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Home My WebLink About20170638.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 February 24, 2017 Dear Sir or Madam: RECEIVED MAR 022017 COMMISSIONERS On March 2, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Johnston Trust 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. Hickenlooper, Governor PvbIic R -0-A/ �w C03/O(p(I -7 I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc : PL Cmm/TP), kit -CPS), Pw C ER!CH(C( f Sm) O3/OQ/1.1 2017-0638 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil a Gas, Inc. - Johnston Trust Production Facility - Weld County Notice Period Begins: March 2, 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 a Gas, Inc. Facility: Johnston Trust Production Facility Exploration a Production Well Pad NWSW Sec 1 T2N R68W Weld County The proposed project or activity is as follows: Comingled gas and liquid streams from wellheads flow to HLP separators. Gas from the separators is either compressed and routed to a sales line, or routed to enclosed combustors (approx. 4% of total gas). Gas from the HLP separators routed to the enclosed combustors will be recorded by flowmeter. Liquid from the LP separators flows to a VRT, from which vapors are compressed to sales pipeline or routed to enclosed combustors (approx. 4% of total gas). Gas from the VRT routed to the enclosed combustors will be recorded by flowmeter. Liquid from the VRT is routed to condensate storage tanks, which are controlled by flares. 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 16WE1209 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 1I' COLORADO Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Betsy Gillard 355611 1/31/2017 11/14/2016 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? Yes - - If yes, for what pollutant? ❑ Carbon Monoxide (CO) O Particulate Matter (PM) Extraction Oil & Gas, Inc. 123 9EF3 Johnson Trust Production Facility NWSW Sec 13 T2N R68W Exploration & Production Weil Pad Oil & Natural Gas -Production & Processing Section 02 - Emissions Units In Permit Application 9 Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit # Issuanc eft Self Cert Required? Action Engineering Remarks 001 SeparatorVenting :'" Yes 16WE1209 1 Yes Permit Initial Issuance 002 Condensate Storage Tank Yes G P01 003 hydrocarbon Liquid Loading " yes ,' GP07 004 Produced Water Storage Tank Yes :" GP0S 005 Vapor Recovery Tower VRT Yes == 17WEO1O4 1 Yes . Permit Initial issuance Section 03 - Description of Project Comingled gas and liquid streams from wellheads flow to LP separators. Gas from the separators is either compressed and routed to a sales line, or routed to enclosed combustors. Sales gas routed to the enclosed combustors will be recorded by flowmeter. Liquid from the LP separators flows to a VRT, from which vapors are routed to enclosed combustors or compressed to sales pipeline. Liquid from the VRT is routed to condensate storage tanks. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?' Requ Yes frig Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?' No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Title V Operating Permits (OP) : VOC No Is this stationary source a major source? No Produced Natural Gas Venting/Flaring Preliminary Analysis Equipment Description This source vents natural, gas from: a well head separator Emissions from this source are: routed to an enclosed flare Colorado Department of Public Health and Environment Air Pollution Control Division Natural gas from low-pressure separators. When gas is not compressed into sales pipeline, it is routed to enclsoed flares. 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 I 825.8 scf/hr RequestedThroughput (Q) 7.234 MMscf/yr 825.8 sd/hr I 0.000 MMscf/d I 0.61 MMscf/mol % Vented I 100% MW 37.118 Ib/Ib-mol Component mole % MW Ibx/Ibmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 1.32073 44.01 0.581 0.016 CO2 1.3 11094 5.55 N2 1.79008 28.013 0.501 0.014 N2 1.1 9571 4.79 methane 26.9516 16.041 4.323 0.116 methane 9.4 82519 41.26 ethane 26.887 30.063 8.083 0.218 ethane 17.6 154282 77.14 propane 21.6117 44.092 9.5290 0.257 propane 20.8 181881 90.94 isobutane 3.87101 58.118 2.2498 0.061 isobutane 4.9 42941 21.47 n -butane 9.37327 58.118 54476 0.147 n -butane 11.9 103978 51.99 isopentane 2.71441 72.114 1.9575 0.053 isopentane 4.3 37362 18.68 n -pentane 3.1019 72.114 2.2369 0.060 n -pentane 4.9 42696 21.35 cyclopentane 0.767978 70.13 0.5386 0.015 cyclopentane 1.2 10280 5.14 n -Hexane 0.5467 86.18 0.4711 0.013 n -Hexane 1.0 8992 4.50 cyclohexane 0.0000 84.16 0.0000 0.000 cyclohexane 0.0 0 0.00 Other hexanes 0 86.18 0.0000 0.000 Other hexanes 0.0 0 0.00 heptanes 0.452041 100.21 0.4530 0.012 heptanes 1.0 8646 4.32 methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00 224-TMP 0.114281 114.23 0.1305 0.004 224-TMP 0.3 2492 1.25 Benzene 0.199701 78.12 0.1560 0.004 Benzene 0.3 2978 1.49 Toluene 0.0793407 92.15 0.0731 0.002 Toluene 0.2 1396 0.70 Ethylbenzene 0.0137051 106.17 0.0146 0.000 Ethylbenzene 0.0 278 0.14 Xylenes 0.01075798 106.17 0.0114 0.000 Xylenes 0.0 218 0.11 C8+ Heavies 0.19387608 185.590 0.3598 0.010 C8+ Heavies 0.8 6868 3.43 VOC mass fraction: 0.6366 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control Operator VOC Emissions (uncontrolled) Operator VOC Emissions (controlled) Notes 225.5 11.3 225.1 11.3 Mole %, MW, and mass fractions from ProMax simulation based on Pressurized Liquid Sample off of LP separators, collected 10/01/2016. Gas composition was determined using ProMax's reverse separator function. Emissions are based on 8760 hours of operation per year. Requested throughput is based on maximum monthly throughput from actual production records. I calculated the average MW of C8+ based on the average MW on the analysis for the gas. Flaring Information Equipment Description Flare to combust low-pressure separator gas when gas is not routed to sales line. Manufacturer Model Serial Number Gas Heating Value Throughput TBD TBD TBD 2076 Btu/scf MMBtu/yr 15017.784 Combustion emission factor source: AP -42: Chapter 13.5 0.068 lb NOX/MMBtu tpy NOX 0.31 2.33 lb CO/MMBtu tpy CO 0.51 Produced Natural Gas Venting/Flaring Preliminary Analysis Emissions Summary 0.5 tpy NOX Uncontrolled/PTE 2.3 tpy CO 225.5 tpy VOC Controlled 11.3 tpy VOC Colorado Department of Public Health and Environment Air Pollution Control Division Uncontrolled Total (Ib/yr) Operator Calculation s (lb/yr) Scenario A Reportable? Controlled Total (Ib/yr) Benzene 2978 2973 Yes 149 Toluene 1396 1396 Yes 70 Ethylbenzene 278 275 Yes 14 Xylenes 218 217 No 11 n -hexane 8992 8977 Yes 450 224-TMP 2492 2488 Yes 125 Notes Permitted emissions are based on operator calculations. I have included them in this PA next to my calculations to show that they are very close and most likely only vary due to rounding conventions. Emission Factors for Permit meter installed: Uncontrolled My calcs Yes Operator calcs NOX 141.2 lb/MMscf natt CO 643.6 lb/MMscf nati VOC 62345 62247 lb/MMscf natt Benzene 411.626 411 lb/MMscf natt Toluene 192.909 193 lb/MMscf natt Ethylbenzene 38.3924 38 lb/MMscf nati Xylenes 30.1365 30 lb/MMscf natt n -Hexane 1243.03 1241 lb/MMscf nab 224-TMP 344.4411 344 lb/MMscf nab Controlled My calcs Operator calcs NOX 141.2 lb/MMscf natt CO 643.6 Ib/MMscf natt VOC 3117 3112 lb/MMscf nati Benzene 20.5813 21 lb/MMscf natt Toluene 9.6454 10 lb/MMscf nati Ethylbenzene 1.9196 2 lb/MMscf nab Xylenes 1.5068 2 lb/MMscf nati n -Hexane 62.1516 62 lb/MMscf nab 224-TMP 17.2221 17 lb/MMscf nati ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented 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 3 Part A: An APEN is required for this source because uncontrolled VOC emissions exceed one ton per year in a nonattainment area for ozone. A permit is required for this source because uncontrolled VOC emissions from this facility exceed five tons per year in an attainment area. This source is subject to Section III.D.2 (Minor Source RACT) because it is located in a nonattainment area. RACT for this source has been determined to be the use of a flare to control emissions. Part B: Public comment required? Public Comment Required 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, XVII.B.2 Facility Status This facility is a synthetic minor source of VOC/n-Hexane for Title V applicability. This facility is a synthetic minor source of VOC for NSR applicability. Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Betsy Gillard'. 357840 1/25/2017 2/15/2017 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Olt & Natural'Gas Production 8i Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? O Carbon Monoxide (CO) ❑ Particulate Matter (PM) 2 Ozone (NOx & VOC) Extraction Oil & Gas, Inc. 123 9EF3 Johnson Trust Production Facility NWSW Sec 13 T2NR68W Exploration <& Production Well Pad Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Emissions Control? Permit # Issuanc e # Self Cert Required? Action Engineering Remarks 001 Separator Venting Yes 16WE1209 1 Yes .., Permit initial issuance 002 Condensate Storage Tank; -: Yes GP01 ;_.. 003 Hydrocarbon Liquid `. Loading Yes " ' GP07 004 Produced Water Storage' Tank., �� ,.,.. Ye5'-' GP05 005 Vapor:Recovery Tower ' " (VRT) Yes 17WE0104 1 Yes Permit Initial issuance Section 03 - Description of Project Comingled gas and liquid streams from, wellheads flow to LP separators. Gas from the separators is either compressed and routed to a sales line, or routed to enclosed combustors. Sales gas routed to the enclosed combustors will be recorded by flowmeter. Liquid from the LP separators flows to a VRT, from which vapors are routed to enclosed combustors or compressed to sales pipeline. Liquid from the VRT '. is routed to condensate storage tanks. Section 04 - Public Comment Requirments Is Public Comment Required? Y If yes, why?' Requesting Syr nor Perr Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?' No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Title V Operating Permits (OP) VOC Is this stationary source a major source? Yes ?;. Produced Natural Gas Venting/Flaring Preliminary Analysis Eauioment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to an enclosed flare Colorado Department of Public Health and Environment Air Pollution Control Division Natural gas vented from Vapor Recovery Tower (VRT). When gas is not compressed into sales pipeline, it is routed to enclosed flares. 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 I 5913.0 scf/hr RequestedThroughput (Q) 2.160 MMscf/yr 246.6 scf/hr I 0.000 MMscf/d I 0.18 MMscf/mol % Vented I 4% MW 46.220 lb/Ib-mol Component mole % MW Ibx/Ibmol mass fraction E lb/hr Ib/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 0.73147 44.01 0.322 0.007 CO2 0.2 1835 0.92 N2 0.194939 28.013 0.055 0.001 N2 0.0 311 0.16 methane 7.10205 16.041 1.139 0.025 methane 0.7 6493 3.25 ethane 24.1569 30.063 7.262 0.157 ethane 4.7 41389 20.69 propane 31.9833 44.092 14.1021 0.305 propane 9.2 80371 40.19 isobutane 6.54783 58.118 3.8055 0.082 isobutane 2.5 21688 10.84 n -butane 16.1284 58.118 9.3735 0.203 n -butane 6.1 53422 26.71 isopentane 4.58625 72.114 3.3073 0.072 isopentane 2.2 18849 9.42 n -pentane 5.12836 72.114 3.6983 0.080 n -pentane 2.4 21077 10.54 cyclopentane 0.884703 70.13 0.6204 0.013 cyclopentane 0.4 3536 1.77 n -Hexane 0.8191 86.18 0.7059 0.015 n -Hexane 0.5 4023 2.01 cyclohexane 0.3187 84.16 0.2683 0.006 cyclohexane 0.2 1529 0.76 Other hexanes 0 86.18 0.0000 0.000 Other hexanes 0.0 0 0.00 heptanes 0.603744 100.21 0.6050 0.013 heptanes 0.4 3448 1.72 methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00 224-TMP 0.155733 114.23 0.1779 0.004 224-TMP 0.1 1014 0.51 Benzene 0.303955 78.12 0.2374 0.005 Benzene 0.2 1353 0.68 Toluene 0.106567 92.15 0.0982 0.002 Toluene 0.1 560 0.28 Ethylbenzene 0.0162702 106.17 0.0173 0.000 Ethylbenzene 0.0 98 0.05 Xylenes 0.01268335 106.17 0.0135 0.000 Xylenes 0.0 77 0.04' C8+ Heavies 0.2190431 187.804 0.4114 0.009 C8+ Heavies 0.3 2344 1.17 VOC mass fraction: 0.8101 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control Operator VOC Emissions (uncontrolled) Operator VOC Emissions (controlled) Notes 106.7 5.3 106.6 5.3 Mole %, MW, and mass fractions from ProMax simulation based on Pressurized Liquid Sample off of LP separators, collected 10/01/2016. Emissions are based on 8760 hours of operation per year. Requested throughput is based on maximum monthly throughput from actual production records. I calculated the average MW of C8+ based on the average MW on the analysis for the gas. Flaring Information Equipment Description Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 2603 Btu/scf Throughput 5622.48 MMBtu/yr Combustion emission factor source: 0.068 lb NOX/MMBtu tpy NOX e. AP -42: Chapter 13.5 0.31 0.87 lb CO/MMBtu tpy CO 0.19 Produced Natural Gas Venting/Flaring Preliminary Analysis Emissions Summary 0.2 tpy NOX. Uncontrolled/PTE 0.9 tpy CO 106.7 tpy VOC Controlled 5.3 tpy VOC Colorado Department of Public Health and Environment Air Pollution Control Division Uncontrolled Total (Ib/yr) Operator Calculation s (Ib/yr) Scenario A Reportable? Controlled Total (lb/yr) Benzene 1353 1341 Yes 68 Toluene 560 559 Yes 28 Ethylbenzene 98 99 No 5 Xylenes 77 76 No 4 n -hexane 4023 4018 Yes 201 224-TMP 1014 1013 Yes 51 Notes Permitted emissions are based on operator calculations. I have included them in this PA next to my calculations to show that they are very close and most likely only vary due to rounding conventions. Emission Factors for Permit meter installed: Uncontrolled NOX 177.0 Ib/MMscf natt CO 806.9 Ib/MMscf natt VOC 98791 98660 lb/MMscf natt Benzene 626.516 621 lb/MMscf nab Toluene 259.107 259 lb/MMscf natt Ethylbenzene 45.5780 46 lb/MMscf natt Xylenes 35.5301 35 lb/MMscf natt n -Hexane 1862.62 1860 lb/MMscf natt 224-TMP 469.3768 469 lb/MMscf nab My calcs Yes Operator calcs Controlled NOX 177.0 lb/MMscf natt CO 806.9 lb/MMscf natt VOC 4940 4933 lb/MMscf natt Benzene 31.3258 31 Ib/MMscf natt Toluene 12.9553 13 lb/MMscf natt Ethylbenzene 2.2789 2 Ib/MMscf natt Xylenes 1.7765 2 lb/MMscf natt n -Hexane 93.1311 93 lb/MMscf natt 224-TMP 23.4688 23 lb/MMscf natt My calcs Operator calcs ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented ral gas vented Regulatory Applicability AQCC Regulation 7 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 3 Part A: Part B: An APEN is required for this source because uncontrolled VOC emissions exceed one ton per year in a nonattainment area for ozone. A permit is required for this source because uncontrolled VOC emissions from this facility exceed five tons per year in an attainment area. This source is subject to Section III.D.2 (Minor Source RACT) because it is located in a nonattainment area. RACT for this source has been determined to be the use of a flare to control emissions. Public comment required? Public Comment Required 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, XVII.B.2 Facility Status This facility is a synthetic minor source of VOC/n-Hexane for Title V applicability. This facility is a synthetic minor source of VOC for NSR applicability. Permit number: Date issued: Issued to: Co Air Po Depart CONSTRUCTION PERMIT 16WE1209 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil a Gas, Inc. Johnson Trust Production Facility 123/9EF3 NWSW Sec1 T2N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Sales Gas Venting 001 Low pressure separators controlled by enclosed flares when not routed to the sales pipeline Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at COLORADO Air Pollution Control Division Page 1 of 8 www.colorado.gov/pacifi (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire i e owner or operator o t lie source or which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4. ) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Sales Gas Venting 001 -- -- 11.3 2.3 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Sales Gas Venting 001 Emissions from the separator are routed to an enclosed flare during sales pipeline bypass VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) COLORADO Air Pollution Control Division 'mem. Page 2 of 8 Process Limits Facility Equipment ID Al.0, Point 1P Palmier Annual Limit t s Sales Gas Venting 001 Natural Gas (Sales Gas) 7,234 MMscf Venting 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 separators to the enclosed combustors 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. 10. In the event of flowmeter maintenance, the owner or operator shall monitor and record Vapor Recovery Unit (VRU) operation and VRU downtime on a daily basis until flowmeter is restored. If the VRUs are found to be not operating, it will be assumed that downtime has occurred since the last record of VRU operation. 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 newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (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 COLORADO Air Pollution Control Division Page 3 of 8 the OftM plan are subjec rior t jnplentation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4- trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 17. 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 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. 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. COLORADO Air Pollution Control Division tr Page 4 of 8 • Whenever there or 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. 20. 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 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. 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. COLORADO Air Pollution Control Division Page 5 of 8 27. Violation of the terms of and Control Act or the r enforcement actions u - -ct penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. olorado Air Pollution Prevention administrative, civil or criminal -121 (injunctions), -122 (civil COLORADO Air Pollution Control Division Page 6 of 8 Notes to Permit Holder at the ti 1) The permit holder is requir• .ay -s = e = . s ng ti a .for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (ton/yr) Controlled Emissions (ton/yr) 001 Benzene 71432 2973 149 Toluene 108883 1396 70 Ethylbenzene 100414 275 14 n -Hexane 110543 8977 450 2,2,4- Trimethylpentane 540841 2488 125 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 ton per year (ton/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source CO -- 643.6 AP -42 VOC 62,247 3112 ProMax simulation based on pressurized sample of hydrocarbon liquid from LP separator 71432 Benzene 411 21 108883 Toluene 193 10 100414 Ethylbenzene 38 2 110543 n -Hexane 1241 62 540841 2,2,4- Trimethylpentane 344 17 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division Page 7 of 8 The emission factors listed a pressure of 43 psig. 6) In accordance with C.R.S. 2'- — .1, h - •11 • t'fhlissiorl'100tice (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: perature of 130 °F and separator Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 8 of 8 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0104 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil &t Gas, Inc. Johnson Trust Production Facility 123/9EF3 NWSW Sec1 T2N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT Natural Gas Venting 005 Vapor recovery tower (VRT) emissions controlled by enclosed flares when not routed to the sales pipeline Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at COLORADO Air Pollution Control Division Page 1 of 8 www.colorado.Rov/pacifi (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire i t e owner or operator o t lie source or which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO VRT Natural Gas Venting 005 -- -- 5.3 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT Natural Gas Venting 005 Emissions from the VRT are routed to an enclosed flare during sales pipeline bypass VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) COLORADO Air Pollution Control Division Page 2 of 8 Process Limits Facility Equipment ID AirLYJ—PAieds Point P r Annual Limit VRT Natural Gas Venting 005 Natural Gas (Sales Gas) Venting 2,16 MMscf Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the VRT to the enclosed combustors 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. 10. In the event of flowmeter maintenance, the owner or operator shall monitor and record Vapor Recovery Unit (VRU) operation and VRU downtime on a daily basis until flowmeter is restored. If the VRUs are found to be not operating, it will be assumed that downtime has occurred since the last record of VRU operation. 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 VRT covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and recordkeeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to 'COLORADO Air Pollution Control Division Page 3 of 8 the O&M plan are subjec rior jnplentation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4- trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 17. 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 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. 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. COLORADO Air Pollution Control Division Page 4 of 8 • Whenever there or 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. 20. 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 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. 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. COLORADO Air Pollution Control Division Page 5 of 8 27. Violation of the terms of per it r • the r, isio the olorado Air Pollution Prevention and Control Act or the r ns e a re ult i administrative, civil or criminal enforcement actions u - - -ct15 eme -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. COLORADO Air Pollution Control Division Page 6 of 8 Notes to Permit Holder at the ti 1) The permit holder is requiray =:s = e : = eking ti a for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (ton/yr) Controlled Emissions (ton/yr) 005 Benzene 71432 1341 67 Toluene 108883 559 28 n -Hexane 110543 4018 201 2,2,4- Trimethylpentane 540841 1013 51 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 ton per year (ton/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 005: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source V0C 98,660 4933 ProMax simulation based on pressurized sample of hydrocarbon liquid from LP separator 71432 Benzene 621 31 108883 Toluene 259 13 110543 n -Hexane 1860 93 540841 2 2 4- Trimethylpentane 469 23 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The emission factors listed above are based on modeled VRT temperature of 90 °F and VRT 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 COLORADO Air Pollution Control Division Page 7 of 8 APEN shall be submitted no l the most recent annual fee i associated with this permit. at (303)-692-3150. 7) This facility is classified as follows: Fthe iv -yea term expires. Please refer to APE a pirat n date for each emissions point g ecif piration date call the Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 8 of 8 COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 February 24, 2017 Dear Sir or Madam: On March 2, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Johnston Trust 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. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Ventingt Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit N & AIRS ID] Permit Number: Facility Equipment ID: Section 02 — Requested Action (check applicable request boxes) Section 01 — Administrative Information y ea a O CC ❑ W 0 O 3 2 0 o a. W C O F c CC G h 0. y c v .0 T F a v c .� s. -c 3 ¢ o — y v E c o - 0 € O u O L u t O a. y u o4 w .0 oL 0 V, C d a Uv, m O10 1tooICC C C c C 0 T. 'd0 V >+ 3 'K 07 0l Lm C C O 6) w '- ' C 0. w o z Q r CC z c u Lu N 3 0 °- c E v v ° < o A. U Q Z 0 0 .- fs. A 0 o �- c W a c '^ -0 Z O C C E w o" 0 N CC 0 w r s .° Q a. D a d P. U U y y a D u a 61 v = C O C a s D D ace ❑ ❑ ® ❑ ❑ ❑ w. rot 'o 3 N a et 00 'C o O U a N O U W C A Fax Number: Section 03 — General .Information V3 O O' For new or reconstructed sources, the projected startup date is: CC U ° N 8 U) T -C N T ca 'D r. O N N F 0 C CC O F 0 o a. O o C) II )4 0 O Z CC 3 6) L Cfr CD C c E 0 M CC s GC c c a 6J iA 0 0 ca 160 u r L a OA cn a 0 c m ca d O OA Cq 0 CL CC General description of equipment and purpose: z u u LW DO a C O Q A ti. C E v V E v. C U ' CC E. w A C .C a .0 efl y r4i. W VI C U 0 d U vi c 61 F = u w >-. O E .5 .G c 0 u u .0,. d y > 0 ? o L,a c 3 e p 1 O d °� -p o O = V� lO 0 eV N W. 0 i d m i.� C.)0 C) = p° vii a U all C 10.07 L' I- r 0 0 CC 0 Ooo M m 00 0 0 a O O •N 0- '7. U 5 y o N C H O Q U u c 0 7 a. fE N M N 0 C O • 01) 0 a b C 0°A .0 V 0 30 3 w Q 6 U C' c C C .0 C• CO CO a a, a a 0 ' 'C o O 0 U U C C II ®D CO CO CU E c CC CC 0 C d z° T C C 'O ca C 03 .0 ti 'G U O O 00 .0 0 E .c.79 cr 3 3c Eauinment Information Section 04 — Processin en E ou (n U ea 1- a. U o CC .o U 0 2 0- 0 C x x ' CC CC 0 to C E CO 0. 'C c. `� ,C 1- C. 'C J a aai c ce L] C U � 0.. 0 -0 U v O 8 O F tU. o i a a ^y CC c 0 "C aa.� Blowdowns: Q ❑ ® ❑ ❑ ❑ .0 0 C CC Leo aCC cc c, C7 'o 6 o o 0 c= u E k r- 0 rj C Vl C Th 0 5e 0z E go O Cr C C t7 mar 8 O n M Vented Gas Properties: O Requested level shall be a "not to exceed value N 0 0 00 e0 a, C, FORM APCD-211 .5 CC it CC 0 O 0 .23 L1 a W O a Emission Source AIRS ID: Permit Number: Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) .0 t 10 L:7 0) O 0 o N o 2 Other (Describe): Width (inches) = ❑ Horizontal LI Down • ❑ Other: Length (inches) = Vertical with obstructing raincap Direction of stack outlet (check one): Circular: Inner Diameter (inches) = Section 07 — Control Device Information 0 C 10 ® Combustion Device used for control of: Make/Model/Serial #: 4i 0O 0` Manufacturer Guaranteed: a' C) C) 0 v CK VOC & HAP Control Efficiency: 3 2 m Waste gas heat content: Pilot burner rating: O z Constant pilot light? VRU used for control of: Make/M odel: n N Requested VOC & HAP Control Efficiency: ❑ Describe Any Other: Section 08 — Emissions Inventory Information & Emission Control Information 0 00 .0 0. u 0 I- 0 d tol Cl C. z� w 3 CO 74 o� L: O F e c d 44 E C 0 0 U Oro 0 .0 d N Z d R d b � o o •� E U A 0 O0 .,i co Is. 'E e d o T % m ¢ {D Estimation Method or Emission Factor Source ProMax AP42,ProMx AP42,ProMx ProMax ProMax ProMax ProMax ProMax pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) ii - ., ; 0.07 O 0 0 0 0 0 10.22 Uncontrolled (Tons/Year) 225.1 AG tn p cry cJ t0 0 —... 0 O 0 [4.49 Actual Calendar Year Emissions4 Controlled (Tons/Year) 00 NI 1 N O O — O O co, O O co O O %0 O co Uncontrolled (Tons/Year) vii c1 O 00 ,A /o 0.37 I- o o 0 0ei 0 —4 Non -Criteria Reportable Air Pollutant Addendum form to report Emission Factor Units � .0 lb/MMBTU I lb/MMBTU 1 � .0.o. En lb/MMSCF � .n Uncontrolled Basis 62,247 s 0 0 7c I O 411 193 00 en O t",") 1241 Control Efficiency (% Reduction) e 01 e in 0+ eeee in CT III 0 1.0 0\ in 0+ Overall Collection Efficiency e © e © o 0 0 0 o 0 e 0 — Please use the APCD Control Device Description Secondary E ECD ECD ECD U W U W U W VOC xON II Benzene d H CdC d .c w d X In -Hexane Environmental Su CC CO ftS � 'C 0. C 2 c� h a) .- — p 3 I~ a 6• C) E •G CO 0 0 O %, � h as �i N r U .'EE 1 Q p R cd tiz a 'd C L C C) o b a ate. V o \ 0 E eCO O 5 t CO o'$ C6 O. �_ 0 L r.. c y et A a. H u y E p. a. a y v a. ¢ d CO .o .c �l 1 ��1 l� ° �I �a) U 9. dC C C) E v 0 3 0 C C C C, W 0 N C) td) a FORM APCD-211 2 z w ci ci w U H 0 Z z 0 v+ O w H It Z Q O I-- 8 U C v Q 0- .6 a 'al wa, J p `a--, -- c• t a. 1 Q w N� Li. V O Z 123- 1E -F3 -GO AIRS ID Number: Permit Number: Extraction Oil & Gas, Inc. Company Name: Zip Code: 80202 C O U Johnson Trust Production Facility Plant Location: Fax Number: jcarlisle@extractionog.com E-mail Address: Controlled Actual Emissions Ibs/ ear 0 Uncontrolled Actual Emissions Ibs/ ear O N co Emission Factor Source ProMax Emission Factor (Include Units) 344 Ib/MMSCF Control Equipment / Reduction (%) O) Chemical Name 2,2,4 TMP Chemical Abstract Service (CAS) Number v co Tr ill N N CO O N 0 CD CD 0 T Q Q Ily Authorized to Environmental Supervisor Q) a) J C O L ^a) LL/ `O N L L = CD U c L Cl, Vj Title of Person Legally Authorized to Supply Data Name of Person Legally Authorized to Supply Data (Please print) a -- C•1 Form Revision Date: A LL cu V2 z E V U L 0 0 a a z Q U O z z O Fes/ r'a O� a Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit 4 & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] uested Action (check applicable request boxes) Section 02 — Re Section 01— Administrative Information Request for NEW permit or newly reported emission source Y a 0 Y i O .O la 1.1 So V i a et 'r. 4) z 0 U Gc. A 0 d Change company name s 0 ❑ Transfer of ownership O O Change fuel or equipment Change permit limit ❑ ❑ Request to limit HAPs with a Federally enforceable limit on PTE Request APEN update only (check the box below that applies) 00 OO e":7) O O a) an 0 O U U z� Extraction Oil & Gas. Inc. Company Name: Johnson Trust Production Facility Source Name: O 3 C U Mailing Address: 370 17th Street, Suite 5300 N 0 00 '00 O U a. N T 0 O .> d O a V > N = u o .E Ca' on g p t o en a) p, op c W U u 01 oO'4 360 C OA y u u .E a O c >, •5 O 0. c c -. v ti o W 'to Q. N a < o 0 `° A y t00 ``d•Ty O r N 0 H O O 07, 73 r O j 1O O y C. &.'7 n E V o ❑ o � . 'O z 720-481-2372 Phone Number: Person To Contact: Josh Carlisle z Fax Number: E-mail Address: Carlisle@extractionog.com Section 03 — General Information O 0 N Ca O O 0 C 0 c to o om n E O 63 O c) 4.3 (n = O O 03 N 6-, .>"< O c � ti °z • 4.3 , O m O, r -. so. = ijU q�� e_ en 4ay w+ T q =Q ��, r..; ---- s E. 0. m nt C O� _ a0 O 'O E 1y > = W m ^� = Q ) eO. O0 xQ CA0 O53 u t m m 4)4 u E 'emu s o v m o e La O o u o= �Ea wa E °c. c G O. d C > V i = C > C V > V in ouo of met c" , A- o> V Ta E a N c O¢ = ° 3 al G"fl.'Uac v c u q H 0 � c n. w a I L)0 A .O •w c c p d .Q m s y 0 O w 0 ea Q C I. d = aa.G© 'o o - z •'E. 1) .= O Gr O Y - O C. n. Es] Ty H a.) L:—... ,eUQa0 cso. Qen -et < S 0 a) _ Cla C) h 'n d 0 0 0.3 0 F, 03 fa o. o O a a 6.3 V in u 4.3 O O u LU 00 c T43 _I ❑ 43 3 j O N 6 ❑ al r h C h ❑� O co 12, 2 C A O c v a o n z E c ('14 4.3 E o. -to La O 0 0 " o .O o o u O n. U 0o 7 • ' u H L. 0 as 1 If unable to corn Enuinment Information Section 04 — Processin d a n ., ea ta 'a V) E O v > O C yg to C C z. 0 a O A. v I)= 'y�r. ea 1-4 L1. 'O N O U y o. ,. W ' : ,V N O a) O e3 e n 3 0 a u p7 0 a❑0❑❑❑ O ;I O N E 0 � > v O ari Process Parameters: e o E 'a. 0 a, � u .it 0 X E 0 O 0 O 'o FE I- O fl 0 II 0 O e > O 00 h \O Molecular Wt. N N b ime z d a. ra AIIMEMMIDA 4) a d 0 28 ad Form APCD-2 I I -NaturalGasVentingAPEN-Ver. I 0-14-2013.docx FORM APCD-211 Vl ae L z E O U V L C 0 U w O V C. d 41. U 0 z z 0 CS) F 0 123 / 9EF3 Emission Source AIRS ID: Permit Number: Section 06 -Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) u ` 0 0 N o E eo• :: u 0 to e0 W Qq 0 c coi C U 00 0 0 O u 00 V 'CO C 93 Z a" 5E n 0 a' O. h zz M 0 3e O .' 8° ft Ew ° `" Other (Describe): ❑ Width (inches) = 0 Horizontal 0 Down D Other: Length (inches) = Vertical with obstructing raincap i a Y U s Direction of stack outlet (check one): Exhaust Opening Shape & Size (check one): Section 07 — Control Device Information Section 08 Emissions Inventory Information & Emission Control Information a O c O w a U E U 0 •O U a 0 E 41) a O CO CO V u a 0 y u .0 0 Estimation Method or Emission Factor Source 4 E CO. . 0.. 0.. a. 0. E . pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 2. v, T.. o to g A o, c E . de min c iE -8°b' de min •EE E . Uncontrolled (Tons/Year) bn O 0 g O b O N so O de min c E 'O O N Actual Calendar Year Emissions Controlled (Tons/Year) Z O Oo O C E 4 c SEEE 'C C b c 'C E E E O) E '0O Uncontrolled (Tons/Year) . T R 0 so 00 o ',..7f.„ o e 'e c 'v :5 v o Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report Emission Factor I lb VOC/MSCF jlb NOx/MMBtu] lb CO/MMBtu I.0' C7 .., lb TOL/MSCF lb EB/MSCF G, ..... {z. Uncontrolled Basis C I p McD O u^ b a N sO O vs o ae Control Efficiency (% Reduction) e C . O eo a ten a eee an Cr, , An a Overall Collection Efficiency Control Device Description Secondary < ZZZ ¢ < < z < z < z Q z ¢ z S ea E a Ci Ss) Q Z N/A w ECD ECD rV ECD Pollutant (-)%1Ox O z0 IBenzene c c F O `M L sit c x 0 g .u�+ = C -0 u 5 ra U E L 40 O -o C 0 77. z c a1 s O y' oas 3 v tat - a L 'O Y th Q - - a U I) as V C 40 d a E C V C) 16 0 w Q C. a y 00 '0 tot 0 C £ w z '77 i d zs L: 0 00 00 00 r04 I Josh Carlisle C. V 00 N 0 d O. a C 00 G0 u w 0 40 z N A ized to FormAPCD-2 I I-NaturalGasV entingAPEN-Ver. 10-1 d-2013.docx FORM APCD-211 Hello