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Home My WebLink About20170765.tiffCOLORADO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 March 15, 2017 Dear Sir or Madam: On March 16, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, Inc. - Bybee 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 0. 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 Pub1►c Rvrzw 3/a1/17 RECEIVED MAR 21 2017 WELD COUNTY COMMISSIONERS 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govfcdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Cc: PLGM(Y)I TP), HLCP6 , PLO cH/ aryl c��) 3/aa/!7 2017-0765 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, Inc. - Bybee Production Facility - Weld County Notice Period Begins: March 16, 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 Et Gas, Inc. Facility: Bybee Production Facility Exploration Et Production NESE Sec. 14 T2N R68W Weld County The proposed project or activity is as follows: Comingled gas and liquid streams from seven (7) wellheads flow into two (2) HLP separators. The high pressure (HP) gas and low pressure (LP) gas from the separators is compressed into the sales tine by electric compressors. During high pressure events, HP and LP gas is routed away from the sales pipeline and to the enclosed combustors. The volume of gas routed to the flare will be measured by a flowmeter, and if the event persists for more than 30 minutes, the facility will shut in. Liquid from the HLP separators is routed to the Vapor Recovery Tower (VRT) for a another phase of separation. Gas from the VRTs is collected by the vapor recovery unit (VRU) and directed the sales pipeline. In the event of sales pipeline downtime, gas from the VRU will be routed to the enclosed combustors and the volume will be measured by flowmeter. Emissions from condensate storage tanks, produced water tanks, and loadout activites are routed to the enclosed 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): • 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 16WE1316 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 MeV COLORADO 1 M, Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Betsy Gillard 356373 12/9/2016 3/9/2017 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) ❑ Particulate Matter (PM) Extraction Oil &-Gas Inc. 123 9EFF Bybee Production Facility NESE Sec 14 T2N R68W Exploration & Production Well Pad Oil & Natural Gas. Production & Processing Section 02 - Emissions Units In Permit Application 2 Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuanc e # Self Cert Required? Engineering Remarks 001 SeparatorVerng Yes 16WE1316 1"Issuance Permit Initial 002 Vapor,Rec©vei`yTower (VRT = Yes 16WE1317 1 Yesissuance PwermitAction Initial 003 Condensate Storage Tank Yes GP01 1 �..., 004 Produced Water'Storage Tank Yes GP05 1 ...' 005Loading Hydrocarben' Liquid Yes -. GP07 1 Section 03 - Description of Project Comingled gas and liquid streams from seven (7) wellheads flow into two (2) HLP separators. The high pressure (HP) gas and low pressure (LP) gas from the separators is compressed into the sales line by electric compressors. During high pressure events, HP and. LP gas is routed away from the sales pipeline and to the enclosed combustors. The volume of gas routed to the flare will be measured by a flowmeter, and if the event persists for more than 30 minutes, the facility will shut in. Liquid from the HLP separators is routed to the Vapor Recovery Tower (VRT) for a another phase of separation. Gas from the VRTs is collected by the vapor recovery unit (VRU) and directed the sales pipeline. In the event of sales pipeline downtime, gas from the VRU will be routed to the enclosed combustors and the volume will be measured by flowmeter. Emissions from condensate storage tanks, produced water tanks, and loadout activites are Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 fit+ resting Synthetic I nor 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? No Is this stationary source a synthetic minor? Yes If yes, explain what programs and which pollutants here: Title V Operating Permits (OP) : VOC, n -Hexane Is this stationary source a major source? Produced Natural Gas Venting/Flaring Preliminary Analysis Point 001: Sales Gas Venting 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 HLP 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/Ib-mol) at 60F and 1 atm Maximum Vent Rate I 7509.0 scf/hr RequestedThroughput (Q) 1.604 MMscf/yr 183.1 scf/hr I 0.004 MMscf/d I 0.14 MMscf/mol % Vented I 2% MW 36.740 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 1.49288 44.01 0.657 0.018 CO2 0.3 2781 1.39 N2 1.45649 28.013 0.408 0.011 N2 0.2 1727 0.86 methane 31.6332 16.041 5.074 0.138 methane 2.5 21475 10.74 ethane 21.6864 30.063 6.520 0.177 ethane 3.1 27592 13.80 propane 22.0252 44.092 9.7114 0.264 propane 4.7 41100 20.55 isobutane 3.55638 58.118 2.0669 0.056 isobutane 1.0 8748 4.37 n -butane 9.84372 58.118 5.7210 0.156 n -butane 2.8 24212 12.11 isopentane 2.47401 72.114 1.7841 0.049 isopentane 0.9 7551 3.78 n -pentane 3.16897 72.114 2.2853 0.062 n -pentane 1.1 9672. 4.84 cyclopentane 0.602103 70.13 0.4223 0.011 cyclopentane 0.2 1787 0.89 n -Hexane 0.6656 86.18 0.5736 0.016 n -Hexane 0.3 2428 1.21 cyclohexane 0.1559 84.16 0.1312 0.004 cyclohexane 0.1 555 0.28 Other hexanes 0 86.18 0.0000 0.000 Other hexanes 0.0 0 0.00 heptanes 0.537277 100.21 0.5384 0.015 heptanes 0.3 2279 1.14 methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00 224-TMP 0.166474 114.23 0.1902 0.005 224-TMP 0.1 805 0.40 Benzene 0.103178 78.12 0.0806 0.002 Benzene 0.0 341 0.17 Toluene 0.079077 92.15 0.0729 0.002 Toluene 0.0 308 0.15 Ethylbenzene 0.00538423 106.17 0.0057 0.000 Ethylbenzene 0.0 24 0.01 Xylenes 0.04931232 106.17 0.0524 0.001 Xylenes 0.0 222 0.11 C8+ Heavies 0.298372186 149.242 0.4453 0.012 C8+ Heavies 0.2 1885 0.94 VOC mass fraction: 0.6554 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control Operator VOC Emissions (uncontrolled) Operator VOC Emissions (controlled) Notes 51.0 2.5 50.9 2.5 Mole %, MW, and mass fractions from ProMax simulation based on Pressurized Liquid Sample off of LP separators, collected from Bybee 14-L on 10/26/2016. Sales gas composition was determined using ProMax's reverse separator function. I am requiring a sample of the sales gas to verify V0C and HAPs content of the gas routed to the enclosed flares. emissions are oasea on uiou nours or operation per year. maximum vent rate in scrinr is oasea on me maximum montn y tnrougnput rrom actual production records. Requested permited throughput is based on the maximum monthly throughput of sales gas routed to combustors from actual production records. 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 TBD Model TBD Serial Number TBD Gas Heating Value 2057 Btu/scf Throughput 3299.428 MMBtu/yr Combustion emission factor source: 0.068 lb NOX/MMBtu tpy NOX AP -42: Chapter 13.5 0.31 0.51 lb CO/MMBtu tpy CO 0.11 Produced Natural Gas Venting/Flaring Preliminary Analysis Emissions Summary 0.1 tpy NOX Uncontrolled/PTE 0.5 tpy CO 51.0 tpy VOC Controlled 2.5 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 (Ib/yr) Benzene 341 340 Yes 17 Toluene 308 308 Yes 15 Ethylbenzene 24 24 No 1 Xylenes 222 221 No 11 n -hexane 2428 2424 Yes 121 224-TMP 805 804 Yes 40 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: Yes Uncontrolled My calcs Operator calcs NOX 140 lb/MMscf nati CO 638 lb/MMscf nah VOC 63539 63460 lb/MMscf nati Benzene 213 212 lb/MMscf natt Toluene 192 192 Ib/MMscf nati Ethylbenzene 15 15 Ib/MMscf nati Xylenes 138 138 lb/MMscf nati n -Hexane 1514 1511 lb/MMscf nati 224-TMP 502 501 lb/MMscf nati Controlled NOX 139.9 lb/MMscf nati CO 637.7 lb/MMscf nets VOC 3177 3173 lb/MMscf nati Benzene 11 11 lb/MMscf nati Toluene 10 10 lb/MMscf nati Ethylbenzene 1 1 lb/MMscf nati Xylenes 7 7 lb/MMscf nati n -Hexane 76 76 Ib/MMscf nati 224-TMP 25 25 lb/MMscf nati 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 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: 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 an enclosed 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, XVI1.B.2 Facility Status This facility is a synthetic minor source of VOC and n -Hexane for Title V applicability. This facility is a synthetic minor source of VOC for NSR applicability. 1 Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Betsy Gillard'' 356373 12/9/2016 3/9/2017 Section 01 - Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Extraction ail & Gas, Inc. • 123 9EFF Bybee Production Facility `- NESE Sec 14 T2N' R68W Exploratiion & Production E ail & Natural Gas Productioi Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application si Yes O Particulate Matter (PM) ❑� Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuanc e It Self Cert Required? Action Engineering Remarks 001 _ Separator Venting Yes. 16WE1316 1 Y '- Permit.In issuance 002 Vapor Recovery Tower (VRT) Yes 16WE1317 1 Yes ,. Fey 1Opt Initial ;! " Issuance 003 Condensate Storage Tank Yes GPO1 1 004 Produced Water Storage Tank .., .. . Yes GPOS 1 005 Hydrocarbon Liquid Loading Yes GP07 1 •,_ Section 03 - Description of Project Comingled gas and liquid streams from seven (7) wellheads flow into two (2) HLP separators. The high pressure (HP) gas and low pressure. (LP) gas from the separators is compressed into the sales line by electric compressors. During high pressure events, HP and LP gas is routed away from the sales pipeline and to the enclosed combustors. The volume of gas routed to the flare will be measured by a flowmeter, and if the event persists for more than 30 minutes, the facility will shut in. Liquid from the HLP separators is routed to the Vapor Recovery Tower (VRT) for a another phase of separation. Gas from the VRTs is collected by the vapor recovery unit(VRU) and directed the sales pipeline. In the event of sales pipeline downtime, gas from the VRU will be routed to the enclosed combustors and the volume will be measured by flowmeter. Emissions from condensate storage tanks, produced water tanks; and loadout activites are Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 questi€ig Syntheti Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 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, n -Hexane Is this stationary source a major source? N3 Produced Natural Gas Venting/Flaring Preliminary Analysis Point 002: VRT Gas Venting 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 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 4497.0 scf/hr RequestedThroughput (Q) 3.960 MMscf/yr 452.1 scf/hr I 0.000 MMscf/d I 0.34 MMscf/mot % Vented I 10% MW 46.690 Ib/Ib-mol Component mole % MW lbxllbmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 C02 0.890811 44.01 0.392 0.008 C02 0.5 4096 2.05 N2 0.177044 28.013 0.050 0.001 N2 0.1 518 0.26 methane 8.98367 16.041 1.441 0.031 methane 1.7 15057 7.53 ethane 19.9369 30.063 5.994 0.128 ethane 7.1 62625 31.31 propane 32.9767 $44.092 14.5401 0.311 propane 17.3 151923 75.96 isobutane 6.12756 58.118 3.5612 0.076 isobutane 4.2 37210 18.60 n -butane 17.2865 58.118 10.0466 0.215 n -butane 12.0 104972 52.49 isopentane 4.29037 72.114 3.0940 0.066 isopentane 3.7 32327 16.16 n -pentane 5.39388 72.114 3.8897 0.083 n -pentane 4.6 40642 20.32 cyclopentane 0.969571 70.13 0.6800 0.015 cyclopentane 0.8 7105 3.55 n -Hexane 1.0294 86.18 0.8871 0.019 n -Hexane 1.1 9269 4.63 cyclohexane 0.2432 84.16 0.2047 0.004 cyclohexane 0.2 2139 1.07 Other hexanes 0 86.18 0.0000 0.000 Other hexanes 0.0 0 0.00 heptanes 0.746029 100.21 0.7476 0.016 heptanes 0.9 7811 3.91 methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00 224-TMP 0.236103 114.23 0.2697 0.006 224-TMP 0.3 2818 1.41 Benzene 0.164381 78.12 0.1284 0.003 Benzene 0.2 1342 0.67 Toluene 0.112688 92.15 0.1038 0.002 Toluene 0.1 1085 0.54 Ethylbenzene 0.00683996 106.17 0.0073 0.000 Ethylbenzene 0.0 76 0.04 Xylenes 0.06228224 106.17 0.0661 0.001 Xylenes 0.1 691 0.35 C8+ Heavies 0.365998405 160.480 0.5874 0.013 C8+ Heavies 0.7 6137 3.07 VOC mass fraction: 0.8313 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control Operator VOC Emissions (uncontrolled) Operator VOC Emissions (controlled) Notes 202.8 10.1 202.5 10.1 Mole %, MW, and mass fractions from ProMax simulation based on Pressurized Liquid Sample off of LP separators, collected from Bybee 14-L on 10/26/2016. VRT gas composition was determined using ProMax. I am requiring a sample of the sales gas to verify VOC and HAPs content of the gas routed to the enclosed flares. production records. Requested permited throughput is based on the maximum monthly throughput of sales gas routed to combustors from actual production records. MW of C8+ based on the average MW on the analysis for the gas. Flaring Information Equipment Description Flare to combust VRT gas when gas is not routed to sales line. Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 2624 Btu/scf Throughput 10391.04 MMBtu/yr Combustion emission factor source: 0.068 lb NOX/MMBtu tpy NOX AP -42: Chapter 13.5 0.31 1.61 lb CO/MMBtu tpy CO 0.35 Produced Natural Gas Venting/Flaring Preliminary Analysis Emissions Summary 0.4 tpy NOX Uncontrolled/PTE 1.6 tpy CO 202.8 tpy VOC Controlled 10.1 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 (Ib/yr) Benzene 1342 1338 Yes 67 Toluene 1085 1085 Yes 54 Ethylbenzene 76 75 No 4 Xylenes 691 689 Yes 35 n -hexane 9269 9258 Yes 463 224-TMP 2818 2816 Yes 141 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 178.4 lb/MMscf natt CO 813.4 lb/MMscf natt VOC 102411 102280 lb/MMscf natt Benzene 339 338 lb/MMscf Hatt Toluene 274 274 lb/MMscf nab Ethylbenzene 19 19 Ib/MMscf natt Xylenes 174 $ 174 lb/MMscf natt n -Hexane 2341 2338 lb/MMscf natt 224-TMP 712 711 lb/MMscf natt My calcs Yes Operator calcs Controlle NOX 178.4 lb/MMscf natt CO 813.4 lb/MMscf natt VOC 5121 5114 lb/MMscf natt Benzene 16.9412 17 lb/MMscf natt Toluene 13.6995 14 lb/MMscf nett Ethylbenzene 0.9580 1 lb/MMscf natt Xylenes 8.7236 9 Ib/MMscf nett n -Hexane 117.0354 117 lb/MMscf nett 224-TMP 35.5805 36 lb/MMscf nab 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 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 #REF! Part A: Part B: 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, XVI1.B.2 Facility Status This facility is a synthetic minor source of VOC and 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 16WE1316 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, Inc. Bybee Production Facility 123/9EFF NESE Sec14 T2N R68W Weld County Well Production Facility I 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 irrtrfr Page 1 of 8 www.colorado.gov/pacifi .. -/. r . rmit j cer fi atiori (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire t t e owner or operator o t e 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 I I I. 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 NOX VOC CO Sales Gas Venting 001 -- -- 2.5 -- 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 foie 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 Potluticrn Cantrol Di nsion *+ ^.! P.;;µ'}. d is :^^ c rr*nt Page 2 of 8 Process Limits Facility Equipment ID AI Point P P Annual Limit r Sales Gas Venting 001 Natural Gas (Sales Gas) 1.604 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 thel 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 Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEtM) 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 OZtM plan are subjec • si;i rov [ %rior plerientation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAM `G 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 observatigns 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. • Whenever there is a change in the owner or operator of any facility, process, or activity; or COLORADO Air Pollution Control Division Page 4 of 8 • Whenever new c• trot . u ► u t is n alle wh ever a different type of control equipment repla• s an i n yp- . ntr a uip nt; 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. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal COLORADO Air Pollution Control Division Page 5 of 8 enforcement actions un. penalties), -122.1 (crimin By: Betsy Gillard Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil a Gas, Inc. i • s • -7-1 (enfc�c ment ti . ), R. -121 (injunctions), -122 (civil N [`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 w 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 i Pollutant CAS # Uncontrolled Emissions (ton/yr) Controlled Emissions (ton/yr) 001 Benzene 71432 340 17 Toluene 108883 308 15 n -Hexane 110543 2424 121 2,2,4- Trimethylpentane 540841 804 40 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 VOC 63.460 3,173 ProMax simulation based on pressurized sample of hydrocarbon liquid from LP separator 71432 Benzene 212 11 108883 Toluene 192 10 110543 n -Hexane 1511 76 540841 2 2 4- Trimethylpentane 501 25 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 separator temperature of 132 °F and separator pressure of 42 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: -yea term expires. Please refer to pirat n date for each emissions point ecif piration date call the Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division i:" :s r at rain +ya h 'rr, S Page 8 of 8 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 16WE1317 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Ft Gas, Inc. Bybee Production Facility 123/9EFF NESE Sec14 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 Gas Venting 002 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.gov/pacifi .. -/, r . rmit ;3 cer fi afiori (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire i t e owner or operator o t e 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: a Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO VRT Natural Gas Venting 002 -- -- 10.1 1.6 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 002 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 A Point 1-4c44 Palmier Annual Limit VRT Natural Gas Venting 002 Gas Vented from VRT to Enclosed Flare 3.96 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 property. 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 0&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 tOis 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 penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer rmit Histo olorado Air Pollution Prevention administrative, civil or criminal -121 (injunctions), -122 (civil Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, Inc. COLORADO Air Pollution Control Division Page 6 of 8 Notes to Permit Holder at the ti 1) The permit holder is requiray seer he ec. ng ti r 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) 002 Benzene 71432 1338 67 Toluene 108883 1085 52 Xylenes 1130207 689 35 n -Hexane 110543 9258 463 2,2,4- Trimethylpentane 540841 2816 141 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 002: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source VOC 102,280 5,114 ProMax simulation based on pressurized sample of hydrocarbon liquid from LP separator CO 813.4 813.4 71432 Benzene 338 17 108883 Toluene 274 14 1130207 Xylenes 174 9 110543 n -Hexane 2338 117 540841 2,2,4-Trimethylpentane 711 36 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. COLORADO Air Pollution Control Division Page 7 of 8 6) In accordance with C.R.S. 25- 114 , : c it P. l ant Sion otice (APEN) associated with this permit is valid for a term as r eived by the Division. A revised APEN shall be submitted no - an .. - -for- e -ye rm expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane 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 4 co Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01 — Administrative Information Request for NEW permit or newly reported emission source Request MODIFICATION to existing permit (check each box below that applies) Change company name aJ O O Transfer of ownership ❑ ❑ Change fuel or equipment Change permit limit ❑ ❑ 7 N O 00 O U 00 0 u� Request to limit HAPs with a Federally enforceable limit on PTE a. c eer CO O .0 .0 co u r co CO O CO c W Q 0) e Q O U 0. N 0 u C C O T u o co v c• .� o .y E w a L 0 .o C O N s N d 0 0 CO t >,3 E c Y c CO z U N A 0. Q o A h o } E c v, V 0) .0 N > -a 00 � a v ❑ ❑ CO L z Fax Number: 0 O N C O CO c u U x E 2 L ,L o O H s `1 CJ 0 m C E0 0 O • of u O v L C. = s A 00 aJ E 00 0 • c o 3 4 C = Section 03 — General Information ,42 O For new or reconstructed sources, the projected startup date is: 09 For existing sources. operation began on: aJ T 4.1 3 Normal Hours of Source Operation: General description of equipment and purpose: 0 ° t— Of Cr.Lo E „ r, f• f., r, Oa C 0- C o t — - os C1,0 N ar E W U aJ " E_-_. _ C no 46 ca 0, • •> CO C A t.E aW A .ti E y C .4 u > > A r 65 t Z Q C V L aJ �° w • 2 A 3 v Y S a' u E d •= r ,_ o T O a s 5 u L O V = e7 = (/1 e E 77, o ; ar v s ,,., u o co E 4 al L M CO• ©a`- 0, C al If' 0 0 01 0 Y • �, o E Q Teel U o . L N o Q E a_ V000 y� D CC op. p 0 C? i'. `o 0 c c `„ o V) u U O • 0 0 y 10 V1 .C` U c ` i a c-, aJ • ._ =cc., o C • a 0 m o For M ▪ M M 4.1 0 0 o a 0 • 0 eJ a Q a 0 0] en 0:-- E 00 CO o 00 o O E 0 a O 'b' V 6 A 3 7..,-7, ..g.' c. U H s c aJ y o .E E N L 7 7 ,O CC' o _ A Z a Q cn Application status:http://www.colorado.gov/cdphe/permitstatus C 0 0 Q Y ❑ O z r C CO E C CO CO C 0 rn zE > 'C 3 c CC v y CO a L 13 V U a > 0 00 4.1 .0 0 A 4.1 E° a0 • a3 - a. 3 Section 04 — Processing Equipment Information V a U 00 CO TJ O 0 G i X Y O elp c CO E N E Ft.; U D -p U CO co C CO o E y CO CJ 0 a U CO C. ce 0 N a E 0 U 0 00 Slowdowns: ❑®❑❑❑ 0 C1 .c O u o G T E c�- 00 e O ce a) u o E C 0 O t -E O, 00 O 0 C7 a O 0 u ce u N C E M Q > o M Molecular Wt. N M Vented Gas Properties: U CJ O c C U A CO O V1 � a O O • n a � E n a 0 v 'v 0 0 0 0 a a U U 0 Bybee Natural-Gas-Venting-APEN-Sales Gas W Cr) FORM APCD-211 N Emission Source AIRS ID: Permit Number: Location (Datum & either Lat/Long or UTM) Source, if no combustion Section 05 — Stack ri Y _ 0 0 N C • E L E. cot l V r Y o ea m ro !] 0 o c 'D 0 vi o 0- z • o A W DD 0 0 U O 00 O 0 N V -104.966306 000 C] h obstructing raincap let (check one): Width (inches) = Circular: Inner Diameter (inches) _ Exhaust Opening Shape & Size (check one): Section 07 — Control Device Information Section 08 — Emissions Inventory Information & Emission Control Information 0 r- N Y 0 CC R 0 0 0 .0 0 0 E E ▪ R Z9 W Y Q< R u N R_ O R C �• E R c 0 a 0 V C O a •y Y y t C • C C co C .� c C A • E ▪ E ▪ u To. U C 0 O `J N 6i. E V � T g L � A Q Estimation Method or Emission Factor Source ProMax x ! 0 o L 4 ProMax x 0 0 L 4 pollutants not listed above. I Requested Permitted Emissions Controlled (Tons/Year) t N e E V :J e E Y L e E 0 'J Uncontrolled (Tons/Year) 50.9 t- O u. O N Actual Calendar Year Emissions4 Controlled (Tons/Year) utw ap E • ulw ap E Uncontrolled (Tons/Year) !, o r .. e E Y •O e E d • v o lPlease use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report Emission Factor Units U L L a h 2 2 L 7 Ib/M MSCF Uncontrolled Basis 0 'V Ni 212 N - V, Control Efficiency (% Reduction) I's.' Cr; o V, e C o V'. Overall Collection Efficiency . O 0 o o O e 0 O 73'9- 0 0 Control Device Description Secondary Q i C z Q z < z C co 0. C] U W ECD ECD C U W Pollutant VOC xOf4 I O x p IBenzene IToulene V c V c D T ti] I Xylene V C A u Z C formation contained herein and information submitted with this application is complete, true and correct. C) EHSR Mana Josh Carlisle N 3 N Name of Legally Authorized Person (Please print) ed to Supply Dat 0 T Bybee Natural-Gas-Ventine-APEN-Sales Gas N O 0 N 6) CD to 0. FORM APCD-211 Cr� V O R z E Or O 4.0 h 0 Co) 0 414 z QI AIR POLLUTANT EMISSION NOTICE U_ N Source AIRS ID: E [Leave blank unless APCD has already assigned a permit tl & AIRS ID] rn Permit Number: [Provide Facility Equipment TD to identify how this equipment is referenced within your organization.] Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01 — Administrative Information Request for NEW permit or newly reported emission source Request MODIFICATION to existing permit (check each box below that applies) Change company name L. .O ❑ Transfer of ownership C E d a CO V L C ❑ ❑ 7. 9 ca ti t 3 a S .E O u ❑ ❑ C: Change fuel or equipment Change permit limit Request APEN update only (check the box below that applies) ®❑ OO CL '0 ON on+ 3 N O O 4i T C y O C/) O 0 O U U o > U U U a. Z (7 W N O U d C G O a y E E a 0 N C u 0 E r W v, .y >- E CC U N U . O a 0 ❑ ❑ as is combusted in lieu of the sales line durin A conservative 10% of VRT z CS.. E-mail Address: ulations. Flowmeter Section 03 — General Information N a For new or reconstructed sources, the projected startup date is: z Ci C) C) C O N L E 0 V C) O C d C CO 0 C) E V 000 L c c u �u O Y y 3 a 00 N .0 ul y C 3 c y u T � m Q N • N T a E V g O ur g F^ N > c O CO C c ,o o a C) CO O cL O C O U C/) V L O O H N 7 c o •_ S A v E `o � z General description of equipment and purpose: O Li ' _ - 0o v, a y w _ 7. r WV `..0 c4M f? OD y N N IN cn o, ac�c. C y c o 0 o a i. co E.E a C .o 0 > 0D y CM z 6)E y Jrz,v Cl.) a a CO 6,5 s y < 7m Cn V v• < v,C N L 3 aci u S E o vL. E d Y s v 'o >` 0 C. =V 6" y 00 CC .... E C' c O. Cl) n 20 0. 0 E y o > U . © d O V V > ≤O C y 0 G M V > C 3 eg,CE O -o .,0 f o f y 3 > U 6.1 L N .O 0 Q G j. f. 7 E 0._ CI .0 Eon s v° O �4 m O u 0.� E 13 A� C) c o. CO o „ U C wr O y 'p C) L ` -O 7 a) VO O iO • Lr O U d .‘.2C = o U O + O70 C. CO CL) C. Ca) �[CO �7i�'. n ° o` Ea. [- 0 ...Li' V C Cr. Q VJ Q C 0 o O z o CO C) E C O CO 0 Cl) V Q� Q E C CC C2 CO o a> O O .00 O G CCCO 7) n U • a ment Information Section 04 — Processing Egui C • 0 a Y CYca L C CO C) U o` CO 0) 00 G C V a 'O u CO CO E O • al O U nu w n L O O 'O y o C) C CO ` C X .a' En ° = y 7 E v a) n C7 a U Blowdowns: ❑ ❑ ❑ ❑ ❑ r 0 N N V X e 4--"E M °)L N E N p 00 N a Process Parameters: c 7 Fo E CU mE N r Bybee Natural-Gas-Venting-APEN O OD yu O E 7 u V 0 A U � 0 C Rc F N C 0 "Z"-) CC c� X X c- L O C u —Vi o. T � c i 0 FORM APCD-211 C C9 L z rr E a O z O U es O z a. U C C c.) F Q1 Emission Source AIRS ID: 123 / Permit Number: Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Stack Information (Combustion stacks must be listed here) i 4 l0 0 E r of 03 ".-3 0 °o 'D O VJ a- t o I- Gr] bD 0 00 e Other (Describe): 8 u vo 0D u O C 'D M :. _-0 '0 et) .C O v 9 I o z L Width (inches) = ❑ Horizontal ❑ Down ❑ Other: Length (inches) = c U 0 O 3 Direction of stack outlet (check one): Device Information Section 07 — Contr C3 2 m Make/Model/Serial #: 0 C) Y C c o ) .0 E 0 00 a Manufacturer Guaranteed: C' Make/Model: C 0 U v _ N. n• 61i > Cn U C GU O C U a U 0 > .n C) _ 0 m 2 Waste gas heat content: Annual time that VRU is bypassed (emissions vented): Pilot burner rating: Constant pilot light? The VRU recycles venting emissions to: O Describe Any Other: cf fi of of nformation & Emission Control Information Section 08 — Emissions Inventory 0 N O .0 C C L O 0 c 0 E L R z� Gfl Y • T. < N R • 7 o R L C O � R u E O v 0 U C o f, E • R C O A c R. 0 -73 O e, UV ` C 2 O y G1: u .2 T y E s Estimation Method or Emission Factor Source ProMax N T 1 ) { a lC 0. Requested Permitted Emissions Controlled (Tons/Year) ^ 0 '.9 — M eN 0 o Tt 0 0 re' — M N O C. ,t3YZSl Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Uncontrolled (Tons/Year) 202.5 t.._9 5 ..S1V1 0 T Cf ti)T s M O el 0 Actual Calendar Year Emissions° Controlled (Tons/Year) ,40o o E CO 0 Uncontrolled (Tons/Year) O r 'O co 0_ O CE O c d c In c1 S Emission Factor Units Ib/MMSCF .r 5 1 U. V C) J �1 ,, v_. N .OZ Ib/MMSCF Uncontrolled Basis 102,280 Ln 0 o 60 cc. M T CT C.4St T 2,338 Control Efficiency (% Reduction) O C a Q Z o^ d• In o '.n O o a Overall Collection Efficiency e 0 0 V/N 0 0 o - a _ e o Control Device Description Secondary V/N z z Primary ' c C.4Z Q v t il n a v ECD Pollutant 0 >zr-) 0 0 0 u)m Cl N Toulene I u u L. Gil Xylene J Cl x z c Josh Carlisle Name of Legally Authorized Person (Please print) � u c. R 0 y C 7 O 2 0 0 . w E O U V 0. R .O d E 7 h O R E C.. L O O • N E o 0 N CO C W CA O Bybee Natural-Gas-Venting-APEN w O N 000 O FORM APCD-211 Hello