253 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl N0x 0.0037 0.0037 CDPHE PS Memo CO 0.0167 0.0167 14-03 V0C 0.262 0.0131 71432 Benzene 0.007 3.50E-04 State default 110543 n-Hexane 0.022 1.10E-03 emission factors Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. CDPHE COLORADO Air Pollution Control Division Page 6 of 7 J 8) Th facili is ified ows a b I L 'iitTatimS "us' `tr tilt Requirement Operating Permit Synthetic Minor Source of: VOC, benzene, n-hexane, total HAPs NANSR Synthetic Minor Source of: VOC MACT HH 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 * DA COLORADO COLORADO CO , Air Pollution Control Division .. - Page 7 of 7 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: BetsyGlllard. Package#: 374908_ Received Date: 2/12/2018 Review Start Date: ::8/2/2018 iii"- Section 01-Facility Information Company Name: Extraction Oil&Gas,Inc ;'' Quadrant Section Township Range County AIRS ID: 123 SENE 22 6N- -- :-. -67 _. Plant AIRS ID: 9F9B. Facility Name: RBF/StrombergerProduction facility Physical Address/Location: SENE quadrant of Section 22,Township 6N,Range 67W County: Weld County Type of Facility: &tploretios°&Production WelEPad '.� What industry segment?'03l`&Neturel Gas Prcduttion&Psocessmg Is this facility located in a NAAQS non-attainment area?If yes,for what pollutant? Carbon Monoxide(CO) ❑ Particulate Matter(PM) E Ozone(Nox a voc) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point# Emissions Source Type Equipment Name Permit# Issuance# Action Control? Required? Remarks 063- , `Natural Gas=RICE COMP-001_ , GP02 441.4.4 002 Natural Gas_RICE COMP-002i', GP02 €, yes-_ 003 I COMP-003":"" yes GP02 1 ,c r Perm#Initial." - --004 C andebtate"Tank , Condensate Tanks I 18WE0137 1 - _yes Issuance permit In ai� 1 -005 ProducedWaterTank Produced Water Tan ks .yes- 18WE0138 1 r, Perm t Enitiel 006 Separator Ventiftg :VRT Separator Venting yes 18WE0139 • 1 • yes Issuance Perm t Init ahf-" 007- Se'aratorVentin LP Separator es 18WE0140 1 Vie, of"" p g pa g y �.�>��Yes,-� Lsauanee�-- • Section 03-Description of Project New welt production tacihty"VRT and HLP;separators are controlled by VRUs,and therma]gxrditers when VRUs are not available.Corsddensate ands wa ter tanks are controlled by enclosed flares.Tanksare connected directly to oil sales line,so no loadout emissions occur.. Section 04-Public Comment Requirements Is Public Comment Required? yes If yes,why? R�queshn nthet�c tuilrfor Peiinrt'- - � '� Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? :no.", If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? ilo Is this stationary source a synthetic minor? yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) _ _ Title V Operating Permits(OP) ✓ - El Non-Attainment New Source Review(NANSR) ✓- Is this stationary source a major source? no , Separator Venting Emissions Inventory 006 Separator Venting Facility Allis ID: w..-, 9146' III County Plant Point Section 02-Equipment Description Details (1)Vapor lecoeery Tow3er(VBT) Detailed Emissions Unit Description: - j 3 , 33 - _ Thermal m.i,, r during VEU Uypasscoediti ns 3 Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency%: Limited Process Parameter Gas meter ',O1111Tt y-4sty7,-(�ifVp,�q Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= _"-%, 10) 'MMscf per year Requested Permit Limit Throughput 3, PI24f MMscf per year Requested Monthly Throughput= 1 MMscf per month Potential to Emit(PTE)Throughput= 12.40 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: 5 2499'_Btu/scf Section 04-Emissions Factors&Methodologies Description MW and composition of gas Scorn site sp0ci5ic.VIII gas sample,ccltected.719/24,18 at 6.9 pstl,and 56 deg P. MW 44.2380 Ib/Ib-mol Displacement Equation Ex=Q'MW*Xx/C Weight Helium 0.0000 CO2 1.1305 92 0.1056 methane 5.4034 ethane 13.3067 propane 31..5266 isobutane 6.5158 n-butane 20 3615 isopentane : 5.3643. n-pentane 6.7555 cyclopentane 0.5451'. n-Hexane 1.9136 cydohexane 0.5372 Other hexanes 3.12831 heptanes 1.4646 methylcyclohexane 0.5032 224-TMP 0 0011 Benzene i! 0.24771 Toluene 0.2109: Ethylbenzene 0 0155 Xylenes 0.0590 C8+Heavies I':-L0.9347 Total 99.97 VOC Wt% 80.02 Emission Factors Separator Venting Operator Calculations Uncontrolled Controlled Uncontrolled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (lb/Mscf) %diffemce from (Gas Throughput) (Gas Throughput) (Gas Throughput) engineer talcs VOC 93406.1992 1868.1240 v 94.09 0.73% Benzene 289.1280 ' 5.7826 0.289 -0.04% �� - Toluene 246.1732 4.9235 0.246 -0.07% Ethylbenzene 18.0924 0.3618 r � ErtartdedgaS� 0.018 -0.51% Xylene 68.8678 1.3774 ;2 Exterrdostgas aita 0.069 0.19% n-Hexane 2233.6509 44.6730 '' Extamfedgaooel✓ 2.231 -0.12% 224 TMP 1.2840 0.0257 ; I EXteada>,€gas , 0.001232 4.05% Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.000 PM2.5 0.000 sox 0.000 NOx 0.0680 169.932 �uatrraf Flares(;NL1x' CO • 2 of 4 K:\PA\2018\18WE0139.CP1.xlsm Separator Venting Emissions Inventory Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 0.00 0.00 0.00 0.00 0.00 0 PM2.S 0.00 0.00 0.00 0.00 0.00 0 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 1.05 0.85 0.85 1.05 1.05 179 VOC 579.12 467.50 9.35 583.18 11.66 1981 CO 4.80 3.88 3.88 4.80 4.80 816 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 3585 2894 58 3579 72 Toluene 3053 2464- 49 3048 61 Ethylbenzene 224 181 4 223 4 Xylene 854 689 14 853 17 n-Hexane 27697 22359 447 27652 553 224TMP 16 13 0 15 0 Section 06-Reeuletory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XVII.B,G Source is subject to Regulation 7,Section XVII.B.2,G Regulation 7,Section XVII.B.2.e The control device for this separator is not subjectto Regulation 7,Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? 4.. Will the operator have a meter installed and operational upon startup of this point? Yes 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 ,"',,.s -7:19;m 331m„q1"9I '. .m ss ors based on*IRT gas analysis collected from RBI Stromberger 1/19/2018.The analysis is site specific and collected w th n one year of appticatfon submitt.1,therefore thereare no amr ai sampling requirements Separator is.ontrolled by thermal oxIdi,erdufing nin bypass,with 98%requested destruction et=;ciency.Permit smll include nRialeesnng requirements to demonstrate destruction effcenry Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 006 01 3-10-001-60 Flares PM10 0.00 0 Ib/MMSCF PM2.5 0.00 0 Ib/MMSCF 500 0.00 0 Ib/MMSCF NOx 169.93 0 Ib/MMSCF VOC 93406.20 98 lb/MMSCF CO 774.69 0 lb/MMSCF Benzene 289.13 98 lb/MMSCF Toluene 246.17 98 lb/MMSCF - Ethylbenzene 18.09 98 lb/MMSCF Xylene 68.87 98 Ib/MMSCF n-Hexane 2233.65 98 lb/MMSCF 224 TMP 1.28 98 lb/MMSCF 3 of 4 K:\PA\2018\18WE0139.CP1.xlsm Separator Venting Regulatory Analysis Worksheet • Colorado Regulation 3 Parts Aand B APEN and Permit Requirements (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 ll.D.1.a)7 Yres Source Req 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part 8,Section 1.02)? 9'i¢i,"1i1)1G Source Req (Source requires a permit Colorado Regulation 7,Section XVII 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 2014? yes- -(Source ism • '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 Sectiont a. Is this separator controlled by a back-up or alternate combustion device(I.e.,not the primary control device)that is not enclosed? IWYAWEIVIThe control 'The control device for this separator is not subtectto 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 MI 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 teens of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself CDPHEk A V c, Air d I1 COYftrC3 X 12 , or Depa ent of 1� Dealt' EnU11onT t ..� r.A223212-I.1 r.r.711:2 CONSTRUCTION PERMIT Permit number: 18WE0139 Issuance: 1 Date issued: Issued to: Extraction Oil &t Gas, Inc. Facility Name: RBF/Stromberger Production Facility Plant AIRS ID: 123/9F9B Physical Location: SENE SEC 22 T6N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID VRT Emissions from Vapor Recovery Tower (VRT) Separator 006 during VRU bypass conditions Thermal oxidizer Venting 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 OP NE COLORADO CO Air Pollution Control Division Page 1 of 7 gfr Lfication y b t ' online aorado.go 4if /cdphe/air rmit self . •$ggula - r 3, Part B .G.2.) s# 3. s permit #I1 expire f the er or o rator oft -,source iwhich this permstt,Jas issued: ^ibr comme> - tru ation oratiptieraticffilildhis source w' 3' &months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type VRT Separator 006 -- 1.1 11.7 4.8 Point Venting 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 AIRS Control Device Pollutants Equipment ID Point Controlled VRT Separator Emissions from the VRT are routed to a thermal Venting 006 oxidizer during Vapor Recovery Unit (VRU) VOC and HAP bypass 4, OP E COLORADO CO G Air Pollution Control Divislan �:� Page 2 of 7 S da" No At 7 PROCESY IMITATION ND R ` R I 8. Ms source s be hrnTted t e followin i'naaim `jorrLru; - processi. atessts listed be` . Monthly ords oft ctual pi'acessi 4,,ates shag be main ed by J owner or operat nd made • he Di viskiriitarg n s pidioattlitmrequest t rnber 3, Par .) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point VRT Separator 006 Natural gas routed to 12,4 MMscf Venting thermal oxidizer Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. 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 & 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 P COLORADO O Air Pollution Control Division t _: -;:� ...,�,•.E Page 3 of 7 4 VI atM plane sub a `ion approval pr = to implem (Regulatio, umber 3, t B, Sectio -G.7 � . . COMPLIMICE TESTI ND S.b LINGa �a, m ni is esting Requiremen s 15. 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 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The 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. (Regulation Number 3, Part B., Section III.G.3) 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 30t'' 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. GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. cae E COLORADO CO Air Pollution Control Division Page 4 of 7 1 19 f`his permit cific s . .S teat final aL Jfor `" ion has b led, then th emainder this conditij is notYapp jle. Otherwi t , lance of t cotruction per': does not vide "fina thori; 'for t ctivity .t operatio f this s. fie. Final authori on of the permit e secur € from APCD iii writing i ccordar, with the provisi of 25-7- (a) C.R.S. r $ C CC Re uta�i " umber , ;germ n III.G. Fin t drization 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. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. ccPHE COLORADO co v Air Pollution Control Division Page 5 of 7 Notes t Q "" rmit Hold ,t the e olys4s permit iss ncF 9 IttiN 1) The rmit holde g „requi to ,,,,fees for th voce time for; is pettnit. An invo for these fees;';,ll be issuq ,after t ermi Olssued. , e permit, lder sh ay the invoice w n 30 days ofritiMle invoi , ure ' _the invoi eshisyarevocation efsi4- 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 AIRS Uncontrolled Controlled Equipment ID Point Pollutant CAS # Emissions Emissions (Ib/yr) (Ib/yr) Benzene 71432 3579 72 Toluene 108883 3048 61 Ethylbenzene 100414 223 4 VRT Separator Venting 006 Xylenes 1330207 853 17 n-Hexane 110543 27,652 553 2,2,4- 540841 15 0 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 006: Uncontrolled Controlled CAS# Pollutant Emission Factors Emission Factors Source (lb/MMSCF) (lb/MMSCF) N0x 169.93 169.93 AP-42 Chapter 13.5 CO 774.69 774.69 Industrial Flares V0C 94,090 1881.8 71432 Benzene 289.00 5.78 108883 Toluene 246.00 4.92 Site specific 1330207 Xylene 69.00 1.38 extended gas analysis 110543 n-Hexane 2231.0 44.62 Note: The controlled emissions factors for this point are based on the thermal oxidizer control efficiency of 98%. cop aE COLORADO 40, CO Air Pollution Control Division s. -a:.,._ t .,�•.� Page 6 of 7 44 444 444377 1 6) Ina rdance wit R S 7 , each Air P ut Emission e EN) associ W,., with this ¢rmit is vatic`" it a t d"Fk�, years fro 't was rec ed the Divisio revised APES hall be su.,F0 ted n'- ter 30 days efore th 've-year ;m expires. Pleas fer to the Ost re .'""nual fe voice eter . e the APE " irati ate for each emi ns point a • i. -• with this permrti any i s garding a 5 'ifie ex4iV tion date cam 1" Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, benzene, n-hexane, total HAPs NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX tit, COLORADO 0 Air Pollution Control Diviszon Page 7 of 7 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Betsy Glliard Package 3: 374908 Received Date: 2/12/2018 Review Start Date: 8/2/2018 Section 01-Facility Information Company Name: Extraction Oil&Gas,Inc. Quadrant Section Township Range County AIRS ID: 123 SENE 22 6Ff -.:67 _. Plant AIRS ID: 9F96 Facility Name: R8F/Stromberger Production Facility Physical Address/Location: SENE quadrant of Section 22,Township 6N,Range 67W County: Weld County Type of Facility: Exploration&Production Welt-Pad What industry segment?Oil&Natural Gas Pmcluction&Prn,-.sling Is this facility located in a NAAQS non-attainment area? yes If yes,for what pollutant? Carbon Monmode(CO) ❑ Particulate Matter(PM) El Ozone(500&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point If Emissions Source Type Equipment Name Permit# Issuance# Action Control? Required? Remarks 001 Natural Gas RICE k=r COMP-001 yes GP02 1 002 Natural Gas RICE = COMP-002 yes GP02 1 003 r Natural Gas RICE COMP-003 yes GP02 1 - Permit€nitial.: 004 CondensateTank, Condensate Tanks yes 18WE0137. 1 -yes ' 'ii Issuance. Permit Initial 005 Produced'WaterTank Produced Water Tanks yes 18WE013& 1 yes - Issuance Permit Initial=_ 006 Separator Venting .€;. "VRT Separator Venting yes 18WE0139 1 yes Issuance Permit Initial 007 Separator Venting - LP Separator Venting yes 18WE0140 1 yes = Issuance , Section 03-Description of Project New well production facility.VRT and HIP separators are controlled by VRUs,and thermal oxidizers when VRUs are not available.Condensate and wa ter tanks are controlled by enclosed flares.Tanks are connected directly to oil sales line,so no loadout emissions occur, Section 04-Public Comment Requirements Is Public Comment Required? yes, If yes,why? 'Requesting Synthetic DAlnorPermit Section 05-Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? no If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? Io.' Is this stationary source a synthetic minor? yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM70 TSP HAPs Prevention of Significant Deterioration(PSD) C El Title V Operating Permits(OP) C_ J El Non-Attainment New Source Review(NANSR) ✓ Is this stationary source a major source? no Separator Venting Emissions Inventory 007 Separator Venting 123: 9F9B 007 s Facility AIRs ID: - - • ••'�` County Plant Paint Section 02-Equipment Description Details LP gas from 1.9 HIP separators Detailed Emissions Unit Description: Thermal oxidizer during VRU byp ass conditions Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency%: 93 Limited Process Parameter Gas meter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput 14 i,5&fflMMscf per year Requested Permit limit Throughput= ,78`:&rFi MMscf per year Requested Monthly Throughput= 7 MMscf per month Potential to Emit(PTE)Throughput= 78.89 MMscf per year Process Control(Recycling) Equipped with a VRU: y % Is VRU process equipment:ii 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: _ - 92Y Btu/scf Section 04-Emissions Factors&Methodologies Description g MHf ndwprposrtron fgas on2st .3peeiff'' gikoar�tgrg ample collected 1/29/2018 at 85 psig and 92 deg F. 1 I MW F '--'3416767!Ib/Ib-mol Displacement Equation Ex=Q"MW'Xx/C Weight% Helium ,.-.. CO2 ---.Z$508 N2 "-k'. O.SCS24 methane 16 2469': ethane 2"667€1. propane-' 29 14311 isobutane 4.5137= n-butane 12.0434'. isopentane _ 29572', n-pentane 3.7267'. cyclopentane 0 2724 n-Hexane 1.1168 cyclohexane 0 2935' Other hexanes 17506 heptanes 0.9845'. methylcyclohexane 0,303. 224-TMP 0.0097 Benzene 01493'. Toluene 0.1450 E ylbenzene 0.0107' Xylenes - - 10374. C8+Heavies ': 0.5004 Total 99.88 VOC Wt% 58.76 Emission Factors Separator Venting Operator Calculations Uncontrolled Controlled Emission Factor source Uncontrolled Pollutant (lb/MMscf) (lb/MMscf) (lb/Mscf) %diffemce from (Gas Throughput) (Gas Throughput) (Gas Throughput) engineer calm fix: ,««., VOC 52831.2030 1056.6241 53.14 0.58% - Benzene 134.2388 2.6848 -- 0.134 -0.18% Toluene 130.3726 2.6075 - 0.13 -0.28% Ethylbenzene 9.6206 0.1924 - 7,;,Af 0.01 3.94% Xylene 33.6271 0.6725 0.034 1.11% n-Hexane 1004.1387 20-0828 j _i j.o. 1.003 -0.11% 224 TMP 0.6294 - 0.0126 r. 0.0006 -4.67% Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 _ 0.000 PM2.5 0.000 1913T:.-3;53'3%;' SOx 0.000 NtOx 0.0680 130.628 X i 3a + g co a:31oo 595.510 � zsfe4zrrYroters4EusPtu #€#se /( n " 2 of 4 K:\PA\2018\18WE0140.CP1.xlsm Separator Venting Emissions Inventory Section 05-Emissions Inventory Potential to Emit - Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled - Uncontrolled Controlled. Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) Ohs/month) PM10 0.00 0.00 0.00 0.00 0.00 - 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 5O0 0.00 0.00 0.00 0.00 0.00 0 NOx 5.15 4.17 4,17 5.15 5.15 875 VOC 2083.93 1687.43 33.75 2095.99 41.92 7121 CO 23.49 19.02 19.02 23.49 23.49 3990 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Ohs/year) (Ibs/year) (Ibs/year) (Ihs/year) (Ihs/year) Benzene 10590 8575 172 10573 211 Toluene 10285 8328 167 10273 205 Ethylbenzene 759 615 12 759 15. Xylene 2653 2148 43 2648 53 n-Hexane 79217 64144 1283 79114 1582 224TMP 50 40 1 48 1 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,0 Source requires a permit Regulation 7,Section)0/11.0,G Source is subject to Regulation 7,Section 050,B.2,0 - Regulation 7,Section XVII.8.2.e The control device for this separator is not subject to Regulation 7,Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? _;" I! 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 Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? MAINERE Will the operator have a meter installed and operational upon startup of this point? Yes Does the company request a control device efficiency greater than 95%for a flare or combustion device? IESSINIIIIIIIIIIIIIIIIIIINZr 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 _ Emisstofisk ased.on LP`soparatorgasanalystsco(fecterl froltr 0' tt-ambergei4120/201"8 The ana(ysrsis site-5 ecrflca�fiW4(I�d Whhr .,@d-;: (it e fro 5Stepeuecpt initt41spmpfitigrequireme eis p1RI11y1ilO(1 'V , Separator 3s cgtrtralled bytherma)#vxld(zesnbtnngvRU bypasswith 0000 requested destruction efRcrency.Per nitwill netUttelpitiaEtestvng7a y bytte md"e gs5r 1 1311 ₹ , ,,,. if `:4' I 11.111,!1111100 1 3 ' F .� 13 311 P �� 3 3 3 /U�y,d�`I r t' � � 1 i �� "111 111 3 1j1'1111111 11 y a/ > 3 /"_.: 'l..l L.'�i13a,;3�u7.ii1(upk.,��.r� ,, ...... .. '.'t.....v *.z.„1 J.(tv.1.'.il ,,,.a. - Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 007 01 3-10-001-60 Flares PM10 0.00 0 lb/MMSCF PM2.5 0.00 0 lb/MMSCF SOx 0.00 0 lb/MMSCF NOv 130.63 0 lb/MMSCF VOC 52831.20 98 lb/MMSCF CO 595.51 0 lb/MMSCF Benzene 134.24 98 lb/MMSCF Toluene 130.37 98 lb/MMSCF Ethylbenzene 9.62 98 lb/MMSCF Xylene 33.63 98 lb/MMSCF n-Hexane 1004.14 98 lb/MMSCF 224 TMP 0.63 98 lb/MMSCF 3 of 4 K:\PA\2018\18WE0140.CP1xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re:ulation 3 Parts Aand B-APEN and Permit Requirements - ISource is in the Non-Attainment Area - - ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.c)7 f.. 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than to TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.31? Not enough Information — NON-ATTAINMENT 1 Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Pdrt A,Section 11.1.1.0)? itM11113O315ource Req 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)7 (i"ed; lSurce Req Isource requires a permit Colorado Regulation 7,Section XVII - 1. Was the well newly constructed,hydraulically fractured,orrecompleted on or after August 1,20142 55rt% -'5 urea isst 'Source is subject to Regulation 7,Section 0011.8.2,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? kwfgt,_;,,;;.'The control 'The control device for this separator is not subject to Regulation 7,Section XVII.B.2.0 Section XVII,0.2e—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 Centro/Commission regulations.This document is not a rule or regulation,and the analysis 4 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 true-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. 44 CDPHE C A D i+ .74 `. ,,,� tAir n Control,, � i y' Depa ent of t c Heap Environ �t CONSTRUCTION PERMIT Permit number: 18WE0140 Issuance: 1 Date issued: Issued to: Extraction Oil 8 Gas, Inc. Facility Name: RBF/Stromberger Production Facility Plant AIRS ID: 123/9F9B Physical Location: SENE SEC 22 T6N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID LP Separator Emissions from low pressure (LP) separator 007 Thermal oxidizer Venting during VRU bypass conditions 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.) eor COLORADO Air Pollution Control I rnmon Page 1 of 7 3. s permit s -r expi f t er or oper nor .; e source . h" ' this permi as issued: does not mend"eo lion/modif peration source withi 8 months =er either, e da f is ce of t $ constr ;ion per or the date on ich such • stru , •r activi was s k"r uled commen .s set th in the permi ,ryplication s. i. ed with thi " oi" f (ii) ots r ups cons u 'i• forr. .- iod of eigh t o 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.) .A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type LP Separator 007 -- 5.2 41.9 23.5 Point Venting 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 AIRS Pollutants Control Device Equipment ID Point Controlled Emissions from the LP separator are routed to a LP Separator 007 thermal oxidizer during Vapor Recovery Unit VOC and HAP Venting (VRU) bypass nrr�s COLORADO O s Air Potiutaon Control Divitxon Page 2 of 7 1,4 PROCES ;.IMITATION =ND R •RR tife • 8. g s source s be li ed t e followintrfra processi atestes listed be . Monthly ords of * -actual ,if4cessi ,elutes sh T be main iAki ed by owner or operate nd made • the Di x.: o, insp reque tea: l • ber 3, Part .) Process Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point LP Separator 007 Natural gas routed to 78,9 MMscf Venting thermal oxidizer Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. 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 40"'s 4C1 0" COLORADO CO Air Pollutzon Control Dinisaon Page 3 of 7 O&M plan' sub¢ t N_ ' ion approv pr to implem''_� i (Regulatio umber 3, t B, Sectio .G.7 • COMPLI CE TESTI ND Swatwi l'LING mfia esting Requirements Via. 15. 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 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The 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. (Regulation Number 3, Part B., Section III.G.3) 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 30t'' whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. COP HE COLORADO Air Pollution Control Dnnsion ��, Page 4 of 7 ,„, , �,.,,, •, .M.. 0 ,,,,,,,,,77:=7- 19. tp&: cikstats permit•: fic final a�hor ion has b ed, then th' ' emainder this conditi ; is no pti bae. Otherwi - ante of t con,,;ruction per '', does not vide 'fina Jthori:.jfor t ctivity o operati f this s e. Final author' on of the mit $Fie secu from ,APCD"ti writing t� ; ccorda with the provisi of 25-7- :`5-12 a C.R.S.' ' C CC R�"j{`i3t�tin"Number 3"`�'Pa"rt"Brt fi III.G. Fina auffb zation ( ) ({l 3 * k� »3?3+ 9^�'_:;sue 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. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. OPH COLORADO IA CO Air Pollution Control Division Page 5 of 7 In : tk Notes t rmit Holdet the off, 'permit iss, nce=- A. 1) The,° ,rmit holder#irequi to j ees for th M time fo is pe it. An invo -" for these fees ill be issue& fter t perms ssued e permi lder shag;.:; ay the invoice w din 30 days a- the- invoic iF lure d_.pa s invoi '._:ie A-evocation of � . 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 AIRS Uncontrolled Controlled Equipment ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 10,573 211 Toluene 108883 10,273 205 Ethylbenzene 100414 759 15 LP Separator Venting 007 Xylenes 1330207 2648 53 n-Hexane 110543 79,114 1582 2,2,4- 540841 48 1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 007: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source (lb/MMSCF) (lb/MMSCF) N0x 130.63 130.63 AP-42 Chapter 13.5 CO 595.51 595.51 Industrial Flares V0C 53,140 1062.8 71432 Benzene 134 2.68 108883 Toluene 130 2.60 Site-specific 100414 Ethylbenzene 10 0.20 extended gas analysis 1330207 Xylene 34 0.68 110543 n-Hexane 1003 20.06 ena £ COLORADO CO 1 Air Pollution Control Division Page 6 of 7 �3 pIrr„ ! fi it 0,44 ' m Nit : The contr d emi e ns f for this poi�`are b ed on the t�rmal a7 idizer contro f€ciency of 6) In a t rdance w R S 7-114 each A€ r` ollutant fission ce (APEN) associ with t . j d for a -p five, wr)r l:he d4p _as d by the Divi evised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, benzene, n-hexane, total HAPs NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX DP COLORADO COLORADO CO Air Pollubon Control Division Page 7 of 7 • _, �o�H� Condensate Storage Tank(s) APEN - Sot,rL A'` l 3 Form APCD-205 CO Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /S (k/ 01.37 AIRS ID Number: /23 /9F16/ 171- [1.e,we blank unless APO)has already assigned a perm iL and Ai-:l D)) Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: RBF/Stromberger Production Facility Site Location Site Location: SENE SEC22 T6N R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado Permit Contact: Kathy Steerman Phone Number: (720) 974-7765 E-Mail Address2: KSteerman@ExtractionOG.com 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by APCD via e-mail to the address provided. 374900 COLORADO Form APCD-205 Condensate Stereo Tank(s)APEN R:evjc cri 07/2017 1 1 AXIej =7.7,1t,`;=, Permit Number: AIRS ID Number: [Leave bi nk untaa APCD has _i€eac`. assigned a s:aarra /!and AIRS Di 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 ❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE) 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: Eight (8) - 400 bbl Condensate Storage Vessels For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 11/14/2017 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: Q Exploration Et Production (EEtP)site ❑ Midstream or Downstream (non EEtP)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No Are Flash Emissions anticipated from these storage tanks? El Yes ❑ No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? E Yes ❑ No If"yes", identify the stock tank gas-to-oil ratio: 0.0003 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) i Yes ❑ No 805 series rules? If so, submit Form APCD-105. Are you requesting≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual Yes ❑ No emissions≥ 6 ton/yr(per storage tank)? COLORADO Form Al''`_11 1v,E.'`i-- Condensate Storage, ic:!';i;(s, s0}EN i?:t.s%Qt.07/2017 2 ;-'17,==.:, • Permit Number: AIRS ID Number: / / D I [` A,-.ZS-�.�iF,z�;.'�S i`t��l�"aS _ti�(;zC`1 �,ii:,:t�'�i_£.:v�F3 li.,�N Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limit4 (bbl/year) (bbl/year) Condensate Throughput: 2,894,324 3,473,189 From what year is the actual annual amount? Projected Average API gravity of sales oil: 45.9 degrees RVP of sales oil: 11.2 Tank design: ✓❑ Fixed roof ❑ Internal floating roof ❑ External floating roof Storage #of Liquid-Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank''(month/year) (month/year) TK-1-TK-8 8 3200 11/2017 11/2017 Wells Serviced by this Storage Tank or Tank Battery5 (EfEP Sites Only) API Number Name of Well ' Newly Reported Well See Form APCD-212 ❑ - - ❑ - - ❑ 4 Requested values will become permit limitations. Requested limit(s)should consider future growth. 5 The EftP Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 Operator Stack Discharge Height Above . Temp. Flow Rate Velocity ID No. Ground Level (feet) (°F) (ACFM) (ft/sec) ECD —15 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑� Upward ❑ Downward El Upward with obstructing raincap ❑ Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter(inches): 48 ❑Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): s� ht COLORADO Form/sPCD 205 Condensate Storage anr£E si APEN 7-:v Es r r, 07,2017 3 AttiV Permit Number: AIRS ID Number: / / Fi _ .J il• unlc .=K_.: Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): % Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: Two (2) ECDs Make/Model: I ES - 48 Combustion ❑� Device: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 2,507 Btu/scf Constant Pilot Light: Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (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: HLP Separator, Gas Buster, VRT, Condensate Storage Tanks 11 coLoRA©O Fcrm / C�v 2`_5 Conclensat St:D7:9,O 9,i arks. PF:4 Pc:n .��,f ar._v1 Permit Number: AIRS ID Number: / / ��...; _.% r✓-t<<,r:,,,:^'�..ls::u- .dF:aC'1 �5i.��a 't G <^..t3.=-;-J a07 Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form-. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency (%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Emission Factor- Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)4 Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg. etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) VOC 0.12 lb/bbl Promax 178.29 8.91 213.95 10.70 NOx 0.068 Ib/MMBtu AP-42 0.12 0.15 CO 0.31 Ib/MMBtu AP-42 0.57 0.68 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor- Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service (CAS1 Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg. etc) Pounds) ear � (Pounds/year)I (Pounds/year) Benzene 71432 0.00021 lb/bbl Promax 611 31 Toluene 108883 0.00018 lb/bbl Promax 510 26 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.00186 lb/bbl Promax 5,395 270 2,2,4- 540841 Trimethylpentane 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. LORADO APEN form�JlPCl� L��SJ a <^:,, ",�,` G;r"s:�:: �uli�i5;li€.,i=t� Revision I-L'viJ 5 ._..uGt�rlxa uc- Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date ZedliLL/ 6.1( /) g- U. (2b0v- vI4 Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with$152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver,CO 80246-1530 https://www.cotorado.gov/cdphe/apcd Make check payable to: Colorado Department of Public Health and Environment Telephone: (303)692-3150 COLORADO Form APCD-211 -Natural Gas Venting APEN Rev 03/2017 6 I E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil&Gas,Inc. Source Name: RBF/Stromberger Production Facility Emissions Source AIRS ID2: N/A/ / Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05:-123-44448 RBF#1 05-123-44446 RBF#2 ®. 05-123-44441 RBF#3 05-123-44447 RBF#4 05-123-44439 RBF#5 05-123-44443 RBF#6 05-123-44445 RBF#7 05-123-44440 RBF#8 05-123-44449 RBF#9 05-123-44442 RBF#10 05-123-44444 RBF#11 05-123-42555 Stromberger#1 05-123-42559 Stromberger#2 05-123-42631 Stromberger#3 05-123-42561 Stromberger#4 05-123-42560 Stromberger#5 05-123-42556 Stromberger#6 05-123-42558 Stromberger#7 05-123-42557 Stromberger#8 Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 5.AP FormAPCD-212-EP-StorageTank-APEN-Addendum_20180103 kV DPHE Produced Water Storage Tan (s) A CO '' ' 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.6ov/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: ( 81NE-a i 3 g AIRS ID Number: /Z3 /9F11g /�vs [Leave bank unless APO has alreaciy assigned a p rmOL;.1 and AIRS!D] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: RBF/Stromberger Production Facility Site Location Site Location: SENE SEC22 T6N R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado Permit Contact: Kathy Steerman Phone Number: (720) 974-7765 E-Mail Address2: KSteerman@ExtractionOG.com 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by APCD via e-mail to the address provided. 374901 CpLOR ADL7 Form APCD ?C7 rodtcti� 'arEate€ Storage,z,e Tanls)APEN .t_. ,oru,. v17 1 Permit Number: AIRS ID Number: / / 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 - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PTE) 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: Two (2) - 400 bbl Produced Water Storage Vessels For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 11/14/2017 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: ❑✓ Exploration Et Production (EEtP)site ❑ Midstream or Downstream (non EELP)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No Are Flash Emissions anticipated from these storage tanks? E] Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes 0 No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? E] Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) Yes ❑ No 805 series rules? If so, submit Form APCD-105. Are you requesting≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual Yes ❑ No emissions≥ 6 ton/yr(per storage tank)? COLORADO Form/.1=CD 207 Produced Water Storage lank(s)APEN Revision()712017 2 M7 r-` 7 .,;,,t: Permit Number: AIRS ID Number: ,'`CD Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limit' (bbl/year) (bbl/year) Produced Water Throughput: 949,000 1,138,800 From what year is the actual annual amount? Projected Tank design: ✓❑ Fixed roof ❑ Internal floating roof ❑ External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bb!) Storage Tank(month/year) (month/year) PW-1&PW-2 2 800 11/2017 11/2017 Wells Serviced by this Storage Tank or Tank Battery5 (EEtP Sites Only) API Number Name of Well Newly Reported Well See Form APCD-212 ❑ - ❑ - ❑ - ❑ 4 Requested values will become permit limitations. Requested Limit(s)should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level (feet) (°F) (ACFM) (ft/sec) ECD —15 TBD TBD TBD Indicate the direction of the stack outlet: (check one) E Upward ❑ Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) E Circular Interior stack diameter (inches): 48 ❑Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): tOLORAOO Form r Pr 9 .:`_7 Produced „_.._er 3ti:3.a<; .,, :y .:ref €�: ' �t:,i:3712017 'f ;;:,1`,7,=:;;;,-,. Permit Number: AIRS ID Number: / / Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr • c Type: Two(2)ECDs Make/Model: I ES-48 Combustion ❑ Device: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: TBD Waste Gas Heat Content: 1495 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: TBD MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —45 psig Describe the separation process between the well and the storage tanks: HLP Separator, Produced Water Storage Tanks C040RAD0 Form r.rt_D-2i7 .Produced '. _.__, .._ .rage 3aik.'..),<PL:,' ReV si.,rt 3,,"3017 4 Att. '. „ „ Permit Number: AIRS ID Number: / / it f.,.a ?di c'dcy ,,�fC}C a DC'Yii[ and A:'.3:.J 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): Overall Requested Control Pollutant Description of Control Method(s) 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 Requested Annual Permit Emission Factor° Actual Annual Emissions : Emission Limit(s)- Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg. etc) (Tons/year).' (Tons/year) (Tons/year) (Tons/year) VOC 0.262 lb/bbl State EF 124.32 6.22 149.18 7.46 NOx 0.068 lb/MMBtu AP-42 1.74 2.09 CO 0.31 lb/MMBtu AP-42 7.92 9.51 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor6 Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service CAS Uncontrolled (CAS) Units (AP-42, Emissions Emissions Number Basis Mfg. etc) (Poundslyear) (Pounds/year) Benzene 71432 0.007 lb/bbl State EF 6,643 332 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.022 lb/bbl State EF 20,878 1,044 2,2,4- 540841 Trimethylpentane 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. A.Lwa: COLORADO For i APCD_207. !'oc..ccci ,‹ r`a. �I f O 20?L. �� ;��,:�� ,n '7, 7 5 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit k 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. r Signature of Legally Authorized Person(not a vendor or consultant) Date Sf.cee wi(� (e('r;r oo/r(r t Name(please print) Title Check the appropriate box to request a copy of the: ❑Q Draft permit prior to issuance ❑Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with$152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 https://www.coloredo.gov/cdphe/apcd Make check payable to: Colorado Department of Public Health and Environment Telephone: (303)692-3150 COLORADO Form APCD-211 -Natural Gas Venting APEN Rev 03/2017 6 I °4 `"`M`"en" HrYn�[n.beemm rLJ •• �2 CDPHE'• Natural Gas Venting APEN — Form. APCD-211 `oN Air Pollutant Emission Notice (APEN) and CoCApplication 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 speclic 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: g L�F (?j AIRS ID Number: /z3 /?P a/ 00,6 Le.ave bank unless APCD Mrs...reedy assigncid a permit and AIRSID Company equipment Identification: VRT Separator Venting [Provide Fact ity Equipment I0 to iii r this equipment is referenced within you E arnura:al.€,t�' Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: RBF/Stromberger Production Facility Site Location Site Location: SENE SEC22 T6N R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 370 17th Street, Suite 5300 Denver, Colorado Permit Contact: Kathy Steerman Phone Number: (720) 974-7765 E-Mail Address2: KSteerman@ExtractionOG.com 'Please use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 374902 w COL ORADO Form,APCD-211 Natural Gas Venting APEN Rey 1.12i2017 1 .,._ ,.�. Permit Number: AIRS ID Number: [Leavea 1.uDte5s r.C?) ..cafteaciy as,signeda perwit and A ._ 2_i Section 2- Requested Action J 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- El Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info a Notes: '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: Vapor Recovery Tower("VRT") Separator Venting Emissions For existing sources, operation began on: For new or reconstructed sources, the projected 11 / 14 / 2017 start-up date is: E Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment Yes ❑ No area Is this equipment located at a stationary source that is ❑ Yes No considered a Major Source of(HAP) Emissions /h�. COLORADO Form APCIU 211 ₹i tu4 El .Gas Venting ADEN Rev 03/2;017 • Permit Number: AIRS ID Number: / / Section 4 - Process Equipment Information E Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: Gal/min • ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes ❑ No Maximum Vent 1 415 SCF/hr Vent Gas 2 499 BTU/SCF Natural Gas Venting Rate: Heating Value: Process Parameters4: Requested: 12.40 MMSCF/year Actual: 10.04 MMSCF/year -OR- Liquid Throughput 4 Requested: Bbl/yr Actual: Bbl/yr Process Parameters4: 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth Molecular Weight: VOC (mote%) 64.1756 VOC (Weight%) 80.0223 Benzene (mole%) 0.1403 Benzene (Weight%) 0.2477 Toluene (mole%) 0.1013 Toluene (Weight%) 0.2109 Process Properties: Ethylbenzene (mole%) 0.0064 Ethylbenzene (Weight%) 0.0155 Xytene (mole%) 0.0246 Xylene (Weight%) 0.0590 n-Hexane (mote%) 0.9823 n-Hexane (Weight%) 1.9136 2,2,4-Trimethylpentane 0 0004 2,2,4-Trimethylpentane 0.001 1 (mole%) (Weight%) 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) LOLORA€O Form APCD-_1 E Natural Gas Venting I.P 03!2017 3 Permit Number: AIRS ID Number: S 1 u k E.i;it 1,(.!) >:'ir .i fs',., Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level Stack ID No. (°F) (ACFM) (ft/sec)' (Feet) Q5000 -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) E Circular Interior stack diameter(inches): TBD ❑ Other (describe): Section 6 - Control Device Information Pollutants Controlled: Size: Make/Model: ❑✓ VRU: Requested Control Efficiency VRU Downtime or Bypassed % Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: Thermal Oxidizer Make/Model: Questor/Q5000 ❑ Combustion Requested Control Efficiency: 98 % Device: Manufacturer Guaranteed Control Efficiency >99 % Minimum Temperature: TBD Waste Gas Heat Content 2,499 Btu/scf Constant Pilot Light: Yes ❑ No Pilot burner Rating TBD MMBtu/hr Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested c _ COLORADO Form APCL-_11 k: u:sa G:€.. Vcntnr€w APLN r;c r 03 2017 4 Permit Number: AIRS ID Number: Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency(% reduction): Overall Requested Control Pollutant Control Equipment Description Efficiency (%reduction in emissions) PM SOX NO), VOC Thermal Oxidizer 98% CO HAPs Thermal Oxidizer 98% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Requested Annual Permit Uncontrolled Emission Factor Actual Annual Emissions 5 Emission Limit(s). Pollutant Emission Factor Source Factor Units (AP-42, Uncontrolled Controlled6 Uncontrolled Controlled Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) PM SOX A f{ ?f �� ¢ NOx 0.0CC lb/MMBtu Mfg -42 e783 '' -6' �$2- r . �`° M‘ .� VOC 94.09 lb/Mscf Promax 472.21 9.44 583.18 11.66 CO Ib/MMBtu -Mfg Al,' `it 0766 3"*.;'3 e,1` Benzene 0.289 lb/Mscf Promax 1.45 0.03 1.79 0.04 Toluene 0.246 lb/Mscf Promax 1.23 0.03 1.52 0.03 Ethylbenzene Xylenes 0.069 lb/Mscf Promax 0.35 0.01 0.43 0.01 n-Hexane 2.231 lb/Mscf Promax 11.20 0.22 13.83 0.28 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. E c, i s j Car ;-t,i ^ r4:�� - />3 jl COLORADO Fc,r, A?'CJ-2 i s l' tU. :1 was _.1g 'd :ii ?c C3/2017 5 +. Permit Number: AIRS ID Number: / / [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. i r f 2-/(2-,/Z-0/47/ , Signature of Legally Authorized Person(not a vendor or consultant) Date ��- l.. {�YL vim. F r( . ' ' f,-'______OU "ll ' IV Name(print) J Title Check the appropriate box to request a copy of the: ID 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$250, if applicable, to: Colorado Department of Public Health and Small Business Assistance Program Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303)692-3150 jily�� ,COLORADO Form APCD-2O7 Produced Water Storage Tank(s)APEN - Revision 07/2017 6 I Mot, ,a�,: „a.' 9/13/2018 State.co.us Executive Branch Mail-Permit application for Extraction RBF/Stromberger Production Facility 4$W*' ETATE DE $t. Gillard -CDPHE, Betsy<betsy.gillard@state.co.us> COLORADO Permit application for Extraction RBF/Stromberger Production Facility Jason Browne <jbrowne@spiritenv.com> Tue, Sep 11, 2018 at 2:33 PM To: Betsy Gillard -CDPHE <betsy.gillard@state.co.us> Cc: Colin Harkins <colin@airbasics.biz>, Kathy Steerman <ksteerman@extractionog.com>, Kelli Cox <kcox@extractionog.com> Hi Betsy, Per our phone call,we're requesting to move forward with AP42 Table 13.5-1 NOx(0.068 lb/MMBTU) &CO (0.31 Ib/MMbtu)emission factors for the VRT and LP TOs. This will maintain consistency with previously issued construction permits for the Q5000 TOs that Extraction operates. Other than that, we will review the draft permits as a group and respond with comments next week before you head out on vacation. Thank you! Jason Browne, PMP Project Manager jbrowne@spiritenv.com DIRECT 720-500-3714 MOBILE 480-329-2614 SPIRIT 3�k'4 R{5 S4M 43ati l. From: Betsy Gillard - CDPHE <betsy.gillard@state.co.us> Sent: Tuesday, September 11, 2018 11:38 AM To: Jason Browne <jbrowne@spiritenv.com> Cc: Colin Harkins <colin@airbasics.biz>; Kathy Steerman <ksteerman@extractionog.com> Subject: Re; Permit application for Extraction RBF/Stromberger Production Facility Jason, I am attaching the 4 draft permits for this facility. Could you please review and let me know if you have comments? https://mail.google.com/mail/u/0/?ui=2&ik=2e1 a84e57d&jsver=CjTH3K6uFRk.en.&cbl=gmail_fe_180905.09_p4&view=pt&msg=165ca56d9d6fd5fa&se... 1/3 • F rif\8\2• �g CDPHE Natural Gas Venting APEN - Form APCD-211 'Ar* Air Pollutant Emission Notice (APEN) and S°` CO ‘� 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: (' 0/F O I L m AIRS ID Number: /�3 /gF9Bl co 7 [Leave b[ac,k unless APCD afteeay[:.ksiped a permit.#and AIRS O] Company equipment Identification: LP Separator Venting [Povicis.FrEdlity Equipment iD to identify ntify =. t.h`s equipment k referenced w i un your , fakiz t.k,s Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: RBF/Stromberger Production Facility Site Location Site Location: SENE SEC22 T6N R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (include zip code) 370 17th Street, Suite 5300 Denver, Colorado Permit Contact: Kathy Steerman Phone Number: (720) 974-7765 E-Mail Address2: KSteerman@ExtractionOG.com 'Please use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by APCD via e-mail to the address provided. • _..... _.. _ _.. 374903...... ��yy,, COLORADO Form APCD-211 Natural `gas s_ntir�;nl EN Rev 0312017 1 SLAV Permit Number: AIRS ID Number: f eav v:u r,t:li€ess 4PC:) ?E a pei 7 is 3Id AIRS ? s 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 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: Low Pressure ("LP") Separator Venting Emissions For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 11 / 14 / 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 days/week weeks/year Will this equipment be operated in any NAAQS nonattainment Yes ❑ No area Is this equipment located at a stationary source that is ❑ Yes O No considered a Major Source of(HAP) Emissions COLORADO Form APCD-2l 1 Natural GaS 'Venting APEN - R .r 0312017 2 I A.- %:. ��.�;;'-�n. Permit Number: AIRS ID Number: / / Jaid(tPthass *CD "ry as:Yipea a pernntand AIRS : Section 4 - Process Equipment Information • Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: Gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: - MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes ❑ No . Maximum Vent 9 00525 SCF/hr Vent Gas 921 BTU/SCF Natural Gas Venting Rate: . Heating Value: Process Parameters4: Requested: 78.89 MMSCF/year Actual: 63.88 MMSCF/year -OR- Liquid Throughput 4 Requested: Bbl/yr Actual: Bbl/yr Process Parameters4: 4 Requested values will become permit limitations. Requested limit(s)should consider future process growth Molecular Weight: VOC (mole%) 37.8970 VOC (Weight%) 58.7586 Benzene (mole%) 0.0651 Benzene (Weight%) 0.1493 Toluene (mole%) 0.0536 Toluene (Weight%) 0.1450 Process Properties: Ethylbenzene (mole%) 0.0034 Ethylbenzene (Weight%) 0.0107 Xylene (mole%) 0.0120 Xylene (Weight%) 0.0374 n-Hexane (mole%) 0.4416 n-Hexane (Weight%) 1.1168 2,2,4-Trimethylpentane 0 0002 2,2,4-Trimethylpentane 0 0007 (mole%) (Weight%) Additional Required Information: ❑r Attach a representative gas analysis (including BTEX a n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis (including BTEX a n-Hexane, temperature, and pressure) ORA6 Form ArCu_ ,i -Ncaturat GasVenting APE - Rrv"'C312017 3 I �,.. Permit Number: AIRS ID Number: =. .}i €._ st._.._ %_D r ....r : a .c<i n t;.L1!R'S ri)] Section 5 - Stack Information 'Geographical Coordinates (Latitude/Longitude or UTM) 40.474235, -104.870861 Discharge Height Operator Temp.. Flow Rate Velocity Stack ID No Above Ground Level {'F) {ACFM) (ft/sec) (Feet) Q5000 -30 TBD TBD TBD Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ✓❑ Circular Interior stack diameter(inches): TBD ❑ Other (describe): Section 6 - Control Device Information Pollutants Controlled: Size: Make/Model: ❑✓ VRU: Requested Control Efficiency VRU Downtime or Bypassed % Pollutants Controlled: VOC/HAPs Rating: TBD MMBtu/hr Type: Thermal Oxidizer Make/Model: Questor/Q5000 Combustion Requested Control Efficiency: 98 % Device: Manufacturer Guaranteed Control Efficiency >99 % Minimum Temperature: TBD Waste Gas Heat Content 1 ,921 Btu/scf Constant Pilot Light: l] Yes ❑ No Pilot burner Rating TBD MMBtu/hr Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested .GOL©RA60 Form PCD-2 i i NaLt rat Gas Vet'LnV APL-ti Rce CS/2S0 7 4 EilVr CIZT7T",';„::-„ Permit Number: AIRS ID Number: s ', 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 D No If yes, please describe the control equipment AND state the overall control efficiency(% reduction): Overall Requested Control Pollutant Control Equipment Description Efficiency (%reduction in emissions) PM SOX NOx VOC Thermal Oxidizer 98% CO HAPs Thermal Oxidizer 98% Other: From what year is the following reported actual accual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Requested'Annual Permit Uncontrolled Emission Factor Actual Annual Emissions Emission Limt(s)5 Pollutant Emission Factor Source Factor Units (AP-42, Uncontrolled Controlted6 Uncontrolled Controlled Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) PM SOx o I,r0 NOx lb/MMBtu egg 4 42 -4705 --TOO a iS 3t VOC 53.14 , lb/Mscf Promax 1,697.16 33.94 2,095.99 41.92 CO 8.05 3 31 lb/MMBtu PA4g rid '41. 3-8� s'i.�: 5t " 3 /J - {`' Benzene 0.134 lb/Mscf Promax 4.28 0.09 5.29 0.11 Toluene 0.130 lb/Mscf Promax 4.16 0.08 5.14 0.10 Ethylbenzene 0.010 lb/Mscf Promax 0.31 0.01 0.38 0.01 Xylenes 0.034 lb/Mscf Promax 1.07 0.02 1.32 0.03 n-Hexane 1.003 lb/Mscf Promax 32.03 0.64 39.56 0.79 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. a17 ct4 �i2.1 r"a \ - l /i3 )b co La ADO Form APCD-21'! Normal 1.G-as V_r.tmc ANN Rev CS/2017 5 I '' Permit Number: AIRS ID Number: [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. It Signature of e;~'ally Authorized Person(not a vendor or consultant) Date / � -P�r� Coordinator Gc� S �� Air Quality Name(print) Title Check the appropriate box to request a copy of the: ✓l Draft permit prior to issuance Ej 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. i 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 Small Business Assistance Program Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303)692-3150 COLORk0ii Form APCD 205 Condensate Storage Tank(s)APENRevision 07/2017 6 �,'°"" 9/13/2018 State.co.us Executive Branch Mail-Permit application for Extraction RBF/Stromberger Production Facility STATE OF Gillard -CDPHE, Betsy<betsy.gillard@state.co.us> COLORADO Permit application for Extraction RBF/Stromberger Production Facility Jason Browne <jbrowne@spiritenv.com> Tue, Sep 11, 2018 at 2:33 PM To: Betsy Gillard -CDPHE <betsy.gillard@state.co.us> Cc: Colin Harkins <colin@airbasics.biz>, Kathy Steerman <ksteerman@extractionog.com>, Kelli Cox <kcox@extractionog.com> Hi Betsy, Per our phone call,we're requesting to move forward with AP42 Table 13.5-1 NOx (0.068 lb/MMBTU) &CO (0.31 lb/MMbtu)emission factors for the VRT and LP TOs. This will maintain consistency with previously issued construction permits for the Q5000 TOs that Extraction operates. Other than that, we will review the draft permits as a group and respond with comments next week before you head out on vacation. Thank you! Jason Browne, PMP Project Manager jbrowne@spiritenv.com DIRECT 720-500-3714 MOBILE 480-329-2614 SPIRIT t1+1 kl Ro NMt:N1AL From: Betsy Gillard - CDPHE <betsy.gillard@state.co.us> Sent: Tuesday, September 11, 2018 11:38 AM To: Jason Browne<jbrowne@spiritenv.com> Cc: Colin Harkins <colin@airbasics.biz>; Kathy Steerman <ksteerman@extractionog.com> Subject: Re: Permit application for Extraction RBF/Stromberger Production Facility Jason, I am attaching the 4 draft permits for this facility. Could you please review and let me know if you have comments? https://mail.google.com/mail/u/0/?ui=2&ik=2e1 a84e57d&jsver=CjTH3K6uFRk.en.&cbl=gmail_fe_180905.09_p4&view=pt&msg=165ca56d9d6fd5fa&se... 1/3 Hello