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Home My WebLink About20180084.tiffCOPHE • COLORADO Department erst of Public Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 December 19, 2017 Dear Sir or Madam: RECEIVED DEC 2 7 2017 WELD COUNTY COMMISSIONERS On December 21, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil and Gas, Inc - Bison 4-64 15-16 2BHZ 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, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Pc) bIiew r.ctPLCMI»(TP), c-tLc�-r)� ewc ERIC N(Jill r CAC) I / 3/ ig iaasi 2018-0084 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil and Gas, Inc - Bison 4-64 15-16 2BHZ Production Facility - Weld County Notice Period Begins: December 21, 2017 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 and Gas, Inc Facility: Bison 4-64 15-16 2BHZ Production Facility Well Production Facility NWNE SEC 15 T4S R64W Weld County The proposed project or activity is as follows: Applicant proposes a new synthetic minor welt production facility in the Non -attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17AR0392 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: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us t.«u Fi8.N1�:t k?iiYtttlMme+rY Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: _. Review Start Date: Section 01- Facility Information Company Name: County AIRS 1D: Plant AIRS ID: Facility Name: Physical Address/Location: NWNE quadrant of Section 15, Township 4S, Range 64W, in Arapahoe County, Colorado Type of Facility Exploration & Production Weil Pad What industry segment? Oil & Natural Gas Production & Piocessmg Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? [j:arbon Monoxide (CO) Particulate Matter (PM) Section 02 - Emissions Units In Permit Application Quadrant ✓bone (NOx & VOC) Section Township Range 15 • 64 AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank Cond. Tanks Yes EPOS 1 Yes Permit Initial Issuance 002 ' Produced Water Tank PW Tanks Yes OPUS 1 yes initial issuance 003 Hydrocarbon Liquid Loading Liquid Loading No GPO7 1 Yes Permit Initial Issuance 00d- Separator Venting Produced Gas Venting Yes 17AR03S2 1 Yes Permit initial Issuance 005 Separator Venting Separator Venting Yes 17AR0393 1 Yes Permit Initial Issuance Section 03 - Description of Project Applicant proposes a new synthetic minor E&P facility. Source updated. point 005 with site specific emission factors on Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Yes Requesting Synthetic Minor Permit Section 05 Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Colorado Air Permitting Project Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx ❑ ❑ O SO2 NOx ❑ ❑ ❑ ❑ O CO VOC PM2.5 PM10 TSP HAPs ❑. ❑ ❑ ❑ ❑. ❑ O O O ❑. L CO VOC PM2.5 PM10 TSP HAPs ❑ O O O ❑. ❑ O ❑ ❑] O. O One Vapor Recovery Tower prior to the inlet of the condensate storage tanks. The emissions from the VRT are 004 controlled by an enclosed flare. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q = Volumetric flow rateNolume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Maximum Vent Rate Throughput (Q) MW 123.5 scf/hr MMscf/yr Ib/Ib-mol 1.2 41.85 136.9863014 0.003287671 scf/hr MMscf/d mole % MW Ibx/lbmol mass fraction lb/hr lb/yr tpy Helium 4.0026 0.168 0.004 0.06 533.05 0.27 CO2 4.21 44.01 8.065 0.193 2.92 25535.65 12.77 N2 18.33 28.013 2.781 0.066 1.01 8805.75 4.40 methane 9.93 16.041 2.834 0.068 1.02 8972.41 4.49 ethane 17.67 30.063 7.332 0.175 2.65 23213.46 11.61 propane 24.39 44.092 10.753 0.257 3.89 34046.10 17.02 isobutane 3.20 58.118 1.857 0.044 0.67 5880.14 2.94 n -butane 11.58 58.118 6.732 0.161 2.43 21314.25 10.66 isopentane 2.69 72.114 1.938 0.046 0.70 6136.94 3.07 n -pentane 3.48 72.114 2.511 0.060 0.91 7951.89 3.98 cyclopentane 70.13 0.000 0.000 0.00 0.00 0.00 n -Hexane 1.14 86.18 0.985 0.024 0.36 3118.66 1.56 cyclohexane 0.30 84.16 0.252 0.006 0.09 799.43 0.40 Otherhexanes 1.11 86.18 0.957 0.023 0.35 3030.57 1.52 heptanes 1.07 100.21 1.069 0.026 0.39 3383.75 1.69 methylcyclohexane 98.19 0.000 0.000 0.00 0.00 0.00 224-TMP 0.11 114.23 0.125 0.003 0.05 395.62 0.20 Benzene 0.30 78.12 0.236 0.006 0.09 747.87 0.37 Toluene 0.16 92.15 0.151 0.004 0.05 477.93 0.24 Ethylbenzene 0.02 106.17 0.021 0.001 0.01 67.44 0.03 Xylenes 0.04 106.17 0.045 0.001 0.02 142.71 0.07 C8+ Heavies 0.28 118 0.331 0.008 0.12 1047.09 0.52 VOC mass frac 0.668 Total VOC (Uncontrolled) 44.27 Notes Mole %, MW, and mass fractions from ProMax simulation with site specific upstream pressurized liquid sample as the input 17AR0393.CP1.xlsm One Vapor Recovery Tower prior to the inlet of the condensate storage tanks. The emissions from the VRT are 004 controlled by an enclosed flare. Flaring Information Equipment Description Gas Heating Value Throughput 1981.13 Btu/scf MMBtu/yr 2377.356 meter installed: Modeled liquid thorughput to separator: 1081.9 Overall Control 95.00% bb4/yf sc/bbl Combustion emission factor source: AP -42: Chapter 13.5 0.068 Ilb NOX/MMBtu 0.31 Ilb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 73784 lb/MMscf 3689.18 lb/MMscf 44.3 tpy 2.21 tpy Promax Nox 0.07 Ib/MMBTU 0.07 Ib/MMBTU 0.1 tpy 0.1 tpy AP -42 CO 0.31 lb/MMBTU 0.31 Ib/MMBTU 0.4 tpy 0.4 tpy AP -42 Benzene 623.22 lb/MMscf 31.16 lb/MMscf 748 lb/yr 37 lb/yr Promax • n -Hexane 2598.88 lb/MMscf 129.9442 lb/MMscf 3119 lb/yr 156 lb/yr Promax Toluene 398.275Ib/MMscf 19.9138Ib/MMscf 478 lb/yr 24 lb/yr Promax Xylenes 118.923 lb/MMscf 5.9462 lb/MMscf 143 lb/yr 7 lb/yr Promax Ethylbenzene 56.201 lb/MMscf 2.8100 lb/MMscf 67 lb/yr 3 lb/yr Promax Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2 17AR0393.CP1.xlsm 005 One high -low-pressure separator controlled by one enclosed flare. Flare has a minimum control efficiency of 95%. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW *Xx /C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Maximum Vent Rate Throughput (Q) MW scf/hr MMscf/yr lb/lb-mol 32.45 3704.3379 scf/hr MMscf/d 25.445 0.08890411 mole % MW Ibx/Ibmol mass fraction lb/hr lb/yr tpy Helium 4.0026 0.000 0.00 0.00 0.00 CO2 44.01 0.000 0.042382 10.54 92333.52 46.17 N2 28.013 0.000 0.011460 2.85 24966.78 12.48 methane 16.041 0.000 0.421411 104.80 918086.95 459.04 ethane 30.063 0.000 0.138113 34.35 300893.29 150.45 propane 44.092 0.000 0.188384 46.85 410413.80 205.21 isobutane 58.118 0.000 0.022636 5.63 49314.84 24.66 n -butane 58.118 0.000 0.066572 16.56 145033.91 72.52 isopentane 72.114 0.000 0.016931 4.21 36885.91 18.44 n -pentane 72.114 0.000 0.021223 5.28 46236.48 23.12 cyclopentane 70.13 0.000 0.001282 0.32 2792.97 1.40 n -Hexane 86.18 0.000 0.006226 1.55 13563.98 6.78 cyclohexane 84.16 0.000 0.002608 0.65 5681.79 2.84 Other hexanes 86.18 0.000 0.007646 1.90 16657.59 8.33 heptanes 100.21 0.000 0,009687 2.41 21104.12 10.55 methylcyclohexane 98.19 0.000 0.002364 0.59 5150.22 2.58 224-TMP 114.23 0.000 0.000000 0.00 0.00 0.00 Benzene 78.12 0.000 0.001184 0.29 2579.47 1.29 Toluene - 92.15 0.000 0.001111 0.28 2420.43. 1.21 Ethylbenzene 106.17 0.000 0.000146 0.04 318.08 0.16 Xylenes 106.17 0.000 0.001096 0.27 2387.75 1.19 C8+ Heavies #DIV/0! #DIV/0! 0.037535 9.33 81773.84 40.89 VOC mass frac Notes Source updated this point with site specific emission estimates on 11/13/2017 0.387 Total VOC (Uncontrolled) 421.16 17AR0393.CP1.xlsm 005 One high -low-pressure separator controlled by one enclosed flare. Flare has a minimum control efficiency of 95%. Flaring Information Equipment Description Gas Heating Value Throughput 1296 Btu/scf MMBtu/yr 42055.2 meter installed: Modeled liquid thorughput to separator: Overall Control 95.00% 1,000 040 bbl!yr ss#/bbl Combustion emission factor source: AP -42: Chapter 13.5 0.068 alb NOX/MMBtu Emissions Summary Table 0.31 Ilb CO/MMBtu Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 25957 lb/MMscf 1297.87 lb/MMscf 421.2 tpy 21.06 tpy Gas Analysis Nox 0.07 Ib/MMBTU 0.07 lb/MMBTU 1.4 tpy 1.43 tpy AP -42 CO 0.31 lb/MMBTU 0.31 lb/MMBTU 6.5 tpy 6.52 tpy AP -42 Benzene 79.49 lb/MMscf 3.97 lb/MMscf 2579 lb/yr 128.97 lb/yr Gas Analysis n -Hexane 418:00 lb/MMscf 20.8998 lb/MMscf 13564 lb/yr 678.20 lb/yr Gas Analysis Toluene 74.589 lb/MMscf 3.7295 lb/MMscf 2420 lb/yr 121.02 lb/yr Gas Analysis Xylenes 73.582 lb/MMscf 3.6791 lb/MMscf 2388 lb/yr 119.39 lb/yr, Gas Analysis Ethylbenzene 9.802 lb/MMscf 0.4901 lb/MMscf 318 lb/yr 15.90 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which aremeasuredin excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2 17AR0393.CP1.xlsm Permit number: Date issued: Issued to: ADO Contro is Heal CONSTRUCTION PERMIT 17AR0392 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Bison 4-64 15-16 2BHZ Production Facility 005/1687 NWNE SEC 15 T4S R64W Arapahoe Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT Venting 004 Vapor Recovery Tower Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division Page 1 of 8 3. s permit s does not c er either, stru ae (ii ) more; (iii) does not complete date. The Division may grant III.F.4.) er or oper or . e source tion/modifaF.peration ce of t constron pe uled commenw_.:.s set s cons this permi «.s issued: ource withi 8 months or the date on ich such th in the permi ••lication iod of eigh - the or construction within a reasonable time of the estimated completion extensions of the deadline. (Regulation Number 3, Part B, Section 4. Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. Until the flow meter is installed, the operator shall monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 5.72 scf/bbl estimated in the permit application. 5. 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.) 6. 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 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO VRT Venting 004 --- --- 2.3 --- Point N 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. COLORADO Air Pollution Control Division Page 2 of 8 8. - emission trot equip ablished i below sh order to r tion Nu er 3, P rated an sions to , Secti II.E.) ned with t " ; emissions or equal he limits acuity Equipment ID Point Control Device • •nts Controlled VRT Venting 004 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT Venting 004 Natural Gas Venting 1.2 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Upon installation of the flow 'meter, 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 11. 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) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject. to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any COLORADO I Air Pollution Control Division c:epa tmext oP 4"Wit Yie < 4.0 G �vvUrmett Page 3 of 8 ly constr ted to a g trot equi bus fractured, pleted o's well, mud either be controlle F date of p • uction by pollution s an avage hy• arbon trot efficiency • ' 5%. If a t have a design tructio fficiency of at l t 98% for OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than .100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold COLORADO. drPollution Control Division Page 4 of 8 GEN l rev ce s ber 3 CON struction yet comm -d on the ram thrtil a perms granted. 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection. of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer COLORADO Air Pollution Control Division 'cerement of Ifi' Al *Oh -Page 5 of 8 Issuance 1 This Issuance Issued to Extraction Oil a Gas. Inc. COLORADO Air Pollution Control Division wti:-:r+srt Ct''ubii t;ce*..+'s �t^.o'�ra:ter. Page 6 of 8 Notes t•; rmit Holds t the iT--• " permit iss 1) The 'rmit holde requi to ees for th • • time fo s pe it. An invo for these fees.' ll be iss � �''=fter t .ermi°; 'ssued e permi lder sh.��-'.ay the invoice w n 30 days ure invoi e evocation ermit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) VRT Venting 004 Benzene 71432 748 38 Toluene 108883 478 24 n -Hexane 110543 3117 156 2,2,4- Trimethylpentane 540841 396 20 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Source V0C 73684.2 Promax and Upstream Pressurized Liquid Sample Analysis 71432 Benzene 622.4 108883 Toluene 397.7 110543 n -Hexane 2595.4 540841 2,2,4-Trimethylpentane 329.3 Note: The controlled emissions factors for this point are based on the Combustor control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 90 °F and separator pressure of 5 psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to COLORADO Air Pollution Control Division ?ancrtg^crt .€cr n. 6 L,,+vrsorU?vr;C Page 7 of 8 the ass at 7) T st recent a ted with t )-692-315!; assifie determin questions r expi rati specific or each emi ins point date call Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: V0C and HAP NANSR Synthetic Minor Source of: V0C 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, 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 X)00000 !COLORADO Air Pollution Cor€trol Division Page 8 of 8 Permit number: Date issued: Issued to: ADO n Contra tic Heat CONSTRUCTION PERMIT 17AR0393 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Bison 4-64 15-16 2BHZ Production Facility 005/1687 NWNE SEC 15 T4S R64W Arapahoe Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Separator Venting 005 • High -Low Pressure Separator Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2. ) COLORADO ar Pollution Control Division Page 1 of 8 3. s permit s does not c er either, stru er or oper or • e source tion/modif •peration f is -;- ice of t constron per was s •uled commends; .s set (11) s cons this permi as issued: ource withi 8 months or the date on ich such th in the permi lication od of eighthe 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. Upon issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. 5. 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.) 6. 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 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Separator Venting 005 --- 1.5 21.1 6.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Separator Venting 005 Enclosed Combustion Device VOC and HAP OLORADO Air Pollution Control Divis L-,,ar rY?t"t Page 2 of 8 9. be li foltowi - "; process] ; ate- :s listed be Monthly ctualtes sh;' be main ed by i owner or operat =nd made he Di ' ,: insp eque l.:,• , ber 3, Par .) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Separator Venting 005 Natural Gas Venting 32.45 MMSCF Compliance with the annual throughput limits shalt 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. 10. 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 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shalt be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III. E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record -keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to COLORADO tttio*i Control Division Page 3 of 8 to imple • (Regulatio 3 umber 3, 1 la esting RegUiremen s 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO), per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. COLORADO s Air Pollution Control Division oart-x. x hFs7?i ftE&G*:-errs:^:t Page 4 of 8 21. his permit cific. 3 ,� at final a o ion has b ed, then th , emainder this conditi, is nog ₹.p le. Otherwiance of t con ruction per '' does not vide fina thon or t ctivity . .perati• f this so ; e Final authors on of the mitu 4 e secu APCD writing i ccorda with the provisi of 25-7- (a) C.R.S. C Rmber , III.G. Fin. .ri°`' . zation cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air. Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. COLORADO Mr Pollution Control Division tupvi.c^,t st Pau,- c "» , C^uirmrme tt Page 5 of 8 Notes t. -rmit Holdpermit iss 1) The =rmit holde _.'requi Z to ees for th,.. time fo = s p- it. An invo for these fees .` ll be issu .'after t ,,... •ermi ; ssued. e permi ,`, lder sh. `.ay the invoice w 3; n 30 days e inv...,.:. sure ,-� s,,�,ti�invoi e <_..,,evocation ermit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. N per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Separator Venting 005 Benzene 71432 2,579 129 Toluene 108883 2,419 121 Ethylbenzene 100414 318 16 n -Hexane 110543 13,559 678 Xylenes 1330207 2,388 119 COLORADO Air Pollution Control Division t:ep rtment •vi PUhl;_ HL'f:kn iJ Envir onm nt Page 6 of 8 5) The Poi ontai o u an ermit are 1 µ.; the folio Uncontro Emissi ac ors (lb/MMSCF) sion factor ource N0x 88.13 (0.068 lb/MMBtu) CO 401.76 (0.31 lb/MMBtu) Back Calculated from AP -42 Combustion Emission Factors V0C 25,955 71432 Benzene 79.5 108883 Toluene 74.6 100414 Ethybenzene 9.8 110543 n -Hexane 417.8 1330207 Xylene 73.6 Site Specific Gas Sample Analysis Note: The controlled emissions factors for this point are based on the Combustor control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 108°F and separator pressure of 98'psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable. Requirement Status Operating Permit Synthetic Minor Source of: V0C and HAP NANSR Synthetic Minor Source of: V0C 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, 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 (COLORA0O AixPallutianControl .Division Pepert v dt d Public tae tit J Lwiruriraetit Page 7 of 8 i COLORADO Air Pollution Control Division PuNlz Heath s Enaa.or 'e t Page 8 of 8 Gas/Liquid Separator APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. - This APEN is to be used for Gas/Liquid Separators only. 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: 114-0-0 512, AIRS ID Number: GCS s / ((.fl- / GU -1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification:. VRT Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Extraction Oil & Gas, Inc. Bison 4-64 15-16 2BHZ Production Facility Site Location: NWNE Sec 15 T4S R64W Mailing Address: (Include Zip code) 370 17th Street, Suite 5300 Denver, Colorado E -Mail Address2: ksteerman@extractionog.com Site Location County: Arapahoe NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 '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. 36`71fa7 Form APCD-211 - Gas/Liquid Separator APEN - Rev 02/2017 Ice lJe.0( 7/3i /i7 per C. kE 5 €/2 pw COLORADO 1 I • - Hatl4�6 Environment Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Venting emissions from VRT For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 01/23 /2017 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 • days/week weeks/year ❑✓ Yes ❑ Yes ❑ No ❑r No COLORADO DeperPnen[of P^ut• Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates 39.708012/-104.535477 �^-: >�.; pe tea ..a'a- � _ < r ^n�•'x,_ is ,.. a •a ei h 1. _. ___ _ a> � -_ X n y .,-4 �..� o Rate �i. _. ,:.. mss.' _ . � , Velo c- �..� __ <:" ..=:3 -,. :.., ..se »� -_': ECD —15' TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward LI Other (describe): Indicate the stack opening and size: (check one) ✓❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 48 Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC/HAPs TBD ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: Constant Pilot Light: Q Yes ❑ No Pilot burner Rating MMBtu/hr Make/Model: Cimarron 48" 95 >9,8 % Waste Gas Heat Content 1981 Btu/scf 0.13 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-211 -Gas/.Liquid Separator APEN - Rev 02/2017 COLORADO Neatui b cnveean�ran, Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall RequestedEGontro'! Efficiency PM Sox . INOx VOC ECD 95 CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) t Pollutant Uncontrolled = Emission Factor Emission Factor Units Emission Factor Source Actual Annual Emissions �>, ,. Requestetl Annua 'Fermat s Emission Limits) Uncontrolled Controlled6 Uncontrolled Controlled PM SOX NOx 0.068 Ib/MMBtu AP -42 0.07 0.08 J VOC 73.6842 — lb/Mscf Promax 39.82 1.99 44.24 / 2.21 - CO 0.31 Ib/MMBtu AP -42 0.34 0.37 -' Benzene 0.6224 lb/Mscf Promax 0.34 0.02 0.37 -- 0.02 Toluene 0.3977 lb/Mscf Promax 0.21 0.01 0.24 -- 0.01 Ethylbenzene Xylenes n -Hexane • 2.5954 lb/Mscf Promax 1.40 0.07 1.56 — 0.08 Trimethyipentane thylp 0.3293 lb/Mscf Promax 0.18 0..01 , 0.20 - ` 0.01 �' Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. trn Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 COLORADO, Depaliment a PvhLk Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 7/31/2017 Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to : Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd 6IA® COLORADO Departmental ,ta Health b toarannene 1c, a u & 'I1 Kiln Gas/Liquid Separator APEN — Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Gas/Liquid Separators only. 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: 17AR0393 AIRS ID Number: 005 / 1687 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Separator Venting [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Extraction Oil & Gas, Inc. Site Name: Bison 4-64 15-16 2BHZ Production Facility Site Location: NWNE Sec 15 T4S R64W Mailing Address: (Include Zip Code) 370 17th Street, .Suite 5300 Denver, Colorado E -Mail Address2: ksteerman@extractionog.com Site Location County: Arapahoe NAICS or SIC Code: 211111 Permit Contact: Kathy Steerman Phone Number: 720-974-7765 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 a -mail to the address provided. Form APCD-211 - Gas/Liquid Separator APEN - Rev 02/2017 AyCOLORADO 1 I Department. AuWfc �i�- Hwme Eevumnmeet Permit Number: 17AR0393 AIRS ID Number: 005 /1687 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action E] NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR • APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It 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: Separator Venting Emissions from HLP For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 01 /23 /2017 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions (] Yes ❑ No ❑ Yes El No Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 tarCOLORADO _ HuaiNk Enm ne , ,t Permit Number: 17AR0393 AIRS ID Number: 005 / 1687 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information If you are requesting uncontrolled VOC emissions greater than 100 tpy you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? I Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 26921 SCF/hr Vent Gas Heating Value: 1 296 BTU/SCF Requested: 32.4,5 MMSCF/year Actual: 29.21 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 25.47 VOC (mole %) 17.91 VOC (Weight %) 38.67 Benzene (mole %) 0.039 Benzene (Weight %) 0.118 Toluene (mole %) 0.031 Toluene (Weight %) 0.111 Ethylbenzene (mole %) 0 004 •(Weight Ethylbenzene %) 0.015 Xylene (mole %) 0.026 Xylene (Weight %) 0.110 n -Hexane (mole %) 0..184 n -Hexane (Weight %) 0.623 2,2,4- Trimethylpentane 2,2,4-Trimethylpentane .0.00 (Weight %) 0.00 Additional Required Information: Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 COLORADO 3 A -Departmental PIM AIRS ID Number: 005 / 1687 / 005 Permit Number: 17AR0393 [Leave blank -unless APCD has already assigned a permit n and AIRS ID] Section 5 - Stack Information Geographical Coordinates latitude.Longitude ors 39.708012/-104.535477 t .. `5k'.rx,..__Feet,]-�.. �. ° °yam ... - As h r ht a rounf Level rjAum) rn ® . Rate ₹ Veloc�zy t/SeC) ow ECD �15' TBD TBD TBD Indicate the direction of the stack. outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) O Circular Interior stack diameter (inches): ❑ Other (describe): - ❑ Upward with obstructing raincap 48 Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed O Device: Combustion Pollutants Controlled: VOC/HAPs Rating: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr Make/Model: Cimarron 48" 95 >98 % Waste Gas Heat Content 1296 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating TBD MMBtu/hr Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 department. Public COLOR -ADO AIRS ID Number: 005 /1687 7 005 PM Permit Number: 17AR0393 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any -emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No - If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Control Equipment Description Overall Requested Control Efficiency reduction n!emissians) SOX NO,, VOC ECD .95 CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) 5 Pollutant Uncontrolled _ Emission Factor Emission Factor Units Emission Factor Source (AP -42,.i Mfg etch x: eques d Annual Permit �'''''5'ri r�n ss--on - Ac ual Annua Emission Uncontrolled (- ons/year) Controlled6 (' ans/year) Uncontrolled _ (Tons/year) Contragec ns/year), PM SOX NOX 0.068 Ib/MMBtu AP -42 - 1.29 1.43 ' VOC 25.9555 Ib/Mscf Eng. Est. . 379.02 18.95 421.1,5 -' 21.06 CO 0.31 Ib/MMBtu AP -42 5.87 6.52 ' Benzene 0.0795 Ib/Mscf Eng. Est. 1.16 0.06 1.29 — 0.07 -- Toluene 0.0745 Ib/Mscf Eng. Est. 1.09 0.05 1.21 0.06 " Ethylbenzene 0.0098 ib/Mscf Eng. Est. 0.14 0.01 - 0.16 — 0.01 ' Xylenes 0.0736 Ib/Mscf Eng. Est. 1.07 0.05 1.19 - 0.06 ' n -Hexane 0.4178 Ib/Mscf Eng. Est. 6.10 0.31 6.78 - 0.34 e 2,2,4- Trimethylpentane - Other: Requested values will become -permit -limitations. Requested limit(s) should consider future process growth. _ 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, Leave blank. Form APCD-211 -Gas/Liquid Separator APEN~ Rev 02/2017 COLORADO Timatsb 6 Finwevannf Permit Number: 17AR0393 AIRS ID Number: 005 / 1687 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 11 /13/2017 Signature of Legally Authorized Person (not a vendor or consultant) Date Kathy Steerman Air Quality Coordinator Name (please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 43OO Cherry Creek Drive South Denver, CO 8O246 -153O Make check payable to : Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-211 -Gas/Liquid Separator APEN - Rev 02/2017 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd COLORADO 6 i � Departmental P.M u Enh b Hello