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Home My WebLink About20163701.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 1150 0 St PO Box 758 Greeley, CO 80632 December 2, 2016 Dear Sir or Madam: On December 8, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Extraction Oil Et Gas, LLC - Janssen 8-G. 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 John W. Hickenlooper, Governor �c) b I i c RV itt.c7 (3/1 DiVa 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Larry Wolk, MD, MSPH, Executive Director and Chief Mee cc. t PLC+cn(Nei! T(3) HLCPs) I icc cH/Zm/C1') t'a(-7/(C 2016-3701 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Extraction Oil Et Gas, LLC - Janssen 8-G - Weld County Notice Period Begins: December 8, 2016 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, LLC Facility: Janssen 8-G Exploration Et Production Facility SENW Sec 8 T6N R65W Weld County The proposed project or activity is as follows: New facility producing condensate and natural gas from 12 wells. Condensate routed to 12 3 -phase separators, which routes condensate to a VRT and natural gas to VRU compressors to a sales line. VRT routes condensate to 14 fixed -roof storage tanks (Point 004) and natural gas to VRU compressors. Condensate and produced water storage tanks are controlled by a bank of enclosed flares. During VRU downtime, natural gas from the VRT is routed with the condensate to the storage tanks and then to the enclosed combustors. Condensate and produced water is unloaded via tanker trucks, and emissions from this process 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): • 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 16WE1037 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 ca�oen©o 1 Iy�� Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Betsy Gillard 352789 9/20/2016 11/9/2016 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 If yes, for what pollutant? Extraction Oil & Gas, LLC 123 9EE2 Janssen 8-G SENW Sec 8 T6N R65W ration &.Production Well Oil "&-.Natural Gas Production & P non -attainment area? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) ❑✓ Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Natural Gas RICE Yes ;% GP02 1 l , 002 Natural Gas RICE Yes „, GP02 1 003 Natural, Gas RICE Condensate Storage Tank Yes'" % „ ; Yes GP02 16WE1037 1 1 No Yes, . c, Permit Inittai Issuance 004 005 Produced Water Storage Tank Yes GP05 1 Nt Section 03 - Description of Project New facility producing condensate and natural gas from 12 wells. Condensate routed to 12 3 -phase separators, which routes condensate to a VRT and natural gas to VRU compressors (Points 001-003) to a sales line. VRT routes condensate to 14 fixed -roof storage tanks (Point 004) and natural gas to VRU compressors. Condensate and produced water storage tanks (Point 005) are controlled by a bank of six (6) enclosed flares. During VRU downtime, natural gas from the VRT is routed with the condensate to the storage tanks and then to the enclosed combustors. Condensate and produced water is unloaded via tanker trucks (Point 006), and emissions from this process are routed to the enclosed flares. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?' yes Requesting Synthetic Iyli Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? N/A 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, HAPs, n -Hexane Non -Attainment New Source Review (NANSR): VOC No ... Yes Section 05 - Emissions Inventory Condensate Storage Tank(s) Emissions Inventory Section 01- Adminstrative Information Facility AIRs ID: 133 County 9EE2 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Two (2) condensate storage tanks Description: liquid manifold. Emission Control Device SIX (6) 48- HV Enclosed Combustion Dev Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = 1022,000''. Barrels (bbl) per year 1,220,400E Barrels (bbl) per year 6,400'. Barrels (bbl) per year 4 Btu/scf scf/bbl roof400-bbi vessels connected by Actual Condensate Throughput While Emissions Controls Operating = Heat content of waste gas Volume of waste gas Volume per barrel W/VRT 2717.57 Btu/scf 0.0368747 MMSCFD 13.16954 scf/bbl W/O VRT 2675.11 Btu/scf 0.203441 MMSCFD 72.6575 scf/bbl Weighted 2713.324 Btu/scf 19.11833 scf/bbl 53,015 MMBTU per year 63,619 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 63,619 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Prornax throughput for both simuations (bbl/d) 2800 While VRUs are running (90%) During VRU Downtime (10%) Weighted EF (lb/bbl) Pollutant Actual emissions (front ProMax) EF (lb/bbl) Actual emissions (from ProMax) EF (lb/bbl) VOC 4042.989908 lb/day 1.444 21691.17007 lb/day 7.747 2.07422 Benzene 20.4398688 lb/day 0.00730 123.4858344 lb/day 0.04410 0.01098 Toluene 5.1078768 lb/day 0.00182 30.8131584 lb/day 0.01100 0.00274 Ethylbenzene 1.75816728 lb/day 0.00063 10.5264612 lb/day 0.00376 0.00094 Xylenes 0.80725104 lb/day 0.00029 4.787605416 lb/day 0.00171 0.00043 n -Hexane 62.232768 lb/day 0.02223 352.742688 lb/day 0.12598 0.03260 2,2,4-TMP 3.170148 lb/day 0.00113 18.0900936 lb/day 0.00646 0.00167 Pollutant Condensate Storage Tanks Uncontrolled E.F. (Ibs/bbl Condensate Throughput) Controlled E.F. (Ibs/bbl Condensate Throughput) Control Device Uncontrolled E.F. (lbs/MMBtu waste heat combusted) Uncontrolled E.F. (lbs/bbl Condensate Throughput) 0.0000 PM2.5 NXXXVii; 1X V ®' ,74.7*7 7*7y,N7lik.7 7 \ O 066 ®' 2.0743 =EMI\► 171&7►7 �. �'7777777777A 0.31 i. a } .: 47t►`7 . 4i7iW 0.00014 0.000047 0.000022 0.00008 0.0000 0.0035 0.0161 Emissions Factor Source Citation Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 NO4 VOC CO 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.2 2.2 2.2 1.8 1.8 1272.0 1272.0 63.6 1060.0 53.0 9.9 9.9 9.9 8.2 8.2 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 6.7E+00 6.7E+00 3.4E-01 5.6E+00 2.8E-01 1.7E+00 1.7E+00 8.4E-02 1.4E+00 7.0E-02 5.8E-01 5.8E-01 2.9E-02 4.8E-01 2.4E-02 2.6E-01 2.6E-01 1.3E-02 2.2E-01 1.1E-02 2.0E+01 2.0E+01 1.0E+00 1.7E+01 8.3E-01 1.0E+00 1.0E+00 5.1E-02 8.5E-01 4.2E-02 13466 673 3363 168 1154 58 528 26 39982 1999 2042 102 1 of 2 K:\PA\2016\ 16WE1037.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII, as provided below Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, as prc Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2, as provided be Regulation 6, Part A, NIPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? Does the company use a site specific emisions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Two different ProMax simulationswere used for the calculations -one with a VRT and one withouta VRT. Both simulations are based on the Janssen Pad pressurized liquid sample, collected by Precision on 8/30/2016. I verifiedtheaccuracy of the input and emissions for both simulations.The,liiquid coming off of the separators was at a prerssure of 36.5 prig anda temperature of 97 deg FJ. and was verified to be directly at (or very near) the bubble point by both. Precision and CARS.The VRT was modeled at a pressure of 8 pug and a temperature of 90 deg F. Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # 004 Process # 5CC Code 01 Uncontrolled Emissions Pollutant Factor PM10 0.00 PM2.5 0.00 NOx 0.08 VOC 49.4 CO 0.38 Benzene 0.26 Toluene 0.07 Ethylbenzene 0.02 Xylene 0.01 n -Hexane 0.78 224 TMP 0.04 Control % Units O lb/1,000 gallons condensate throughput O lb/1,000 gallons condensate throughput O lb/1,000 gallons condensate throughput 95 lb/1,000 gallons condensate throughput O lb/1,000 gallons condensate throughput 95 lb/1,000 gallons condensate throughput 95 lb/1,000 gallons condensate throughput 95 lb/1,000 gallons condensate throughput 95 lb/1,000 gallons condensate throughput 95 lb/1,000 gallons condensate throughput 95 lb/1,000 gallons condensate throughput 2 oft K:\PA\2016\16 W E1037.CP1.xlsm Condensate Tank Radulatory Analysis Worksheet Colorado Ra dMgn 3 Para A and B -Anal and P.M RaaYaments NON ATIAMMENT 1. Are uncontrolled emissions from any criteria 12130/2 from Mis i092idual source greater Man 1 Mr, (Regulation 3, Part ',Section II.O1.a), don date 0eraice Otte) prior .12/30/2002 ate tot modi,e9 after 12/31/2002(See n062T36 01 Definitions 1.12 320114 aM Sect ion 2 for additional guidance on grandfather appllobillty)? I Are tonsl facility uncontrolled VOC em'issbrs Horn the greater than 2 TP1, NDa greater Man 5 TW or CO emissions greater than 5TPy)Regulation 3, Part B, Section 0.O.2(, ISa Colorado Rmeebn 7.52.on AI . Is Ms storage tank located in Me 4b ozone control see on any mane non -attainment area or attainment/maintenance area? 2. Is this storage tanRlocated at an oil aM gas exploration and production operan22 natural gas comprenOrratico. natural gas drip station? 3. Is .s stooge ask located upstream of a naNral gas processing pant? Ire. NEE. toRegoletiom],Section XII,asprot,.below Swbe AI.C1 -General Peauiremenn for Nr Pollution Control Equipment -Prevention of leakage Section AI.C2- Emission Estimation Procedures Section AI.D-Emission Ceara Requirements Swan ALE - Monitoring Section ALF -ReeoN ping and Reporting Colorado debn P. gallon ALD 1. Is this wage tank located in tine g3sr ozone control area or any ozone 2onatrainmem area or attainment/maintenance area? storage located s m a rual gas processing pant? 3. Oaes naaage tank 'flrli stodM nor -stabilised liquids) emissioe aM have ummrtmlled actual emission rarer -Manor equal to 2 tors per year VOC, lIsto g nkIsnot s12un].2oRegrratk,n7,Section SILO colgpd6 emulation? sorbs ARI s tank located at a transmission/storage faculty? Is Mq modensate storage lank' located at an ail and gas eapgraton and production operation, well production hdlily2, natural gas compressor station' of natural gas processing plant? this coMewte storage tank a nwd roof storage tank] 4. Are uncontrolled actual emsslmiol this stragetadeqwl to. renter than 6 tors per year VOC? 'Storage tank it multi. to RegOatbn]salbn avlL e.C.ia C3. as provided below 5MI. Ia-General Provisions for Air pollution Control FquipMent aM Prevention 01 Emissions Serbs InALC3- Emissions Cont.,Conbd and Mori., Rwuims Sedba RNI.C3 Peardkeeping Requirements 5. Onesetank contain 312'323022aed' 'Storage ssuawto5agualwn],Section XVR.e2,asprovided below Saba lMLC1 Mere and Moritoning for Storage Tanks 5.d with Air Pdluten Control Equipment 4OCNL Part 60. Subteen Ith Standards of ...anon for V5Mlla Omen. Liquid Roam VesN. 1. Es the individual storage vessel capacity greater than or equal to n cubic meters Pr) (4]2 BBts)? 'Waage Tank it not subject to NIPS Kb CFP. Part 60, Sidman 0000, Standards of12763, mnm ter Crude., and Naha. 6s Production. Tnnamlrgn and OM,20??? ribalon 1. Was nsa s or rfied Ire inn CFR, 60.21 afar August 23, 2011? 2- DoestMls condensate... vesselmeetthe definkiannoft .. vessel•' per 60.3430?ssa scondensate s vessel located at a facility i Me ashore of and natural gas production segment, natural gas processing segment or natural gal transmission and storage segment cit. Mushy, Are potential VOC emissions' from the i2lvdual storage vessel greater than or equal to 6 tons per year? 5. tithe stage Fosse, sugwtoa, controlled in accordance with requirements for atra a vessels in 4O CFR Pon 63Srbpxt m or 00 CFR Part 63 Subpart NN? ISto on ankanot subject toNSPsotmo sacra Pan 515ubmn MALT NN. OP and Gal Predwbnfondue 1. n Me tank located at a Mat is major. for Maine 2. Is the stage tank ...el at an al and natural gas production facility that meets enter of Me folloMng criteria: a. a facility that processes, upgrades Or stores hydrocarbon liquids' 843.760420220 OR facility that treteses, upgrades or scam natural gas pd. m Me point at whits natural gas enters Me natural gas transmission and storage source cateeay cr is delivered ma final end use[ (63.]6Mal(3B? 3. Does Me tank meet the definition cif 'storage vessel.' in 63.]61? a. Oces the taM et the defrni6on U'stoage 6240042 the 50,205l lc, flash Subpart per 261? 5. Is the tank subject mmntrol requirements urder4OCFR Part 60, Subpart IN or Subpart 0000]63. 'Storage Tank is not ubpam MALT HN PACT Pa* RACT rslaw b ragukM a6agW'lon 7 des not apply AND Ilthatano h In the nonanalnmw area. Mite tank numb loth cdeda, ton rme.6ACT requkanranta Qatlaimw This dcu7ed asaisa opratorsss6MdeVrm*aq qoplk:abify dotes legiinmetdOsa Clean AO Act is impls9worq regulations. adAr °ugly CorANCatedasionre 22.00x. This docursrfu 766340'1594.4207, and OsrWyae*cottons may mf apply to e prdvhr a * bated 20207 O1a individalIrrts arddmurahrces. Thu document d?atnot charge or ad... teary law. regulation, or err' other legally bkndrgmp*mmd rd is not legallyenbreab4 In Os even drymnAs* batmen Ms language d !WS mcurlentrsd0 Ianpape the Clew Air Act, its inshmsdirq np2OOs and Air Qugty Cott. Commission npubt4m, the lefv.pe ots afehfa or regulation 441 canted. Tis usednon-mends., bnpuge such., 5esmsmtd,ney.—shout'rd oa7'u WendedbdscdsAPCD NTopre0aMam 0Mrecommembff2m. Menbtoy WmrologysWsson 'war end -required ridintended h dscribscap2Ing requirements tinder 0s tenon 01010 Chan Ai Ad end A3 Quaily Cont.Comnisson repdMOOu, bathes &C MClOOS rotm3aM'ah legally bkr Lgngs,,,. h n odd*.s* Source Requires an ADEN. Go to the neat Source Requires a Perr. S.3. e. Mem. question 11, Go to the next duesdon Source Go to. neat question Storage Tanks net Subject to Regulation ?, 1.122n XILG GO In re. gueStiOn GO. the next question SOLO ena. question sources subject t parrs of Regulate, 2, Mc.. INILEMC. Go m Me next question 1sa,dais subject to all wonslars d Regulation ], Section in 6 c image Tank is net subject MPS R0 -The storage vessel capacity isbebwto applicable trash.O. Go. the next question Storage Tanks not subject NSPS0000. Storage Tank is Dr.,. rP.Cr HH -There are no MAC, requirerren. for tanks at area sources Emissions from ProMax - With VRT Tank Flash Mass Flow 158.267 lb/hr CO 0.563764 lb/hr N2 0.0402412 lb/hr C1 0.909381 lb/hr C2 19.233 lb/hr VOC Flow 137.5206138 lb/hr 3300.494731 lb/day Tank W&B 36.6367 lb/hr 0.117597 lb/hr 0.000695 lb/hr 0.060509 lb/hr 5.5206 lb/hr 30.9373 lb/hr 742.4952 lb/day B 0.762784 lb/hr 0.088877 lb/hr T 0.19 lb/hr 0.022672 lb/hr E 0.0648876 lb/hr 0.008369 lb/hr X 0.02 lb/hr 0.002751 lb/hr 0.00271198 lb/hr 0.000331 I b/h r 0.01 lb/hr 0.001094 lb/hr X(total) 0.03 lb/hr 0.004177 lb/hr n -Hex 2.15 lb/hr 0.443112 lb/hr 2,2,4-TMP 0.110373 lb/hr 0.021717 lb/hr Total Mass Flow 194.9037 lb/hr 4677.689 lb/day CO 0.681361 lb/hr 16.35266 lb/day N2 0.040936 lb/hr 0.982461 lb/day C1 0.96989 lb/hr 23.27737 lb/day C2 24.7536 lb/hr 594.0864 lb/day VOC Flow 168.4579 lb/hr 4042.99 lb/day B 0.851661 lb/hr 20.43987 lb/day T 0.212828 lb/hr 5.107877 lb/day E 0.073257 lb/hr 1.758167 lb/day X(total) 0.033635 lb/hr 0.807251 lb/day n -Hex 2.593032 lb/hr 62.23277 lb/day 2,2,4-TMP 0.13209 lb/hr 3.170148 lb/day Emissions from ProMax - without VRT Tank Flash Tank W&B Mass Flow CO N2 C1 C2 1026.35 lb/hr 4.82829 lb/hr 1.38062 lb/hr 13.914 Ib/hr 130.69 lb/hr 33.9302 lb/hr 0.144705 lb/hr 0.003423 lb/hr 0.132939 lb/hr 5.38747 lb/hr VOC Flow 875.53709 lb/hr 28.26166 lb/hr 21012.89016 lb/day 678.2799 lb/day B 5.06045 lb/hr 0.084793 lb/hr T 1.26223 lb/hr 0.021652 lb/hr E 0.43061 lb/hr 0.007993 lb/hr X 0.107469 lb/hr 0.002627 lb/hr 0.0179974 lb/hr 0.000316 lb/hr 0.0700283 lb/hr 0.001045 lb/hr X(total) 0.20 lb/hr 0.003989 lb/hr n -Hex 14.27 lb/hr 0.422912 lb/hr 2,2,4-TMP 0.733015 lb/hr 0.020739 lb/hr Total Mass Flow 1060.28 lb/hr 25446.72 lb/day CO 4.972995 lb/hr 119.3519 lb/day N2 1.384043 lb/hr 33.21704 lb/day C1 14.04694 lb/hr 337.1265 lb/day C2 136.0775 lb/hr 3265.859 lb/day 0 0 VOC Flow 903.7988 lb/hr 21691.17 lb/day B 5.145243 lb/hr 123.4858 lb/day T 1.283882 lb/hr 30.81316 lb/day E 0.438603 lb/hr 10.52646 lb/day X(total) 0.199484 lb/hr 4.787605 lb/day n -Hex 14.69761 lb/hr 352.7427 lb/day 2,2,4 -IMP 0.753754 lb/hr 18.09009 lb/day Permit number: Date issued: Issued to: D trot Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE1037 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Extraction Oil Et Gas, LLC Janssen 8-G 123/9EE2 SENW SEC 8 T6N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Storage Tanks 004 Two (2) condensate storage tanks, each comprised of seven (7) fixed -roof 400 -bbl vessels connected by liquid manifold. Enclosed Flares This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit shall expire if the owner or operator of the source for 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 COLORADO I Air Pollution Control Division Page 1 of 8 rant extensions of the deadline. (Regulation Number 3, 3. 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.) 4. 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 5. 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 Condensate Storage Tanks 004 -- 2.2 63.6 9.9 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. 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 Condensate Storage Tanks 004 Enclosed Flares VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit Condensate Storage Tanks 004 Condensate throughput 1,226,400 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to COLORADO Air Pollution Control Division Page 3 of 8 rol requirement must be met within 90 days of the date at t o - `. n " - ces •' • - tion. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING 8 MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is required to conduct periodic testing in accordance with the most recent O&M plan approved by the Division. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. COLORADO Air Pollution Control t}ivision Page 4 of 8 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the 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. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Extraction Oil Et Gas, LLC COLORADO Air Pottution control Division of Moan Enwronivnt Page 5 of 8 No th this it issuance: 1) The permit holder is required to pay fees for the processing time 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-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 13466 673 Toluene 108883 3363 168 Ethylbenzene 100414 1154 58 Xylenes 1330207 528 26 n -Hexane 110543 39982 1999 2,2,4- Trimethylpentane 540841 2042 102 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division L .Dar n-Rr t emu- :; 4 a s E,^.+ c _'r.t nt Page 6 of 8 Point 001: it are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx -- 0.00353 AP -42 CO -- 0.01608 AP -42 VOC 2.074 0.104 Wof ProMax simulations; Pro ax sd ulaio s; 90% throughput with VRT operating, VRT throughput with RT not operating. 71432 Benzene 0.0110 0.0005 108883 Toluene 0.0027 1.4E-04 100414 Ethylbenzene 0.0009 4.7E-05 1330207 Xylene 0.0004 2.2E-05 110543 n -Hexane 0.0326 0.0016 540841 2,2,4 Trimethylpentane 0.0017 8.0E-05 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs, n -Hexane NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z COLORADO Air Pollution Control Division Page 7 of 8 • 3 I i .1 ' . S . rt 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 DT;sylment x._;12,^_ aa:h rny G't^r- t?L Page 8 of 8 y Cu F as C c Cu Ca C C U E as C O Cu U) C Cu W C CU F.r z C Z .—.--C, Permit Number: cn C C Cu F- 0 ro 0 Cn a) C a) C O U ti T Ca nested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative information D❑ O r - N w J V1 CC as (D co Zv) 06 H N O °° o 0 o i) o U C U N (A C Z Q O e x W C6 N- (I) W -, U) W M j 0 7 i Change company name Transfer of ownership ❑ ❑ Change permit limit ❑ ❑ U 3 Elevation: 4,772 N O N 03 ADEN Submittal for Permit Exempt/Grandfathered source ❑ ❑ n h Josh Carlisle O 0 O ut based on estimated annual "Actual" through Cu C Fax Number extractionog.com U) Co U CD 0 N N CD O Section 03 — General Information z zz S G` c c y d 'n N U C- C) SC n 7 C) C G Ca c` C L' ❑D v ' 0 n C 0 zzo 4, ❑ DD 2 o � � U 0 > _ S C u C L c.L' . •C T C a 7 a E> 7 y o . U e y c c .� a u E L V C v L SS •> .V .P V S 2 10 V1 C V 1 C ` (�i -2 -E. 0 v, L CM .0 LL s U .2 c w 7 z n c.`^ E c Z -_'o v t i Ca ._ v L' C` CY C) N q L .-e, 'J S -v, Q V E 5cil O. C, • . 7 - ... .L. 3 w 4.. U c O C .? 6 C) •; 7 1 O .L ... c 1-.!C07 C n L V I E•.c°EO�L E 2 r.C A S E%-, L L ..ecJ�' s E a'+Z E �_ 'IC no c ^. CL.w0. W CC C7 L�J u= E d • z 7 rn .5 t.... 7 c' c5 F . L i G C> e) la C. i, a _s ., O`o 5' 2 0 �S+ zi O 0.C V p Cu 2000 bbl/year Actual While Controls Operational: 0 0 CO Internal Floating Ito( c C _ C CD O N CD O CO O N_ CO a co O N tr) O U c O O O N N- N O J_ 0 N O J 0 7 0 Z O O O O O T 0 • 0. v r Co S O S Ce Ce S L O U) L 7' Name of Well See Addendum VPI Number aleTunk APGN-Ver. 7-29-2014 Fom APCD-2O5-Conde N 0 C) a FORM A PCD-2115 h^1 U) Emission Source AIRS ID: Permit Number: L F so CIF en 0 C C O C C C C C L C O C v i C C CC a C C u 1) COGCC DB 2 CO N CD N O -104.688277 ('7 co z 1 I) A , 0 3 ❑ O n U a 5 Q — C. L • C, Section 05 — Stack z C) y 2 '- a a a 2 C v 8 C U) u E _U C) Q) i 0 C C CO o) Z C C,'3 :J C) 2 C) Z z O z •0° C C tion 07 — ( C 2 2 c J 2I2 I S. f C) y C az > C y • C C C) N C co a) C) 0 U) US U) C U) a c 0 U A A 73 TA 0 a U) (!) U) U) m a M A U7 U) La] C) — C .. CC y C C E 44= n • -C C G a C .= O C C v '12u '- v G ▪ _ .i 7 ✓% C C J !. C x H 3 O V CC 7.3 ration proce C C C e L C C C C y O C L 0 Section Or) — Etnissi • • Emission Factor Data Source CDPHE ProMax CDPHE ProMax ProMax ProMax ProMax t n-llecone 0.03261 lbs/BBL 16.66 0.83 19.99 1.00 ProMax 2,2,-t-1rii e1h)ipentane 0.00166 lbs/BBL 0.85 0.04 0.85 0.04 ProMax ._ . urn, Air Polha,nt Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 63.60 0.34 0.07 o O 0 O Uncontrolled (Tons/Year) I N V' (O CD N CO N O (O r 0.58 0.26 Actual Calendar Year Emission'' Controlled (Tons/Year) I O CO to IN 00 O n O O N O O A - O O Uncontrolled (Tons/Year) M co co p a-- o") co (() dr 'a O N O `e ' J L:. 4. a u C .. L) C c =t 'Co C 0 > Ibs/BBL _J Ib/Ib-VOC Ibs/BBL lbs/BBL lbs/BBL Ibs/BBL y CC a a' C 0.0037 I O NO N 0.0094 0.01098 0.00274 0.00094 0.00043 ^I C ,r _ - o— D z > _ v v - , J � 4, '. r C) C C- 4) CC a - O A i 1 C C ^R 1 O T= C U G' — C v az N < L — C -gipC C ra C. C) A a C •d a. > C C 'S 7 C Cc U C C c 7 u 7 a C w C J C 71. .51 V C C 7 'C E C C C) i 7 1 z i Form APCD-2O5-CondensaieTank APEN-Ver. 7-29-2014 FORM APC1)-2115 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Extraction Oil & Gas, LLC Source Name: Janssen 8-G Emissions Source AIRS ID2: N/A / 12-2. / I � �!% Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 42355 Janssen #1 H 05 - 123 - 42359 Janssen #2 x 05 - 123 - 42360 Janssen #3 x 05 - 123 - 42366 Janssen #4 x 05 - 123 - 42362 Janssen #5 x 05 - 123 - 42356 Janssen #6 x 05 - 123 - 42361 Janssen #7 x 05 - 123 - 42357 Janssen #8 0 05 - 123 - 42364 Janssen #9 x 05 - 123 - 42358 Janssen #10 x 05 - 123 - 42363 Janssen #11 H 05 - 123 - 42365 Janssen #12 0 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 Hello