HomeMy WebLinkAbout20210292.tiffCOLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
January 20, 2021
Dear Sir or Madam:
RECEIVED
JAN 2 5 2021
WELD COUNTY
COMMISSIONERS
On January 21, 2021, the Air Pollution Control Division will begin a 30 -day public notice period for
Mallard Exploration, LLC - Anderson/Shull Production Facility. A copy of this public notice and the
public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor 1 Jill Hunsaker Ryan, MPH, Executive Director
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Cc*. f I..(TP)( Mt-On/TR), pti(ER/JM/GH IC t4))
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01/27/21
2021-0292
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Mallard Exploration, LLC - Anderson/Shull Production Facility - Weld County
Notice Period Begins: January 21, 2021
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: Mallard Exploration, LLC
Facility: Anderson/Shull Production Facility
Oil and gas production facility
SESW, Section 31, T9N, R59W
Weld County
The proposed project or activity is as follows: Applicant proposes to add new equipment associated with
production from fifteen (15) newly producing wells. Equipment includes storage tanks, hydrocarbon liquid
loadout, and combustion of produced gas when gas is unable to be collected by on -site vapor recovery
equipment.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permits 20WE0809, 20WE0810,
20WE0811, 20WE0812, 20WE0813, 20WE0814, 20WE0815, and 20WE0816 have been filed with the Weld
County Clerk's office. A copy of the draft permits and the Division's analyses 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. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Bradley Eades
Colorado Department of Public Health and Environment
COLORADO
Department of Public
Health B Enuimnment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
2I
COLORADO
Department of Public
Health ft Environment
C• r
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0809
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
Mallard Exploration, LLC
Anderson/Shull Production Facility
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Anderson
CNDTK
007
Five (5) 500 barrel fixed roof condensate
storage vessels connected via liquid
manifold. These tanks are associated with
production from "Anderson" wells.
Emissions from the
storage vessels are
routed to a sales
pipeline through the
use of a vapor
recovery unit (VRU).
During VRU
downtime, emissions
are routed to
enclosed
combustor(s).
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.
Page 1 of 11
COLORADO
Air Pollution Control Division
Department of PubItc Heatth b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section IILG.2.)
3. This permit must 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
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section I I I. F.4. )
4. The operator must 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 must 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 must 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
Anderson
CNDTK
007
---
---
19.04
3.42
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 must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
Page 2 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must 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 owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
9. The emission points in the table below must 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
Anderson
CNDTK
007
Emissions from the storage vessels are
routed to a sales pipeline through the use
of a vapor recovery unit (VRU). During VRU
downtime, emissions are routed to enclosed
combustor(s).
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must 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.)
Page 3 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Anderson
CNDTK
007
Total condensate throughput
1,993,460 barrels
Condensate throughput during VRU
downtime.
607,748 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the condensate storage vessels are routed to the
enclosed combustor(s). The total hours of VRU downtime, total condensate throughput volume
and total condensate throughput volume during VRU downtime shall be recorded on a monthly
basis. The owner or operator must use monthly VRU downtime records, monthly condensate
throughput volume records, and the calculation methods established in the Notes to Permit
Holder to demonstrate compliance with the process and emission limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for 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, Part D, Section I.C.) (State only enforceable)
15. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.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 II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
Page 4 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 schedule in Regulation Number 7,
Part D, Section II.B.2.d.
16. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must 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
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
17. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
18. The storage tanks covered by this permit are subject to the storage tank measurement system
requirements of Regulation Number 7, Part D, Section II.C.4.
19. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING I* MAINTENANCE REQUIREMENTS
20. Upon startup of these points, the owner or operator must 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
the OEtM 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
21. The owner or operator must complete site specific sampling including a compositional analysis
of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for
emission factor development, a sales oil analysis to determine RVP and API gravity. Testing
must be in accordance with the guidance contained in PS Memo 14-03. Results of testing must
be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants
using Division approved methods. Results of site -specific sampling and analysis must be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point, as reflected in the "Notes to
Permit Holder".
Page 5 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. The owner or operator must 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, Part D, Sections II.B.2. and II.A.23)
Periodic Testing Requirements
23. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
24. A revised Air Pollutant Emission Notice (APEN) must 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 (NO.) 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.
25. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
Page 6 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
26. 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.
27. 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.
28. This permit is issued in reliance upon the accuracy and completenessof 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.
29. 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.
30. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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.
31. 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.
32. 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:
Page 7 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration, LLC
Synthetic minor permit for new equipment at an
existing source.
Page 8 of 11
r
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 must 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)
007
Benzene
71432
5,702
87
Toluene
108883
4,235
65
Ethylbenzene
100414
552
8
Xylenes
1330207
865
13
n -Hexane
110543
41,279
629
2'2'4
Trimethylpentane
540841
2,186
33
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.
Page 9 of 11
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
When
Emissions
are routed
to the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
NOx
2.4 x 10"3
---
2.4 x 10"3
AP -42
Chapter
13.5
CO
1.1 x 10-3
---
1.1 x 10-3
VOC
1.2308
---
0.0615
ProMax
71432
Benzene
2.9 x 10-3
---
1.4 x 10"4
108883
Toluene
2.1 x 10"3
---
1.1 x`10"4
100414
Ethylbenzene
2.8 x 10.4
---
1.4 x 10-5
1330207
Xylene
4.3 x 10-4
--
2.2 x 10-5
110543
n -Hexane
0.0207
---
1.0 x 10-3
540841
2'2'4
Trimethylpentane
1.1 x 10"3
--
5.5 x 10.5
Note: The controlled emissions factors for this point are based on a control efficiency of 100% when
emissions are routed to the VRU and a control efficiency of 95% when emissions are routed to the
enclosed combustor(s). The site specific emission factors for this source were developed using a
site specific pressurized liquid sample in conjunction with ProMax. Uncontrolled actual VOC and
HAP emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput. Controlled actual VOC and HAP emissions are calculated by multiplying
uncontrolled emissions by a 100% control efficiency when emissions are routed to the VRU and a
95% control. efficiency when emissions are routed to the enclosed combustor(s) (i.e. during VRU
downtime). The emission factors in AP -42 Chapter 13.5 for NOx and CO (0.068 lb/MMBtu and 0.31
lb/MMBtu respectively) were converted to units of lb/bbl using a gas to oil ratio (GOR) of 14.8
scf/bbl and a heat content of 2,324 Btu/scf as estimated using ProMax. Actual NOx and CO
emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput during VRU downtime.
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 must 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:
Page 10 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
NANSR
Synthetic Minor Source of: VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http: //www.ecfr.Rov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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
63.898O -End
Subpart NNNNN - Subpart )O(X)O(X
Page 11 of 11
AIM
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0810
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
Mallard Exploration, LLC
Anderson/Shull Production Facility
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Shull CNDTK
008
Five (5) 500 barrel fixed roof condensate
storage vessels connected via liquid
manifold. These tanks are associated with
production from "Shull" wells.
Emissions from the
storage vessels are
routed to a sales
pipeline through the
use of a vapor
recovery unit (VRU).
During VRU
downtime, emissions
are routed to
enclosed
combustor(s).
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.
Page 1 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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.Rov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section 111.G.2.)
3. This permit must 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
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section I I I. F.4. )
4. The operator must 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 must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit atone doesnot provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must 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
Shull CNDTK
008
---
---
17.97
3.24
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 must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
Page 2 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must 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 owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
9. The emission points in the table below must 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
Shull CNDTK
008
Emissions from the storage vessels are
routed to a sales pipeline through the use
of a vapor recovery unit (VRU). During VRU
downtime, emissions are routed to enclosed
combustor(s).
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must 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.)
Page 3 of 11
C.✓4�:M1
i:�V'd. . Ntal
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Shull CNDTK
008
Total condensate throughput
1,099,340 barrels
Condensate throughput during VRU
downtime.
567,613 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the condensate storage vessels are routed to the
enclosed combustor(s). The total hours of VRU downtime, total condensate throughput volume
and total condensate throughput volume during VRU downtime shall be recorded on a monthly
basis. The owner or operator must use monthly VRU downtime records, monthly condensate
throughput volume records, and the calculation methods established in the Notes to Permit
Holder to demonstrate compliance with the process and emission limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section I I I. E. ) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for 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, Part D, Section I.C.) (State only enforceable)
15. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.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 II, it must be
enclosed; have no visible emissions daring normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
Page 4 of 11
C.Ml�fY Ntme
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 schedule in Regulation Number 7,
Part D, Section II.B.2.d.
16. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must 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
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
17. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
18. The storage tanks covered by this permit are subject to the storage tank measurement system
requirements of Regulation Number 7, Part D, Section II.C.4.
19. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
20. Upon startup of these points, the owner or operator must 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
the OItM 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
21. The owner or operator must complete site specific sampling including a compositional analysis
of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for
emission factor development, a sales oil analysis to determine RVP and API gravity. Testing
must be in accordance with the guidance contained in PS Memo 14-03. Results of testing must
be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants
using Division approved methods. Results of site -specific sampling and analysis must be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point, as reflected in the "Notes to
Permit Holder".
Page 5 of 11
nos --
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. The owner or operator must 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, Part D, Sections II.B.2. and II.A.23)
Periodic Testing Requirements
23. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
24. A revised Air Pollutant Emission Notice (APEN) must 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 (NO,t) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t 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.
25. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
Page 6 of 11
4.40": -:-
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
26. 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.
27. 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.
28. 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.
29. 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.
30. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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.
31. 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.
32. 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.
Page 7 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
By:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration, LLC
Synthetic minor permit for new equipment at an
existing source.
Page 8 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 must 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
(lb/yr)
Controlled
Emissions
(lb/yr)
008
Benzene
71432
3,161
82
Toluene
108883
2,348
61
Ethylbenzene
100414
306
8
Xylenes
1330207
480
12
n -Hexane
110543
22,956
593
2,2,4-
Trimethylpentane
540841
1,214
31
ote: 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.
Page 9 of 11
COLORADO
Air Pollution Control Division
Department of Riblic Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
When
Emissions
are routed
to the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
NOx
2.4 x 10-3
---
2.4 x 10"3
AP -42
Chapter
13.5
CO
1.1 x 10-3
---
1.1 x 10-3
VOC
1.2421
---
0.0621
ProMax
71432
Benzene
2.9 x 10-3
---
1.4 x 10"4
108883
Toluene
2.1 x 10-3
--
1.1 x 10-4
100414
Ethylbenzene
2.8 x 10-4
---
1.4 x 10'5
1330207
Xylene
4.4 x 10-4
---
2.2 x 10-5
110543
n -Hexane
0.0209
---
1.0 x 10-3
540841
Trimethylpentane
1.1 x 10-3
---
5.5 x 10-5
Note: The controlled emissions factors for this point are based on a control efficiency of 100% when
emissions are routed to the VRU and a control efficiency of 95% when emissions are routed to the
enclosed combustor(s). The site specific emission factors for this source were developed using a
site specific pressurized liquid sample in conjunction with ProMax. Uncontrolled actual VOC and
HAP emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput. Controlled actual VOC and HAP emissions are calculated by multiplying
uncontrolled emissions by a 100% control efficiency when emissions are routed to the VRU and a
95% control efficiency when emissions are routed to the enclosed combustor(s) (i.e. during VRU
downtime). The emission factors in AP -42 Chapter 13.5 for NOx and CO (0.068 lb/MMBtu and 0.31
lb/MMBtu respectively) were converted to units of lb/bbl using a gas to oil ratio (GOR) of 14.9
scf/bbl and a heat content of 2,347 Btu/scf as estimated using ProMax. Actual NOx and CO
emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput, during VRU downtime.
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 must 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:
Page 10 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
NANSR
Synthetic Minor Source of: VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http: //www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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 X00000(
Page 11 of 11
COLORADO
Air Pollution Control Division
Department of Public Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0811
Date issued:
Issuance: 1
Issued to: Mallard Exploration, LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Anderson/Shull Production Facility
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Anderson
PWTK
009
Five (5) 500 barrel fixed roof produced
water storage vessels connected via liquid
manifold. These tanks are associated with
production from "Anderson" wells.
Emissions from the
storage vessels are
routed to a sales
pipeline through the
use of a vapor
recovery unit (VRU).
During VRU
downtime, emissions
are routed to
enclosed
combustor(s).
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.
Page 1 of 10
4.:Y�rr
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
0
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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.Rov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit must 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; (ill') does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
4. The operator must 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 must 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 -
b. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section I I.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS-
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Anderson
PWTK
009
---
---
0.21
0.10
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 must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must 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 owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
9. The emission points in the table below must 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.)
EqFacilityuipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Anderson
PWTK
009
Emissions from the storage vessels are
routed to a sales pipeline through the use
of a vapor recovery unit (VRU). During VRU
downtime, emissions are routed to enclosed
combustor(s).
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must 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.)
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Anderson
PWTK
009
Total produced water throughput
1,503,786 barrels
produced water throughput during VRU
downtime.
782,924 barrels
The owner or operator must monitor monthly process ratesbased on the calendar month.
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the produced water storage vessels are routed
to the enclosed combustor(s). The total hours of VRU downtime, total produced water
throughput volume and total produced water throughput volume during VRU downtime shall be
recorded on a monthly basis. The owner or operator must use monthly VRU downtime records,
monthly produced water throughput volume records, and the calculation methods established
in the Notes to Permit Holder to demonstrate compliance with the process and emission limits
specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section IILE.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for 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, Part D, Section I.C.) (State only enforceable)
15. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.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 II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7,
Part D, Section II.B.2.d.
16. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must 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
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
17. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
18. The storage tanks covered by this permit are subject to the storage tank measurement system
requirements of Regulation Number 7, Part D, Section II.'C.4.
19. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
20. Upon startup of these points, the owner or operator must 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
the OEtM 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
21. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
22. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 5 of 10
C. t
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
23. A revised Air Pollutant Emission Notice (APEN) must 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 (NO„) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
24. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS
25. 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.
26. 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
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
27. 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 specificallyidentified on the permit.
28. 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.
29. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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.
30. 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.
31. 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:
Bradley Eades
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration, LLC
Synthetic minor permit for new equipment at an
existing source.
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 must 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
(lb/yr)
Controlled
Emissions
(lb/yr)
009
Benzene ''
71432
325
8
Toluene
108883
145
4
Ethylbenzene
100414
9
<1
Xylenes
1330207
15
<1
n -Hexane
110543
210
5
Note: All non -criteria reportable pol utants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Controlled
Emission
Controlled
Uncontrolled
Factors
Emission
CAS #
Pollutant
Emission
Factors
(lb/bbl)
When
Emissions
are routed
to the VRU
Factors
During VRU
Downtime
(lb/bbl)
Source
(lb/bbl)
N0x
5.4 x 10-5
---
5.4 x 10-5
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
When
Emissions
are routed
to the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
AP -42
Chapter
13.5
CO
2.5 x 10-4
---
2.5 x 10-4
VOC
0.0104
5.2 x 10-4
Flash
Liberation
Analysis
(sampled
7/22/20)
71432
Benzene
2.2 x 10-4
---
1.1 x 10-5
Note: The controlled emissions factors for this point are based on a control efficiency of 100% when
emissions are routed to the VRU and a control efficiency of 95% when emissions are routed to the
enclosed combustor(s). The site specific emission factors for this source were developed using a
site specific pressurized liquid sample in conjunction with flash liberation analysis. Uncontrolled
actual VOC and HAP emissions are calculated by multiplying the emission factors in the table
above by the total produced water throughput. Controlled actual VOC and HAP emissions are
calculated by multiplying uncontrolled emissions by a 100% control efficiency when emissions are
routed to the VRU and a 95% control efficiency when emissions are routed to the enclosed
combustor(s) (i.e. during VRU downtime). The emission factors in AP -42 Chapter 13.5 for NOx
and CO (0.0681b/MMBtu and 0.31 lb/MMBtu respectively) were converted to units of lb/bbl using
a gas to oil ratio (GWR) of 0.6 scf/bbl and a heat content of 1336 Btu/scf as measured in the
flash liberation anlaysis. Actual NOx and CO emissions are calculated by multiplying the emission
factors in the table above by the total produced water throughput during VRU downtime.
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 must 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 pointassociated 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.
Page 9 of 10
AIM
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
NANSR
Synthetic Minor Source of: VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ -Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart X 0000(
Page 10 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0812
Issuance: 1
Date issued:
Issued to: Mallard Exploration, LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Anderson/Shull Production Facility ,
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Shull PWTK
010
('5)
wateFiver stora500ge vesselsbarrelfixed connectedroofproduced via liquid
manifold. These tanks are associated with
production from "Shull" wells.
Emissions from the
storage vessels are
routed to a sales
Pipeline through the
use of a vapor
recovery unit (VRU).
During VRU
downtime, emissions
are routed to
enclosed
combustor(s).
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.
Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1.
YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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.Rov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit must 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
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section I II. F.4.)
4. The operator must 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 must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit atone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section I I.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Shull PWTK
010
---
---
0.10
0.04
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 must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
Page 2 of 10
C44,0
Ntal
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must 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 owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
9. The emission points in the table below must 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
Shull PWTK
010
Emissions from the storage vessels are
routed to a sales pipeline through the use
of a vapor recovery unit (VRU). During VRU
downtime, emissions are routed to enclosed
combustor(s).
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must 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.)
Page 3 of 10
Ntagif
..
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Shull PWTK
010
Total produced water throughput
631,308 barrels
Produced water throughput during VRU
downtime.
370,939 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the produced water storage vessels are routed
to the enclosed combustor(s). The total hours of VRU downtime, total produced water
throughput volume and total produced water throughput volume during VRU downtime shall be
recorded on a monthly basis. The owner or operator must use monthly VRU downtime records,
monthly produced water throughput volume records, and the calculation methods established
in the Notes to Permit Holder to demonstrate compliance with the process and emission limits
specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for 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, Part D, Section I.C.) (State only enforceable)
15. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II. 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 II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7,
Part D, Section II.B.2.d.
16. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must 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
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
17. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
18. The storage tanks covered by this permit are subject to the storage tank measurement system
requirements of Regulation Number 7, Part D, Section II.C.4.
19. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved, report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
20. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (O8LM) 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 OEtM 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
21. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
22. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
23. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
•
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment' replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
No later than 30 days before the existing APEN expires.
24. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS
25. 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.
26. 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
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
27. 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 operators agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
28. 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.
29. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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.
30. 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:
31. 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:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration, LLC
Synthetic minor permit for new equipment at an
existing source.
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 formmust 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 must 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
(lb/yr)
Controlled
Emissions
(lb/yr)
010
Benzene
71432
136
4
Toluene
108883
61
2
Ethylbenzene
100414
4
<1
Xylenes
1330207
6
<1
n -Hexane
110543
88
3
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/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:
Controlled
Emission
Controlled
Uncontrolled
Factors
Emission
CAS #
Pollutant
Emission
Factors
(lb/bbl)
When
Emissions
are routed
to the VRU
Factors
During VRU
Downtime
(lb/bbl)
Source
(lb/bbl)
NOx
4.6 x 10-5
---
4.6 x 10-5
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
When
Emissions
are routed
to the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
AP -42
Chapter
13.5
CO
2.1 x 10'
---
2.1 x 10'
VOC
0.0104
--
5.2 x 10'
Flash
Liberation
Analysis
(sampled
7/22/20)
Note: The controlled emissions factors for this point are based on a control efficiency of 100% when
emissions are routed to the VRU and a control efficiency of 95% when emissions are routed to the
enclosed combustor(s). The site specific emission factors for this source were developed using a
site specific pressurized liquid sample in conjunction with flash liberation analysis. Uncontrolled
actual VOC and HAP emissions are calculated by multiplying the emission factors in the table
above by the total produced water throughput. Controlled actual VOC and HAP emissions are
calculated by multiplying uncontrolled emissions by a 100% control efficiency when emissions are
routed to the VRU and a 95% control efficiency when emissions are routed to the enclosed
combustor(s) (i.e. during VRU downtime). The `emission factors in AP -42 Chapter 13.5 for NOx
and CO (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively)' were converted to units of lb/bbl using
a gas to oil ratio (GWR) of 0.6 scf/bbl and a heat content of 1336 Btu/scf as measured in the
flash liberation anlaysis. Actual NOx and CO emissions are calculated by multiplying the emission
factors in the table above by the total produced water throughput during VRU downtime.
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 must 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.
Page 9 of 1O
COLORADO
Air Pollution Control Division
Department of Public Health El Enwonment
Dedicated to protecting and improving the health and environment of the people of Colorado
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
NANSR
Synthetic Minor Source of: VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources<
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart X 0000(
Page 10 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0813
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
Mallard Exploration, LLC
Anderson/Shull Production Facility
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Anderson
LOADOUT
011
Truck loadout of condensate by
submerged fill. This loading operation
is associated with production from
"Anderson" wells.
Enclosed combustor(s)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission' and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days
after commencement of operation under this permit by submitting a Notice of Startup
(NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division
of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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
Page 1 of 10
a44 -
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must 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 completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must 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 must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
0.4
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Anderson
LOADOUT
011
---
---
0.55
0.09
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 must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants must 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 must
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 owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
7. The owner or operator must track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must be
made available to the Division for inspection upon request. For the purposes of this condition,
insignificant activities are defined as any activity or equipment, which emits any amount but
does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3,
Part C. I I. E. )
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
8. The emission points in the table below must 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
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
Anderson
LOADOUT
011
Enclosed combustor
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part
B, Section II.A.4)
Process/Consumption Limits
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Anderson
LOADOUT
011
Condensate Loaded
92,057 barrels
The owner or operator must calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits must 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 must calculate throughput eachmonth and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution
control equipment. Compliance with Section II.C.5. must be achieved in accordance with the
following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal
to 5,000 barrels per year on a rolling 12 -month basis must control emissions from
loadout upon exceeding the loadout threshold.
13. Storage tanks must operate without venting at all times during loadout. (Regulation Number
7, Part D, Section II.C.5.a.(ii))
14. The owner or operator must, as applicable (Regulation Number 7, Part D, Section
II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport
vehicles and to route the vapors to the storage tank or air pollution control
equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless
loadout occurs less frequently, then as often as loadout is occurring.
15. The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
Page 4 of 10
C41
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect
the facility within 24 hours after loadout to confirm that all storage tank thief hatches
(or other access point to the tank) are closed and latched.
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
that includes, at a minimum, operating procedures for each type of loadout control
system.
16. The owner or operator must retain the records required by Regulation Number 7, Part D,
Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division
upon request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution,
required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
17. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing
plant in Colorado must submit a single annual report that includes actual emissions and
specified information in the Division -approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING & MAINTENANCE REQUIREMENTS
19. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (OEtM) plan and record keeping format approved by the Division, in order to
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your OEtM 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
20. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
21. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
22. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section I I . 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 (NO.) 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.
For any non -criteria reportable pollutant:
If the emissions increase by 509 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
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
23. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
GENERAL TERMS AND CONDITIONS
24. 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.
25. 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.
26. 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.
27. 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.
28. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
29. 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.
30. 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:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration, LLC
Synthetic minor permit for new equipment at an
existing source.
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 must 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: rLys: v .., ,70tOrad i CC le: , c-rerz
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) ,
011
Benzene
71432
38
2
n -Hexane
110543
331
17
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
NOx
4.2 x 10'
4.2 x 10-4
AP -42 Chapter
13.5
CO
1.9 x10-3
1.9 x 10-3
VOC
0.2360
0.0118
APCD PS MEMO
14-02
n -Hexane
110543
3.60 x 10-3
1.8 x 10-4
Page 9 of 10
COLORADO
Air Pollution Control Division
Department of Pubttc Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: Controlled emission factors are based on a 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 must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
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://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A'- Subpart UUUU
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 X00000(
Page 10 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0814
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
Mallard Exploration, LLC
Anderson/Shull Production Facility
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Shull
LOADOUT
012
Truck loadout of condensate by
submerged fill. This loading operation
is associated with production from
"Shull" welts.
Enclosed combustor(s)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days
after commencement of operation under this permit by submitting a Notice of Startup
(NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division
of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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
Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must 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 completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must 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 must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
Shull LOADOUT
012
---
---
0.32
0.06
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 must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants must 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 must
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 owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
7. The owner or operator must track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must be
made available to the Division for inspection upon request. For the purposes of this condition,
insignificant activities are defined as any activity or equipment, which emits any amount but
does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3,
Part C. I I . E. )
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
8. The emission points in the table below must 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.)
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
Shull
LOADOUT
012
Enclosed combustor
VOC and HAP
PROCESS LIMITATIONS AND RECORDS"
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part
B, Section II.A.4)
Process/Consumption Limits
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Shull
LOADOUT
012
Condensate Loaded
54,095 barrels
The owner or operator must calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits must 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 must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
Page 3 of 10
.4%0
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.1. a 4.)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution
control equipment. Compliance with Section II.C.5. must be achieved in accordance with the
following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
Facilities constructed before May 1, 2020, must be in compliance by May 1 2021.
Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal
to 5,000 barrels per year on a rolling 12 -month basis must control emissions from
loadout upon exceeding the loadout threshold.
13. Storage tanks must operate without venting at all times during loadout. (Regulation Number
7,Part D, Section II.C.5.a.(ll))
14. The owner or operator must, as applicable (Regulation Number, 7, Part D, Section
II.C.5.a.(iii))
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport
vehicles and to route the vapors to the storage tank or air pollution control
equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless
loadout occurs less frequently, then as often as loadout is occurring.
15. The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect
the facility within 24 hours after loadout to confirm that all storage tank thief hatches
(or other access point to the tank) are closed and latched.
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
that includes, at a minimum, operating procedures for each type of loadout control
system.
16. The owner or operator must retain the records required by Regulation Number 7, Part D,
Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division
upon request.
Records of the annual facility hydrocarbon ;liquids loadout to transport vehicles
throughput.
Inspections, including a description of any problems found and their resolution,
required under Sections' II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
Records of the infeasibility „of observation of loadout.
Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
17. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing
plant in Colorado must submit a single annual report that includes actual emissions and
specified information in the Division -approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
19. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (OItM) plan and record keeping format approved by the Division, in order to
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your OEtM 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
20. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
21. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
22. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3 Part A,
Section 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 (NO.) 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.
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
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
23. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
GENERAL TERMS AND CONDITIONS
24. 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.
25. 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 locatedin the Requirements to Self -Certify for Final Authorization section
of this permit.
26. 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.
27. 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.
28. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
29. 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.
30. 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.
Bv:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration, LLC
Synthetic minor permit for new equipment at an
existing source.
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 must 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 r=aps:, 1 r. /coloracl .g,o, p ci`=c:' a Yy "aqc- r �
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)
012
Benzene
71432
22
1
n -Hexane
110543
195
10
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/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:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
N0x
4.2 x 104
4.2 x 104
AP -42 Chapter
13.5
CO
1.9 x 10-3
1.9 x 10"3
V0C
0.2360
0.0118
APCD PS MEMO
14-02
Note: Controlled emission factors are based on a flare control efficiency of 95%.
Page 9 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
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://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart X O0O0(
Page 10 of 10
COLORADO
Air Pollution Control Division
Department of Pubtic Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
20WE0815 Issuance: 1
Mallard Exploration, LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Anderson/Shull Production Facility
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point'
Equipment Description
Emissions Control
Description
Anderson
Bulk
Separator
013
Gas venting from low pressure separators
(bulk separators) during vapor recovery
unit (VRU) downtime. This point is for gas
vented from bulk separators associated
with the "Anderson" wells.
Enclosed combustor(s)
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 (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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 -
Page 1 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must 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 completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must 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 must 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 must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
Anderson Bulk
Separator
013
---
---
2.36
---
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 must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
Page 2 of 11
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
50 tons per year of VOC
9. The emission points in the table below must 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.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Anderson
Bulk '
Separator
013
Emissions from the bulk separators are
routed to Enclosed combustor(s) during
Vapor Recovery Unit (VRU) downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Anderson
Bulk
Separator
013
Gas vented from the low pressure
"bulk separators" to the enclosed
combustor(s)
1.44 MMSCF
Compliance with the annual throughput limits must 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
Page 3 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. The owner or operator must continuously monitor and record the volumetric flow rate of gas
vented from the bulk separator(s) to the enclosed combustor(s) using a flow meter. The flow
meter must be calibrated and maintained per the manufacturer's specifications and schedule.
The owner or operator must use monthly throughput records to demonstrate compliance with
the process limits contained in this permit and to calculate emissions as described in this
permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
13. This sourceis subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. The combustion device covered by this permit is ;subject to ;Regulation Number 7, Part D,
Section II. 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 II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A23; 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 schedule in Regulation Number 7,
Part D, Section II. B.2.d.
15. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. 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 commencement of operation 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.
16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
Page 4 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
OPERATING £t MAINTENANCE REQUIREMENTS
17. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. The owner/operator must 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 content (weight fraction) of this emission stream. Results of the
Analysis must 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 must 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 must submit
to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for
permit modification to address these inaccuracies.
19. The owner or operator must 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, Part D, Sections 11.8.2. and II.A.23)
Periodic Testing Requirements
20. On an annual basis, the owner/operator must complete a site specific extended gas analysis
("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC
content (weight fraction) of this emission stream. Results of the Analysis must 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 must be used
to demonstrate that the emissions factor established through the Analysis is less than or equal
to, the emission factor 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 factor submitted with the
permit application and established in the "Notes to Permit Holder" the operator must 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).
Page 5 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice (APEN) must 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 (NO.) in ozone
nonattainment areas emitting less than 100 tons of V0C 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 levet 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.
22. Federal regulatory program requirements (i.e. PSD, NANSR) must 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 must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
Page 6 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 9 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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..
25.
This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conductof 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.
26. 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.
27. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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.
28. 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.
Page 7 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
29. 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:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration,+LLC
New synthetic minor permit for new equipment
at existing facility.
Page 8 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 must 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 sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Anderson
Bulk
Separator
013
Benzene
71432
203
10
Toluene
108883
150
8
Ethylbenzene
100414
17
2
Xylenes
1330207
34
2
n -Hexane
110543
1,786
89
2,2,4-
Trimethylpentane
540841
1
<1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 11
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Fraction
(%)
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
VOC
66.8
65,376.70
3,268.84
Extended Gas
Analysis
110543
n -Hexane
1.27
1,240.46
62.02
Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control
efficiency of 95%. The VOC and HAP emission factors listed above are based on a site -specific
extended gas analysis obtained from the bulk separator at the Anderson facility on 07/22/2020.
The weight % values and molecular weight (37.1 lb/lbmol) from the sample along with the
displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter
10) were used to determine the emission factors. Actual emissions are calculated by multiplying
the emission factors in the table above by the total metered low pressure gas vented from the
bulk separators and routed to the enclosed combustor(s).
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 must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
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 following website: http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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
Page 10 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 X0(X)CX
Page 11 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
20WE0816 Issuance: 1
Mallard Exploration, LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Anderson/Shull Production Facility
123/9FED
SESW SEC 31 T9N R59W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Shull Bulk
Separator
014
Gas venting from low pressure separators
(bulk separators) during vapor recovery
unit (VRU) downtime. This point is for gas
vented from bulk separators associated
with the "Shull" wells.
Enclosed combustor(s)
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 (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, 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 must 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 -
Page 1 of 11
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
certify compliance as required by this permit may be obtained online at
www.colorado.Rov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must 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 completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must 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 must 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 must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
Shull Bulk
Separator
014
---
---
3.14
---
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 must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
Page 2 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
9. The emission points in the table below must 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.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Shull Bulk
Separator
014
Emissions from the bulk separators are
routed to Enclosed combustor(s) during
Vapor Recovery Unit (VRU) downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Shull Bulk
Separator
014
Gas vented from the low pressure
"bulk separators" to the enclosed
combustor(s)
1.92 MMSCF
Compliance with the annual throughput limits must 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
Page 3 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
11. The owner or operator must continuously monitor and record the volumetric flow rate of gas
vented from the bulk separator(s) to the enclosed combustor(s) using a flow meter. The flow
meter must be calibrated and maintained per the manufacturer's specifications and schedule.
The owner or operator must use monthly throughput records to demonstrate compliance with
the process limits contained in this permit and to calculate emissions as described in this
permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III. E. ) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. The combustion device covered by this permit is subject to Regulation Number, 7, Part D,
Section I I. 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 1, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; 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 schedule in Regulation! Number 7,
Part D, Section II.B.2.d.
15. The separator covered by this permit is subject to Regulation 7, Part D, Section II. F. 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 commencement of operation 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.
16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
Page 4 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
OPERATING Et MAINTENANCE REQUIREMENTS
17. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the OEtM 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
18. The owner/operator must 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 gas vented from a bulk separator associated with
this emissions point in order to verify the VOC content (weight fraction) of this emission
stream. Results of the Analysis must be used to calculate site -specific emission factors for
VOC (in units of lb/MMSCF gas vented) using Division approved methods. Results of the
Analysis must be submitted to the Division as part of the self -certification and must
demonstrate the emissions factor established through the Analysis is less than or equal to, the
emissions factor submitted with the permit application and established herein in the "Notes
to Permit Holder" for this emissions point. If the site -specific emissions factor developed
through this Analysis is greater than the emissions factor submitted with the permit
application and established in the "Notes to Permit Holder" the operator must 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 inaccuracy.
19. The owner or operator must 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, Part D, Sections 11.8.2. and II.A.23)
Periodic Testing Requirements
20. On an annual basis, the owner/operator must complete a site specific extended gas analysis
("Analysis') of the natural gas vented from this emissions unit in order to verify the VOC
content (weight fraction) of this emission stream. Results of the Analysis must 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 must be used
to demonstrate that the emissions factor established through the Analysis is less than or equal
to, the emission factor 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 factor submitted with the
permit application and established in the "Notes to Permit Holder" the operator must 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).
Page 5 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Whenever there is a change, in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
22. Federal regulatory program requirements (i.e. PSD, NANSR) must 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 must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
Page 6 of 11
o;.Y�rr
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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.
25. 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 operators agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
26. 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.
27. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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.
28. 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.
Page 7 of 11
tagi
C
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
29. 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:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Mallard Exploration, LLC
New synthetic minor permit for new equipment
at existing facility.
Page 8 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit 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 must 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 must 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 sources operates at the permitted
limitations.
Equipment '
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Shull Bulk
Separator
014
Benzene
71432
271
14
Toluene
108883
200
10
Ethylbenzene
100414
23
1
Xylenes
1330207
45
2
n -Hexane
110543
2382
119
2,2,4-
Trimethylpentane
540841
2
<1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 11
Ctor r
turf
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Weight
Fraction
(�)
Uncontrolled
Emission
Factors
(Ib/MMSCF)
Controlled
Emission
Factors
(Ib/MMSCF)
Source
VOC
66.8
65, 376.70
3,268.84
Extended Gas
Analysis
71432
benzene
0.14
141.23
7.06
110543
n -Hexane
1.27
1,240.46
62.02
Note:
The controlled emissions factors for this point are based on the enclosed combustor(s) control
efficiency of 95%. The VOC and HAP emission factors listed above are based on a site -specific
extended gas analysis obtained from the bulk separator at the Anderson facility on 07/22/2020.
The weight % values and molecular weight (37.1 lb/lbmol) from the sample along with the
displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter
10) were used to determine the emission factors. Actual emissions are calculated by multiplying
the emission factors in the table above by the total metered low pressure gas vented from the
bulk separators and routed to the enclosed combustor(s).
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 must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
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 following website: http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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
Page 10 of 11
a„,
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
Bradley Eades
436D17
9/28/2020
12/3/2020
Section 01- Facility Information
Company Name: Mallard Exploration, LLC
County AIRS ID: .123
Plant AIRS ID: .9FED
Facility Name: Anderson/Shull Facility
Physical
Address/Location:
County:
Type of Facility: jExploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant?
Weld County
Section 02- Emissions Units In Permit Application
Leave Blank- For Division Use Only
AIRS Point #
(Leave blank unless APCD
has already assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
007
_
Storage Tank
Anderson Condensate Tanks
.Yes
20WE0809
`
1
Yes
-
-
Permit Initial
Issuance
" -.
_
-
Anderson
008
Storage Tank
Shull Condensate Tanks
.'Yes
20WE0810
Shull -
009
Storage Tank
Anderson PW Tanks
"" Yes
20WE0811
Anderson PW
.010
-
Storage Tank
Shull PW Tanks
- "Yes
20WE0812
Shull PW
011
Liquid Loading
Y.
Anderson Loadout...
'-Yes -
20WE0813.;.
Anderson
012
Liquid Loading
Shull Loadout
Yes
20WE0814
Shull
013
Separator Venting
Anderson Venting
- Yes
20WE0815
Anderson
014
Separator Venting
-
Shull Venting
Yes
20WE0816
Shull
015
- NatuzeLfas RICE
- '
Anderson VRU Como, Erg,
Yes ..
GP02
' r?
- N d
GP .
Ole
-
h.atf.ltar,:.os ftIGE
..
Shull 4RU Cams. EngAy
Yes
` GP02
NA -
iglu -
GP -..
.
Yes
Ozone (NOx & VOC)
Quadrant' Section Township
31
SESW
9N
Range
59
Section 03 - Description of Project
This project is requesting a. permit to authorize new equipment associated with fifteen (15) newly producingwells and two (2) existing wells. Of the 15 wells, nine (9) are
associated with the Anderson production train and eight (8) are associated with the Shull production train. That is, there are separate production trains that process fluids from
the respective groups of wells that operate separately (no shared equipment) but are collated at the same surface site and are therefore the same stationary source for purposes
of source agreegation. -
It should further be noted that this facility previously included permitted equipment which has all been removed from the facility (per email received 9/29/20). The two (2)
existing wells previously produced to surface equipment permitted at the "Anderson Facility", ail of which has been removed.This facility is currently (i.e. prior to issuance of this
permit) a synthetic minor source authorized by GP10. This permit will include new synthetic minor limits for VOC with respect to Nonattainment New Source Review (NANSR)
and as such will require Public Notice prior to issuance. -
The APEN. indicates that the .Anderson . and Shull wells: began producing to new equipment in July 2020.
Sections 04, 05 & 06- For Division Use Only
Section 04- Public Comment Requirements
Is Public Comment Required? Yes -
If yes, why? 'Requesting Synthetic Minar Permit _;
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No '
If yes, for what pollutants? �' _ _
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a. true minor? - -
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants: SO2 NOx
Prevention Significant Deterioration (MD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
'ftd
Yes'
O n
'
C PMPM1SP
C 2.5 n F0 T
J
J
HAPs
111 J1
Is this stationary source a major source? No -
If yes, indicate programs and which pollutants: 502
Prevention of Significant Deterioration(PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
N
NOx
_
CO
VOC
_
PM2.5
t —7
■
PM10
TSP HAPs
C
L ■
Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
Facility AIRS ID:
123
County
9FED
Plant
007
Point
Section 02 - Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit Five (5) 500 barrel fixed roof condensate storage vessels connected via liquid manifold.
Description:
Emission Control Device Emissions are commingled with produced water tank vapors (Point 009) and compressed to sales line via vapor recovery unit
Description: (VRU). During VRU downtime, tank vapors are routed to enclosed combustors (ECDs).
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter Liquid Throuft0t _ s
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Total (Process 01+Process 02)
Actual Throughput =
'Requested Permit Limit Throughput=
1,812,237 Barrels (bbl) per year
1,993,460 Barrels (bhl) per year
Requested Monthly Throughput= 169307.6 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput = 1,993,460 Barrels (hbl) per year
% Process 01:
% Process 02:
Process 01(Emissions routed to VRU)
Actual Throughput =
'Requested Permit Limit Throughput=
Requested VOC & HAP Control Efficiency %:
Process 02 (Emissions routed to ECDs)
Actual Throughput =
'Requested Permit Limit Throughput =
Requested VOC & HAP Control Efficiency %:
Secondary Emissions from Process 02 - Combustion of Emissions
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 =
Requested heat content of waste gas routed to combustion device =
69.5 %
1,259,738 Barrels (hbl) per year
1,385,712 Barrels (bbl) per year
100 %
552,498 Barrels (bbl) per year
607,748 Barrels (bbl) per year
95 %
Btu/scf
14.9 scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
Requested Monthly Throughput = 1175590.6 Barrels (bbl) per month
Requested Monthly Throughput= 51517.0 Barrels (bbl) per month
19,133.7 MM BTU per year
21,0471 MM BTU per year
21,047.1 MMBTU per year
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
50 scfh
2324 Btu/scf
0.4 MMscf/yr
1017.9 MMBTU/yr
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
` `�. , F S;: Process 01
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(Ib/bbi) (1b/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
1.2308
3.0000
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (Includes flash)
Site Specific E.F. (includes flash)
f<e Specific E.F. (includes flash)
rtg.Specific E.F. (includes flash)
Benzene
0.0029
0.0000
Toluene
0.0021
0.0000
Ethylbenzene
0.0003 -
5.0000
Xylene
0.0004
0.0000
n -Hexane
0.0207
0-0000
224 TMP
0.0011
r, 1000
... Process 02 c -
Emission Factors
Conden ate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
( Throughput)
( Throughput)
VOC
1.2308
0.0615
Site Specific E.F. (includes flash).,.
'Site Specific F.S. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific EP, flash)
Site Specific E.F. (Includes f3asfr}
Site Specific E.F. (includes flash)
Benzene
2.9E-03
1.4E-04
Toluene
2.1E-03
1.1E-04
Ethylbenzene
2.8E-04
1,4E-05
Xylene
4.3E-04
2,2E-05
n -Hexane
0.0207
1.0E-03
224 TMP
1.1E-03
5.5E-05
C:\Users\ bPaile"§tDesktop\Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage Tank(s) Emissions inventor;)
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
( Throughput)
PM10
, 0:0075
;.;i"?,
AP -42 Tattle 1.4-2(PM10/PM 2
AP -42 Table 1.4-2 (PM10/PM.2 5) ' _ -
PM2.5
0.0075
0.0003
SOx
0.0030
AP -42 Table 1.4-2 (PM10/PM.2.5)'�
AP -42 Chapter 13.5 Industrial Flares -
AP -42 Chapter 13.5 Industrial Flare:,
NOx
0.0680
0.0024
CO
>0.3100 _
0.0107
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(ib/MMBtu) (Ib/MMscf)
(Pilot Gas Heat
Combusted)
(Pilot Gas
Throughput)
PM10
0.0075
17.3161
AP -42 Table 1.4-2 (PM10/PN1.2.5)
AP -42 Table 1.4-2 (PMSO/PM.2.5)
AP -42 Table 1.4-2 (SOx)'.
AP -42 Chapter 13.5 Industrial Flares (N04)
Other -Explain
AP -42 Chapter 13.5 industrial Flares (CO) ,_„
PM2.5
0.0075
17.3161
SOx
0.0006
1.3671
NOx
0.0680
158.0320
VOC
0:6600
1533.8400
CO
0.3300
720.448-0
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.1
0.1
0.1
0.1
0.1
14.73
0.1
0.1
0.1
0.1
0.1
14.0
v.v
0.0
0.0
0.0
0.0
0.1
0.8
0.69
0.69
0.8
0.750
127.4
1226.3
1115.59
17.34
1226.78
19.036
3233.6
s'.4
3.12
3:12
3.4
3.420
550.9
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
5702
5184
79
5702
87
4235
38"s0
59
4235
65
552
502
8
552
8
865
787
12
865
13
4'1279
37627
572
41279
629
2186
1987
30
2186
33
CAUsers\b3ade" ADesktop\Remote Work \My Packages\Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage Tank(s) Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, 8
Source requires a permit
Regulation 7, Part D,Section LC, D, E, F
Storage team_ is subject to Regulation 7, Part D, Section.I.C-F
Regulation 7, Part D,Section I.G, C
Storage Tank is not subject to Regulation 7, Section `.ss
Regulation 7, Part D,Section II.B, C.1, C.3
Storage tank is subject to Regulation 7, Part D, Section 7i, 0, C.1 & C.3
Regulation 7, Part D,Section II.C.2
Storage tank is subject to Regulation 7, Part D, Section II.C.2
Regulation 7, Part D,Section II.C.4.a.(i)
Storage tank is subject to Regulation 7, Part C, Section II.C.4.a(i), b -f -
Regulation 7, Part D,Section II.C.4.a.(ii)
Storage Tank is notsubject to Regulation 7, Part D, Section II.C.4.a(lib b - f
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject t3 NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage tarts i5 not subject to N5P$ 0000.
NSPS Subpart 0000a
Storage Task is not subject to NSPS 0000a
Regulation B, Part E, MACE Subpart HH
Storage Tank is not subject to IMACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors to '
estimate emissions?
If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes, the permit will contain an "Initial Compliance' testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample
should be considered representative which generally means site -specific and collected within one year ofthe -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 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 - Technical Analysis Notes
These storage tanks recieve oil from the Anderson Wells. Fluids flow from the wellhead separators to "bulk separators" for a second stage of gas/liquid separation Oil from the bulk separator is discharged to "
these storage tanks. Vapors from the condesnate tanks are commingled with vapors from produced watertanks (pt 009) and route d to vapor recovery units whichcompress the gas into the sales pipeline. When
VRUs are down, the commingled tank gas is combusted in ECDs. The combusted vapors from the storage tanks are monitored via to nk gas meter. -
Emissions are based. on a pressurized liquid sample pulled on 7/22/20 from the Anderson Bulk Separators at 20 psig, 1026. Emis sions were modeled using ProMax to estimate both flash and working/breathing
emissions.
APEN indicates that firstdate of production is 7/2020.
Applicant is reporting emissions from combustion of pilot fuel at the combustor to this point (note that this control device is shared between storage tanks (point 007, 009) and loadout (point 011) for the
Anderson production train. Pilot emissions are reported here. Note that emissions of VOC from combustion of pilot fuel is est imated using factors in AP -42 chapter 13.5: This is likely an overestimate as this
factor provides a general estimate of VOC (post combustion) from control of unspecified waste streams. We generally allow us a of factors In Chapter 1 for pilot combustion, which provides significantly lower
emissions estimates for VOC...,
A limit for NOx will not be included in the permits since NOx emissions from combustion of gas from all sources routed to com mon combustors associated with this point (007, 009, 01I, 013) is less than
reportingthresholds for NOx: -
Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point ti
007
Process ft
. 01
SCC Code
404-003.11 Fused Roof Tank, Condensate, working+breathingeflashin
Uncontr
oiled
Emission
Pollutant s Factor Control % Units
PM10 O:C-r,0 16/1,000 gallons Condensate throt
PM2.5 0.00 0 16/1,000 gallons Condensate throt
NOx 0.02 0 lb/1,000 gallons Condensate throt
VOC 29,30 98 lb/1,000 gallons Condensate tiro'.
CO 0.08 0 lb/1,000 gallons Condensate throt.
Benzene 0.07 98 lb/1,000 gallons Condensate throt
Toluene 0.05 98 lb/1,000 gallons Condensate throt
Ethylbenzene 0.01 98 lb/1,000 gallons Condensate throt
Xylene 0.01 98 lb/1,000 gallons Condensate throt
n -Hexane 0.49 98 16/1,000 gallons Condensate th rot
224 TMP 0.03 98 lb/1,000 gallons Condensate throt
CAUsers\biaxfiEMDesktop\Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions.
Colorado Regulation 3 Parts and B-APEN and Permit Requirements
ISmi_v i, in the Nw-Aria iinr-ant Are,
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.O.l.a)7
2. Is the construction date (service date) pdor to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0501 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3. Part B, Section ll.D.3)?
IV. have indicated at r_q.c_ is in the Non+@toinment Area
NON -ATTAINMENT •
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than )TPY(Regulation 3, Part A,Sectionll.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section ll.D.2)7
krcerequlre:e oermtt
Colorado Regulation 7, Part D. Section I.C-F & G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Regulation 7, Part D, Section IA.1)7
2. Is this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part D, Section I.A.1)7
3. !stills storage tank located at a natural gas processing plant (Regulation 7, Part D, Section 1.6)7
4. Does this storage tank contain condensate?
5. Does this storage tank exhibit "Flash"(e.g. storing non -stabilized liquids) emhsions(Regulation 7, part D, Section 1.6.2)7
6. Are uncontrolled actual emissions of this storage tank equalto argreaterthan?tons per year VOC (Regulation 7, Part D Section l.D.3.a(h)?
laiq; .milt is subj. is Ridiuletion'I,=art0 Soctlon hCc
Pert D, Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Part0, Section I.C.2—Emission Estimation Procedures
Part D, Section I.D— Emissions Control Requirements
Part D, Section LE —Monitoring
Part D, Section 1.; —Recordkeeping and Reporting
I
■
Sierage'nnk, Is ran suhEctrn Regulosien 7. tdsctlun 1.6
Part D, Section l.G.2- Emissions Control Requirements
Part D, Section I.C.1.a and b —Genera) Requirements for Air Pollution Control Equipment —Prevention of Leakage
Colorado Regulation 7. Part D. Section II
1. Is thh storage tank located Ma transmission/storage facility?
2. Is this storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor station3 or natural gas processing plant°(Regulation 7, Part D, Section 11.[17
3. Does this storage tank have a fixed roof (Regulation 7, Part D, Section ll.A.20)?
4. Are uncontrolled actual emissions of this storage tank equal to or greaterthan 2 tons per year VOC (Regulation 7, Part D, Section ll.Gl.c)7
=tor Mik isdisittoct Siviiidetisn't.Fors S ?inn 11.0,Cd
Part 0, Section HA —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D, Section II.GI- Emissions Control and Monitoring Provisions
Part D, Section II.C.3 - Recordkeeping Requirements
5. Does the storage tank contain only "stabilited"liquids (Regulation 7, Part D, Section ll.C.2.b)?
NOM
Ye,
*OVA
414211C.
Source Requires an APEN. Coto
Go to next question
Source Requires a permit
Continue -You have indicated th
Continue - You have indicated th
Storage Tank b not subject to RE
Continue -You have indicated th
Go to the next question -You ha
Go to the next question
Source Issubject to parts of Reg'
i fll5ource is subject to all provision:
Part 0, Sectionll.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located m a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May S, 2020 or located at a facility that was modified an or after May 1, 2020, such
6. that an additional controlled storage vessel h constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ll.C.4.a(1)7 ,. Go to the next question
I`-=o-Ctk issubdeccite -It cstIon
Is the controlled storage tank ld at a wellproduction facility, t l gas rilpressor station, or natural gas processing plant constructed on or afterlanuary 1, 2021 or located at a facility that was modelled on or after January 1,
7. 2021, such that an additional controlled storage vessel is constructed? anticipated increase n throughput of hydrocarbon liquids or produced wmer(Regulation 7, Part D, Section lLC.4.a.)? ;a'vNNI
ISiacege Tank is no: rz=' c to Requital. 7, Part D. Section II r_ receive
40 CFR. Part 60, Subpart Kb, Standards of Performancefor Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel opacity greater than or equal to 75 cubic meters (ma) (-472 33Ls] (40 CFR 60.1106(a))?
2. Does the storage vessel meet the following exemption in 60.1116(d)(4)7
a. Does the vessel has a design capacity less than or equal to 1,589.874 in'( -10,000 BBL] used for petroleum'. or condensate stored, processed, or treated prior to custody transfer' as defined In 60.111b7
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2)after July 23, 1984(40 CFR60.1106(a))?
4. Does the tank meet the definition of"storage vessel"s in 60.11167
5. Does the storage vessel More a"volatile organic liquid(VOL)"sas defined in 60.111b7
G. Does the storage vessel meet any one of the following additional exemptions
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ('29.7 psi) and without emissions to the atmosphere (60.110h(d)(2))7; or
h. The design capacity is greater than or equal to 151m' (-950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.110b(b))7; or
c. The design capacity is greater than or equal to 75 Ms 1-472 BBL) but less than 151 m' (-950 BBL) and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b))7
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greater than or equalto 151 ms (-950 BBL] and stares a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or
b. The design capacity is greater than or equalto 75 M' x472 BBL] but less than 151 ms f-950 BBL) and stores a liquid with a maximum true vapor pressure greaterthan or equalto 15.0 kna but less than 27.6 kPa7
ISmrma lank Is not suhiect Ica n15PS Kb
40 CFR. Pert 60. Subpart 0000/0000a, Standards of Performance for Crude OR and Natural Gas Production, Transmission and Distribution
1. Is this storage vessel located at a facility in the onshore ail and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry?
2. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2)between August23, 2013 and September 13, 20157
3. Was this storage vessel constructed,reconstructed, or modified (see defintions 40 CFR, 60.2) after September 18, 20157
4. Are potential VOC emissions'from the Individual storage vessel greater than or equal to 6 tons per year?
5. Does this storage vessel meet the definition of"storage vessel"' per 60.5430/M.5430a?
6. is the stooge vessel subject to and controlled in accordance with re u'rements for storage vessels In 40 CFR Part 60 Sub art Kb or 40 CFR Part 63 Subpart HH?
I5:wag_ Tank is not suaicct to NSP<OGOOa
Gn tothe next question
Stooge Tank h not subject NSPS
WISTiegg
11�n.!'!
[Note: If a storage vessel Is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC an the applicability determination date, ft should remain subject to NSPS 0000/0000a per
60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT NH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following creerla:
a. Afacilhy that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2))i OR
b. Afacility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or 6 delivered to afinal end user' (63.760(a)(3))?
2. Is the tank located at a facility that is major° for HAPs?
3. Does the tank meet the definition of"storage vessel." in 63.7617
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions.° per 63.7617
5. Is the tank subject to control requirements under 40CFR Part 60, Sub art Kb or Sub art 00007
I�tgr etankis not eobiott to MAO' Hit
Subpart A, General provisions per 463.764 (a) Table 2
563.766- Emissions ...Standards
563.773- Monitoring
§63.774- Recordkeeping
563.775 -Reporting
RACT Review
RACT review's required If Regulation 7 does not apply AND if the tank is in the ion-attainmentarea. If the tank meets both criteria, then review RACT requirements.
Continue -You have Indicated th
Storage Tank is not subject NSPS
Go to the next question
Storage Tank not subject NSPS
Yes IContinue- You have indicated th
Storage Tank is not subject MAC
Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
Facility AIRS ID:
123
County
9FED
Plant
008
Point
Section 02- Equipment Description Details
Storage Tank liquid Condensate
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Five (5) 500 barrel fixed roof condensate storage vessels connected via ld man1 Id.
Emissions are commingled with produced water tank vapors (Point 010) and compressed to sales line via vapor recovery unit
(VRU). During VRU downtime,. tank vapors are routed to enclosed combustors (ECDs).
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
uia rnroq�h�_ ;_;
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Total (Process 01+ Process 02)
Actual Throughput =
Requested Permit Limit Throughput =
999,400 Barrels (bbl) per year
1,099,340 Barrels (bbl) per year
Requested Monthly Throughput =
Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput=
% Process 01:
% Process 02:
Process 01 (Emissions routed to VRU)
Actual Throughput =
Requested Permit Limit Throughput =
Requested VOC & HAP Control Efficiency %:
1,099,340 Barrels (bbl) per year
84 %
51.E %
483,388 Barrels (bbl) per year
531,727. Barrels (bbl) per year
Requested Monthly Throughput =
45160,4 Barrels (bbl) per month
Process 02 (Emissions routed to ECDs)
Actual Throughput=
Requested Permit Limit Throughput =
Requested VOC & HAP Control Efficiency %:
100 %
516,012 Barrels (bbl) per year
567,613 Barrels (bbl) per year
Requested Monthly Throughput =
48208.2 Barrels (bbl) per month
Secondary Emissions from Process 02- Combustion of Em iss ions
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 =
Requested heat content of waste gas routed to combustion device =
95
2346.5 Btu/scf
14.9 scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
18,036.2 MMBTU per year
19,839.S MMBTU per year
79.2595 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Process 01
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
1.2421
0.0-000
to Specific E.F.(iecludes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F, (Includes flash)
S't�te Specific E.P. (includes flash) .
1{e Specific E.F.(includes flash) '
Site Specific E.F. (includes flash)
Benzene
2.9E-03
G;0000
Toluene
2.1E-03
0,0000
Ethylbenzene
2.8E-04
Xylene
4.4E-04
0,0000
n -Hexane
0.0209
0,0000
224 TMP
1.1E-03
0.0000
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0000
PM2.5
0.0000
0.0000
SOX
0.0000
0-.0000
NOx
0.0000
0.0000
CO
0.0000
0.0000
I
C:\Users�lnfa%fhs\Desktop\Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
cess02 ti`s.'
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Throughput)
(Throughput)
VOC
.;1.2421
C.,,,32,
$ite5slf7,c,EF:(lttdttrt Fj)ash) '
Site 5p'ett 6.F. (includei'ftash}
Site5'crftc E.F(includes#lash) '
Site SpeuCE.F: (mcPu es fidsh) r'� ,•
Sites tSftcE.Fi(inc[e)slash) -`
Site5'}tea'i,i=E,Pt (inelp sfI@sh)
site5pectfic E.F:(indudes ash)
Benzene
2.9E-03
H
Toluene
2.1E-03
-
Ethylbenzene
2.8E-04
,. _
Xylene
4.4E-04
' _.,
n -Hexane
'.`0.0209
- _
224TMP
1.1E-03
=__
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (I4/bbl)
(waste heat
combusted)
(Throughput)
PM10
0.0075
:9:3
AP,42Ta`Me1.4-2 (PMitf�PM.25}
AP 42T ), 142(PM PM,25)
AP -42 Tet1,42 (PM2 S),.
AP -0. apter f35Tnth7stria( Flares jN
AP -42 pt 13.51ntfusMal Flares
PM2.5
0-0075
993
50x
-
r `,
NOx
0.0680
..,_-
CO
0.3100
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf)
(Pilot Gas Heat
Combusted)
(Pilot Gas
Throughput)
PM10
0.0075
s
AP42T' 4.2(PM10PPM:25) '
AP;424 814.2 (plirt
AP -A 4-2 (50
AP -42 Pt -.115 ustndI
Other
AP pfrfdF+5Frfal Flares [C 0))
PM2.5
0.0075
SOx
0.0006
i 99999
NOx
0.0680
_
VOC
0.6600
.� _
CO
:0.3100
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tans/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
50x
NOx
VOC
CO
v,.
0.95
0555
190.5
_..
.2.5_69.
15.96
--._„
v -a
2622
2.95
__
3 294
S9.9.4
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
)Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
___
2265
2223
_135
__.;
_,--
430
22955
20969
939
9%
i_..
:..
CAUsersYtda3lps\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage?ank(s) Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Part D,Section I.C, D, E, F
Storage tank is subject to Regulation 7, Part D, Section I.C-F
,
Regulation 7, Part D,Section I.G, C
Storage Tank is not subject to Regulation ',Section I.G
Regulation 7, Part D,Section I I.B, C.1, C.3
Storage tank is subject to Regulation 7, Part D, Section II, B, C.1 & C3
_
Regulation 7, Part D,Section II.C,2
Storage tank is subject to Regulation 7, Part D, Section II.C.2
_
Regulation 7, Part D,Section ll.C.4.a.(i)
Storage tank is subject to Regulation 7, Part D, Sectionii.C.4.a(i), b - f
....
Regulation 7, Part D,Section II.C.4.a.(ii)
Storage Tank is not subject to Regulation 7, Part D. Section II.C.4.a(ij), b - f
_
Regulation 6, Part A, NSPS Subpart Kb .
Storage Tank is not subject to NSPS jib
_
Regulation 6, Part A, NSPS Subpart 0000
`storage tank is not subject to NSPS 0000.
-
NSPS Subpart 0000a
Storage Tank is not subject to NSPS 0000a
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
For condensate or crude oil tanks, does the company use the state default emissions factors to - "-
estimate emissions?
If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
.Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted (for produced water tanks, a pressurize_ liquid sample must be analyzed using flash liberation analysis)? 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 maybe 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 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08- Technical Analysis Notes
These storage tanks redeye oil from the Anderson Wells. Fluids flow from the wellhead separators to "bulk separators" for a second stage of gas/liquid separation. Oil from the bulk separator is discharged to these
storage tanks. Vapors from the condesnate tanks are commingled with vapors from produced water tanks (pt 010) and routed to vapor recovery units which compress the gas into the sales pipeline. When VRUs are
down, the commingled tank gas is combusted in ECDs. The combusted vapors from the storage tanks are monitored via tank gas meter.
Emissions are based on a pressurized liquid sample pulled on 7/22/20 from the Anderson Bulk, Separators at 20 psig,102F. Emissions were modeled using ProMax to estirria, oth flash and working/breathing
Applicant is reporting emissions from combustion of pilot fuel at the combustorto this point (note that this control device is shared between storage tanks (point 008, 010) and loadout (point 012) forthe Anderson
production train.. Pilot emissions are reported here. Note that emissions of VOC from combustion of pilot fuel is estimated using factors in AP -02 chapter 13.5. This is likely an overestimate as this factor provides a
general estimate of VOC (post combustion) from control of unspecified waste streams. We generally allow use of factors in Chapter 1 for pilot combustion, which provides significantly lower emissions estimates for
A limit for NOx will not be included in the permits since NOx emissions from combustion of gas from all sources routed to common combustors associated with this point (008, 010, 012, 014) is less than reporting
thresholds for NOx.
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point #
Process #
01
SCC Code
4-04-003-11 Fixed Roof Tank, Condensate, working+hreathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control h Units
PM10 CLOG a lb/1,000 gallons Condensate throu
PM2.5 0.00 0 lb/1,000 gallons Condensate throu
NOx 0.03 0 lb/1,000 gallons Condensate throu
VOC 2947 97 lb/1,000 gallons Condensate throu
CO 0.19 0 lb/1,000 gallons Condensate throu
Benzene 0.07 97 16/1,000 gallons Condensate throu
Toluene 0:05 97 lb/1,000 gallons Condensate throu
Ethylbenzene .0.01 97 Ib/1,000.gallons Condensate throu
Xylene 0.01 97 16/1,000 gallons Condensate throu
n -Hexane 050 97 lb/1,000 gallons Condensate throu
224 TMP 0.03 07 lb/1,000 gallons Condensate throu
CAUsersgbafa3lts\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809,CP1
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and. B -APEN and Permit Requirements
cac._a.s,n.na.`Fa=, x�_,nenr t.ea
ATTAINMENT
1 Are uncontrolled actual emissionsf y criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, 5eRion ll.D.La)?
2 Is theconstruction date (service date) pto 12/30/2002 and not modified after12/31/2002(See P5 Memo 0501 Definitions 1.12 and114 and Section 2 for addrtonal guidance on grandfather applicability)?
3 Are total facility uncontrolled VOC emissions grefter than5TPY NOxgreater than to TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 1103)?
■
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan )TPY(Regulation 3, Part A, Section ll.D.S.a)?
2. Is the construction date (service date)prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3, Part B, 5eRion 11.0.2)?
wurrosulms a t
Colorado Regulation 7, Part D. Section LC -6.G
1. Is this storage tank located inthe 8 -hr ozone control area or any ozone non -attainment area or attainment/ma area (Regulation 7, Part D, Section lA.1)?
2. Is this storage tank located at oll and gas operations that collect, store, or handle hydrocarbon liquids or produced water ANDthat are located at or upstream of a natural gas processing plant (Regulation 7, Part 0, Section IA.1)7
3. Isthis storage tank located at a natural gas processing plant (Regulation ], Part D, Section l.G)? •
4. Doesthis storage tank contain condensate?
5. Does this storage tank exhibit "Flash" (e.g. staring non -stabilized liquids) emissions (Regulation 7, part D, section l.G.2)?
6. Are uncontrolled actual emissions of this storage tank equal to or greeter than 2 tons per year VOCfRegulation 7, Part o,Section l.D.3.a(ii))?
'Storage Wok
Part 0, Section I.C.1—General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Part 0, Section I.C.Z—Emission Ertimation Procedures
Part D, Section LEI —Emissions Control Requirements
Perth, Section LE —Monitoring
Part D, Section I.F-Recordkeeping and Reporting
74o,Y'-' -a s:rhic=ct qe P.a¢ ''inn i.5ac'.la^ 1C -
Part O, Section 1.G.2- Emissions Control Requirements
Part D, Section I.C.La and b —General Requirements for Air Pollution Contral Equipment —Prevention of Leakage
Colorado Regulation 7. Part ID, Section II
1. Is this storagetank located at a transmission/rtoragefacility?
2. Is this storage tank'located at an oil and gas exploration and production operation , well produrtion facility', natural gas compressor stations or natural gas processing plane(Regulation 7, Part D, Section II.C)?
3. Does this storage tank have a fixed roof (Regulation 7, Part D, Section ll.A.20)?
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section ll.C.1.c)?
Part 0, Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part O, Section II.C.1-Emissions Control and Monitoring Provisions
Part°, Section ILC.3-Recordkeeping Requirements
S. Doesthe storage tank contain only "stabilised" liquid (Regulation ] Part D, Section ll C.2.b)?
' Storage tit .:, _uk:c.,a a,Pc,U..e.....,.,t_...2
Part 0, Section II.C.2-Capture and Mon Boring for5torage Tanks fitted with Air Pollution Control Equipment
Is the controlled soragetank located at a well production facility, natural gas compressorstatIon,or natural gas processing plant constructed on or after May L 2020 or located at a facility that was modified on or after May 1, 2020, such
6 that an additional [ lled rtorage vesselts corrtructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part O, Section lLC.4.a(i)?
I t6 -
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or afterlanuary 1,
] 2021, such that an additionalcontrolled storage vessel is constructedt anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Bert:an'LC .4.a.(ii)?
Paz,.
40 CFR, Part 60, Subpartn, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m) (`472 BBLs] (40 CFR 60.SSob(a))?
2. Does the storage vessel meet the fallowing exemption in 60.lilb(d)(4)?
a. Does thevessel has a design capacity less than or equal to 1,589.8]4 ma( -10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custody transfer' as defined in 60.1316?
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984 (40 CFR60.11nb(a))?
4. Does the tank meet the definition of"storage vessel"' In 60.1116?
5. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined In 60.111b?
6. Does the storage vessel meet any one of thefollowing additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [-29.7 psi] and without emissionstothe atmosphere (60.110b(d)(2))?; or
b. The design capacity u greaterthan or equal to 151 ms (-950 BBL) and stores a liquid with a maximumtrue vapor pressure' less than 3.5 kPa (60.11ob(b))?; or
c The design capacity is greaterthan or equalto 75 Ma [-472 BBL] but lessthan 151 ms (-950 BBL] and stores a liquid with a maximum true vapor pressure' lessthan 15.0 kPa(60.13ob(b))?
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greaterthan or equal to 151 ma1-950 BBL] and stores liquid with a maximum true vapor pressure greater than or equal to 3.5 kite but less than 5.2 kPa?; or
b. The design capacity Is greaterthan or equalto 75 he (`472 BBL] but lessthan 151 m' (-950 BBL] and stares a liquid with a maximum true vapor pressure greaterthan or equalto 15.0 kPa but less than 27.6 kPa?
I5tnra";e Tarue!s -.gtsia'ac'Pe "dSP§K.b
40 CFR, Part 60, Subpart0000/O0OOa. Standards of Performance for Crude OR and Natural Gas Praduction.Transmission and Distribution
1. Is this storage vessellocated eta facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Wasthi storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015?
4. Are potential VOC enissions'from the individual storage vessel greater than or equal to 6 tons per year?
5. Doesthis storage vessel meetthe definition of"storage vessee per 60.5430/60.5430a?
6. Is the storage vesselsublert to and controlled in accordance with requirements for storage vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HO?
Yes
Ye=
No
Source Requires an APEN. Go to
Go. next question
Source Requires apermit
Continue - You have indicated th
Continue - You have indicated th
Storage Tank is not subject to Re
Continue -You have indicated th
Go to the next question -You. ha
Go to the next question
Source Is subject to parts of Reg:
[Source u subject to all provision
Go to the next question
Go to the next. question
Storage Tank is not subject NSPS
Ysa
Fik.W44
[Note: If a storage uessel is previously determined to be subject to NSPS 0000/0O0Oa due to emissions above 6 Mns per year VOC anthe applicability determination date, it should remain subject to NSPS 0000/00O0a per
60.5365(e)(21/60.5365a(e)(2) even if potential VOC emissions drop below 6tons per year]
4a CFR. Part 63, SUboartMACT HH, Oil and Gas Production Facilities
1. Isthe storagetank located at an oil and natural gas production facilitythat meets either of the following criteria:
a. Afacilitythat processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. Afacilitythat processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))?
2. Is the tank located at a facility that is majors far HAPs?
3, Doesthe tank meet the definition of"storage vessel"' in 63.]61?
4. Does thetank meet the definition of"storage vessel with the potential forflash emissions'per 63.761?
5. IstheMnk subjectto control re q uirements under 40 CFR Part 60, Subpart Kh or Sub art 0000?
MAC' IfH
Subpart A, General provisions per 463.]64 (a) Table 2
463.766 - Emissions Control Standards
§63.]]3 -Monitoring
463.]]4-Recordkeeping
§63.]]5 -Reporting
RACT Review
PAR review is required If Regulation] does not apply AND if the tank Is in the non -attainment area. If the tank meets both criteria, then review RAC' requirements.
Continue -You have indicated th
Storage Tank is not subject NSPS
Go to the next question
Storage Tank is not subject NSPS
�ves 'Continue- You have indicated th
Storage Tank is not subject MAC
Storage Tank(s) Emissions inventory
Section 01- Administrative Information
'Facility AIRS 10:
, Iz3+-: ft mgr .V E .-�r�-d 8".z` 79:VO ,
County Plant Point
Section 02- Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit
Description:
forage vessels connected. via liquid ani₹old.
Emission Control Device EMissions are commingled
with condensate tank vapors(Point 007) and compressed to sales line
Description: (VRU). During VRU downtime tank vapors are routed to enclosed combustors (ECM)..
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Total (Process Pa+Process 02)
Actual Throughput=
Requested Permit Limit Throughput =
1,36tbre Barrels (144) per year
1;503,788` Barrels (bbl) per year
Potential to Emit (PTE) Condensate Throughput =
% Process 01:
% Process 02:
Process 01(Emissions routed W VRU)
Actual Throughput=
'Requested Permit Limit Throughput =
Requested VOC & HAP Control Efficiency %:
Process 02 (Emissions routed to ECDs)
Actual Throughput=
'Requested Permit Limit Throughput =
Requested VOC & HAP Control Efficiency %:
Secondary Emissions from Process 02 - Combustion of Emissions
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 =
Requested heat content of waste gas routed to combustion device =
1,503,786- Barrels (bbl) per year
5 %
%
655. Barrels (bbl) per year
720 82: Barrels (661) per year
100 ,%
'. 711,749 Barrels (bbl) per year
782,924, Barrels (bbl) per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
Requested Monthly Throughput=
Requested Monthly Throughput =
Requested Monthly Throughput=
570.6 MMBTU per year
527.3 MM BTU per year
627.3 MM BTU per year
Section 04 -Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Pollutant
Pollutant
Pollutant
Produced Water Tank
Uncontrolled
Controlled
Oh/bbl)
(Ib/bbl)
(Produced Water
Throughput)
a0MA04oftrog
(Produced Water
Throughput)
Control Device
Uncontrolled
(Ib/MMBtu)
(waste heat
combusted)
Uncontrolled
(Ib/bb0
(Produced Water
Throughput)
Produced Water Tank
Uncontrolled
Controlled
(16/661)
06/bbl)
0;0104
12E-04.....
9„6E -d6
6=6E-06
1.oE-os
Emission Factor Source
Emission Factor Source
Emission Factor Source
MINEEMEM
...0.0E+0o-.
12r718.8 Barrels(661) per month
51223.9 Barrels (bbl) per month '
66494.9 Barrels (6til) per month
10 of 34 C:\Users\beades\Desktop\Remote Work\My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage Tank(s) ssions Inventory
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
( Throughput)
PM10
.0.0075
-
AP -42 Tali ,3' i•.
AP -42 Tble-50x
AP -42 Table
AP -42 Chapter aI e5'(NOi, =
AP -42 ChapteF151n '"ial Flares (co) '-;.
PM2.5
0.0075
c '52.
5 5555
NOx
0.0680
5 5,5'6
CO
0.3100
-
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) ' (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
50x
NOx
VOC
CO
010
0.G
0.0
0.0
0.0
0.4
0:0
0.3
0.0
022
0.0
0.4
0.0
.,._
0.0
0.0
0.0
0.0
...
_...:. -
002
0.02
0.02
3,6
7.8
0.19
754
0.204
34.7
0.1
_.39
0.09
010
0.10
16.5
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
%ylene
n -Hexane
224 TMP
325
235
8
325
8
145
i32
3
145
0.
9
8
0.2
9
0
15
14
0.4
..5
0
210
191
S
210
5
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
a
Source_ permit
Regulation 7, Part D,Section I.C, 0, E, F
5 ewe.tenk sjsutitect to Regulation 7. Part.!D, Section LC -F
Regulation 7, Part D,Section I.G, C '
Storage_ Tank is not subject to Regulation 7, Section 1.G
Regulation 7, Part D,Section II.B, C3, C.3
Storage.tant Is cobieet to Regulation 7, Part ra Section II. B, ."_,1 8, C.3
Regulation 7, Part D,Section II.C,2
Storage twits suPathiect to Regulation 7, P₹ D, Section II.C,2
Regulation 7, Part D,Secdon ll.C.4.a.(I)
5-[a ., a�!t yect to Regulation 7 Peet C, Section II .4 aiR, b -f
Regulation 7,•Part 0,5ectionll.C.4.a.(ii)
to _ not sullied to Regulation . Pact -.,9 K 1 .J , „c i
Regulation 6, Part A, NSPS Subpart Kb
Storage Took s one se Lt to NSPS {b
Regulation 6, Part A, NSPS Subpart0000
Storage tank is not subiect to NSPS 0000.
NSPS Subpart 0000a
., __.,-,, ,. ,_,.subpect to NSP50OGOa
Regulation B, Part E, MACE Subpart HH
ProducedWat_, Storage tank is not 'subjects to :MACS HtI `
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors to
estimate emissions?
If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a. condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site speck emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted (for produced water tasks, a pressurize liquid sample must be analyzed using flash liberation analysis)? 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 gat been modified (e.g., no new wells brought on-line), then it may be appropriate to use an
older she -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 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 -Technical Analysis Notes
These storage tanks recleve produced water from the Anderson Wells. Produced water flows from the inlet separators at approximately 86 psi to these atmospheric storage tanks. Vapors from the produced water
tanks are commingled with vapors from condensate tanks (Point 007) and routed to vapor recovery units which compress the gas into the sales pipeline. When VRUs are down, the commingled tank gas is combusted
inECDs. The combusted vapors from the storage tanks are monitored via tank gas meter.
Emissions are based on a pressurized liquid sample pulled on 7/22/20from the Anderson Separators. at 86 psig, 142F. The laboratory performed flash liberation anlaysison the sample to quantify and characterize
emissions from the gas bbe`ratedas flash.
APEN indicates that firstdate `of production is 7/2020.
Applicant did not originally Include working and breathing calculations for produced water tanks so calculations were requested and provided with application revisions on 12/21/20. They show mslgnifioan
^'contribution from working and breathing losses (Increases of tpy uncontrolled; -0.003 tpy controlled), -
A limit for NOx will not be tnduded In the permits since NOx emissions from combustion of gas from all sources routed to common: combustors associated with this point (007, 009, 011, 013) Is less than reporting
11 of 34 C:\Users\beades\Desktop\Remote Work \My Packages\ Package 436017 (Mallard Anderson -Shull) received In Oct 2020\20WE0809,CP1
Storage Tark(s) Emissions Inventory
Section 09-SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point #
009
Process # SCC Cade
01 m ._
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 C.!s3 0 6/1,000 gallons Produced Water throughput
PM2.5 0.00 b/1,000 gallons Produced Water throughput
Sox xBEF't 0 b/1,000 gallons Produced Water throughput
NOx 0.00 0 b/1,000 gallons Produced Water throughput
VOC 00.25 97 b/1,000 gallons Produced Water throughput
CO 0.00 0 6/1,000 gallons Produced Water throughput
Benzene 0.C1 97 6/1,000 gallons Produced Water throughput
Toluene 0.00 97 b/1,000 gallons Produced Water throughput
Ethylbenzene 0.00 97 6/1,000 gallons Produced Water throughput
%ylene 0.00 97 6/1,000 gallons Produced Water throughput
n -Hexane 0.00 97 b/1,000 gallons Produced Water throughput
224 TMP 0.00 97 6/1,000 gallons Produced Water throughput
12 of 34 C\users\beades\ Desktop \Remote Work \My Packages\ Package 436017 (Mallard Anderson -Shull) received In Oct 2020\20WE0809.CP1
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Coloradof_ Ligation 3Parts A and B- APEN and Permit Requirements
�ou.__ in thu NOrFAttalnment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY(Regulation 3, Part A,Section Hale)?
2. Produced Water Tanks have no grandfathering provisions
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10TPY or CO emissions greater than 30 TM,(Regulkion 3, Part B. Section ll.D.3)7
',have inclicated that source is int:e frion-Attot:nnent Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollMamsfirm this individual source greater than l TPY(Regulation 3, Part A, Section ll.D.l.a)?
2. Produced Water Tanks have no grandfathering provisions
3. Are total facility uncontrolled VOC emissions greaterthan 2TPY, NOx greater than STPY or C0 emissions greater than lO IP/(Regulation 3, Part B,Section ll.D.2)?
ISoDscerequire-en per,.
Colorado Regulation 7, Part D, Section I.C-F &G
1. Is this storage tank located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/malntename area (Regulation?, Part D, Section I.A.1)?
2. Is this storage tank located at oll and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part 0, Section IA.117
3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part 0, Section I.G)? •
4. Does this storage tank contain condensate?
5. Does th'a storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions{Regulation 7, part D, Section 1.6.2)7
6. Are uncontrolled actual emissions of this storage tank equal to or grekerthan 2 tons per year VOC (Regulation 7, Part D,Section l.D.3.a(ii))?
I55r _Fe tank is stegect to Re uenticn Parteh Sect,nht.i,
Part D, Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Part D,Section I.C2—Emission Estimation Procedures
Part D, Section1.13 Control Requirements
Part D, Section LE —Monitoring
Part D, Section I.P—Recordkeeping and Reporting
I
not subhtel to Ruguiatson 7, Suction I.G
Part D, Section I.G.2- Emissions Control Requirements
Pert D,Section I.C.1.a and b —General Requirements far Air Pollution Control Equipment —Prevention of Leakage
Colorado Regulation T, Part D. Section II
1. Is tho storage tank located at a transmission/staragefacility7
2. Is th's storage tanks located at an oil and gas exploration and production operation, well production facility', natural gas compressor station or natural gas processing plant'(Regulatian 7, Part D, Section ll.C)7
3. Does this Marage tank have a fixed roof(RegulMian 7, Part D,Section llA20)?
4. Are uncontrolled actual emissions of thn storage tank equal to or greater than 2 tans per year VOC (Regulation 7, Part D, Section ll.C.1.c)?
IS<c'er,.rana inambject to HeuNlaNn 7,Per v,Section ll, B, C.13 C.3
Pert D, Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Pert 0, Section 112.1- Emissions Control and Monitoring Provisions
Part 0, Section II.C.3 - Recardkeeping Requirements
5. Does the storage tank contain only "stabilized" liquids (Regulation 7, Part 0, Section ll.C2.6)?
late -see mot( is siblect to lie.,i_ vv,,. Pert D,5gctlon lLC.2
Part D, Section II.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located at a facility that was modified on or after May 1, 2020, such
6, that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ll.C.4.a.(1)7
yes
No
No
Yes
iat ..
No
Yatt-
4gfM
Source Requires an APEN. Go to
Gam next question
Source Requires a permit
Continue - You have Indicated th
Continue - You have Indicated th
Storage Tank is not subject to RE
Continue - You have indicated th
Go to the next question -You ha
Go to the next question
Sources subject to parts of Reg
reed{Source issubject to all provision:
₹IGo to the next question
Is the controlled sorage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or afterlanuary 1,
7. 2021such that as additionalt II d storage vesselconstructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ILCA.a.(IIl7
- sublentt qn,inqnn Pe, F:etnen C4a1!h f
40 CPR. Part 60. Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the indivIdual storage vessel capacity greater than or equal to 75 cubic meters (0) ["'472 BBLsj (40 CFR 60.130b(a))?
2. Does theMorage vessel meet the following exemption in 60.1116(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m'[-10,000 BBL] used for petroleum' or condensate stored, processed, or treated priorto custody transfer' as defined in 60.111b?
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984 (40CFR 50.110h(a))?
4. Does the tank mart the definition of"storage vessel.' in 60.1116?
5. Oues the storage vessel store a "volatile organic liquid (VOL)"sas defined in 60.111b7
6. Does the storage vessel meeteny one of the fallowing additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa [-29.7 psi] and without emissions to the atmosphere (60.110b(d)(2111; or
b. The design capacity is greater than or equal to 151 ms (-950 BBL) and stores a liquid with a maximum true vapor pressure less than 35 kPa (60.1106(6))?; or
c. The design capacity is greater than or equal. 75 Ms [-472 BBL] but less than 151 ms [-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))?
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greater than or equal to 151 m' [`950 BBL] and stares a liquid with a maximum true vapor pressure greater than or equal to 3.5 kna but less than 52 kfta?; or
b. The design capacity Is greater than or equal to 75 M' (-472 BBL] but less than 151 m' I`950 BBL) and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 275 kna?
ker.., Tank is not subiect to NViry Ott:
40 CFR. Part 60 subpart 0000/0000a. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment ar natural gas transmission and storage segment of the industry?
2. Was this moragevessel constructed,reconstructed, or modified (see definitions 40CFR,60.2) between August 23, 2011 and September 18, 20157
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 20157
4. Are potential VOC emissions' from the individual storage vessel greater than or equaito 6 tans per year?
S. Does this storage -vessel meet the definition of"storage vessel"' per 60.5430/60.5430a7
6. Is the storage vessel subject to and controlled in accordance with requlrements for storage vessels In 40 CFR Part 60 Sub art Kb or 40 CFR Part 63 Sub art HH?
[Note: If a storage vessel is previously determined to be subjectta NSPS 0000/0000a due to emissions above Storm per year VOC on the applicability determination date, it should remain subject. NSPS 0000/0000a per
60.5365(e)(2)/60:536Sa(e)(2) even gpmemial VOL emissions drop below 6 tons per Merl
40 CFR, Part 63, subpart MALT HH. 011 and Gas Production Facilities
1. Is then ragetaik located at an oil and natural gas production facility that meets either of the following crfterla:
a. Afacility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. Afaciky thatprocesses, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or k delivered to a final end user'(63.76010)(3))?
2. Is the tank located at afaciiity that a major' for HAPs?
3. Does the tank meet the definition of"storage vessel.' in 63.761?
4. Does the tank meet the definition of"rtorage vessel with the poteMialfor flash embsions"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart O00O?
Produced trinter Storage tank is not sub--=ct w hernCT F!H
Subpart A, General provisions per 463.764 (a) Table 2
463.766- Emissions Control Standards
463.773 -Monitoring
463.774-Recordkeeping
453..5 -Reporting
RACT Review
RACT review i. required if Regulation? does not apply AND if the tank is in the non -attainment area. lithe tank meets both criteria, then review RACT requirements.
Na
Y {%
Go to the next question
Storage Tank is not subject NSPS
Continue - You have indicated th
Storage Tank Is not subject NSPS
Go to the next question
Storage Tank Is not subject NSPS
'WAY*
Y*
'Yes 'Continue- You have Indicated th
Storage Tank is not subject MAC
Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
Facility AIRS ID:
123
County
9FED
Plant
010
Point
Section 02 - Equipment Description Details
Storage Tank Liquid e t 0 Ui[steY'
Detailed Emissions Unit Five (5) S00 barrel fixed roof produced water storage vessels connected via liquid manifold.
Description:
Emission Control Device Emissions are commingled with condensate tank vapors .(Point 008) and compressed to sales line via vapor recovery unit
Description: (VRU). During VRU downtime, tank vapors are routed to. enclosed combustors.(ECDs).
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter a,
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Total (Process 01+ Process 02)
Actual Throughput =
Requested Permit Limit Throughput =
526,090 Barrels (bbl) per year
631,308 Barrels (bbl) per year
Requested Monthly Throughput= $3617.9 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput =
Process 01:
% Process 02:
Process 01 (Emissions routed to VRU)
Actual Throughput =
Requested Permit Limit Throughput=
Requested VOC & HAP Control Efficiency%:
631,308 Barrels (bbl) per year
53.8 %
„,-116,97dBarrels (bbl) per year
60;368`. Barrels (bbl) per year Requested Monthly Throughput=
Barrels (bbl) per month
Process 02 (Emissions routed to ECDs)
Actual Throughput =
(Requested Permit Limit Throughput =
Requested VOC & HAP Control Efficiency Y.:
, Xli.:314 400..x;;%
309,116 Barrels (bbl) per year
370,939 Barrels (bbl) per year Requested Monthly Throughput=
Secondary Emissions from Process 02 - Combustion of Emissions
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 =
Requested heat content of waste gas routed to combustion device =
95 %
1135.5 Btu/scf
0.6 scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device=
Control Device
210.6 MMBTU per year
252.7 MMBTU per year
252.7 MMBTU per year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
_ -Process 01
Emission Factors
Produced Water Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(Ih/bbl) (Ib/bbl)
(Produced Water
Throughput)
(Produced Water
Throughput)
VOC
0.0104
0.0E+00
Sit -Specific E.F. (includes flash
E.F. (includes _
cdiG E.F. (includes y `
tc E.F. (includes flash) _
Benzene
2.2E-04.
0.0E+00:';Specrfic
Toluene
9.6E-05
0.0E+00
Ethylbenzene
5.7E-06
0.0E+00
Xylene
1.0E OS
0.0E+00
ii E.F. (includes flas(r}-' I :
-. pec(fir E.F. (includesif
°' ecific E.E. (includes -ft
n -Hexane
1.4E-04
0,0E+00
224 TMP
0.0E+00
0.0E+09
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/hbl)
(waste heat
combusted)
(Produced Water
Throughput)
PM10
0.0000
h {
5ii rr
PM2.5
0.0000
SOx
0.0000
NOx
0.0000v,
CO
0.0000
Bartels (bbl) per month
CAUstrAlidelies\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage Tanks Emissions Inventory
Process 02
Emission Factors
Produced Water Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Throughput)
(Throughput)
VOC
0.0104
S.2L 01
S li (includes flash)
Sncludes flash)
Site _ (includes flash)
Site Specific E.F.:(includes flash)
Site Specific E,F.(includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Benzene
2.2E-04
1.1F. -OS
Toluene
9.6E-05
4 8i. 05
Ethylbenzene
5.7E-06
2.9E-07
Xylene
1.0E -OS
55.0E-07
n -Hexane
1.4E-04
7.0E-06
224 TMP
0.0E+00
0.0E+00
Pollutant
Control Device
Em fission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
( Throughput)
PM10
0.0075
0.0000
AP -42 Table. l.4-2(PM10/PM.2.5)
PM2.5
0.0075
0.0000
AP -42 Table 1.4-2 (PM10/PM.2.5)
SOx
0.0000
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP-42Chapter .13.5Industrial Flare sjtl,5-
NOx
0.0680
4.6E-05
CO
0.3100
21E-04
AP -42,0 jteC135 Industrial Flares]
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/mmetu) (Ib/MMscf)
(Pilot Gas Heat
Combusted)
(Pilot Gas
Throughput)
PM10
0.0000-
PM2.5
0.0000
5Ox
0.0000
NOx
0.0000
VOC
0.0000
CO
0.0000
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tans/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month) _
PM10
PM2.5
5Ox
NOx
vOC
CO
0.0
0.0
a-0
0.0
am
0.2
0.0
0.0
0.0
0.0
0.2
OA
0.0
0.0
0.0
ma
0.0
0.0
0.007
0.007
0.009
_. 39
1.5
3.3
2.743
O.t81
3.202
0,097
16.4
0.0
0,033
0.033
0,039
0.039
5.7
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
136
114
3
136
€
61
51
_
61
2
4
3
0,1
4
0
6
5
0.2
6
0
E3
73
7.
88
3
0
0
0
,.
C:\UskEsldi&lles\Desktop \Remote Work \My Packages Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage Tank(s) Emissions Fr en5=o,ry=
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, a
Source resu=rss a permit
Regulation 7, Part D,Section I.C, D, E,.F
5„ore,s ,>r,.. SIthiVi to Fie a«<=en 7, 11,,, EL Section 1.4-2
Regulation 7, Part D,Section I.G, C
Regulation 7, Part D,Section II.B, C.1, C.3
.+r ation ,, Part D. s__.ror:, q, R _.19 Lis
Regulation 7, Part D,Section II.C.2
2torege .4..,, , c-< t„ Reg91,tred 7, Far, tr, 3.44.114, ;r14.2
Regulation 7, Part D,Section II.C.4.a.(i)
9remge 14.2_ _b,,,,I TO , , a L,,- D, S.,t_,a,. L. 4.-e1F - f
Regulation 7, Part D,Section II.C.4.a.(ii)
s ._,.. r, .._z r, n , saz. v:. ati•• -„ ..� t t, >.ar; p, 'a -_f
Regulation 6, Part A; NSPS Subpart Kb
Storage Tagk ig rent qubjett to NSPS {t:
Regulation 6, Part A, NSPS Subpart 0000
NSPS Subpart 0000a
star:age Tasxic fcs ots sect tc z5?s`C,-, mss
Regulation 8, Part E, MAer Subpart HH
Produced Wate=Storage tank is not subject €o MACT FIN
(See regulatory applicability worksheet for detailed analysis)
Section 07- Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors to
estimate emissions?
If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample
should be considered representative which generally means site-specificand 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 14-03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 - Technical Analysis Notes
Thesestorage tanks recieve produced water from the Anderson Wells. Produced water flows from the inlet separators at approximately 86 psi to these atmospheric storage tanks Vapors from the pr oduced water
i tanks are commingled with vapors from condensate tanks (Point 007)and routed to vapor recovery units which compress the gas into the sales pipeline. When VDUs are down, the commingled tank gas is combusted
ECDs. The combusted vapors from the storage tanks are monitored vla tank gas meter.
Emissions are based on a pressurized liquid sample pulled on 7/22/20 from the Anderson Separators at 86 prig, 142F. The laboratory performed flas
emissions from the gas liberated as flash.
AP EN indicates that first date of production is 2,,
Applicant did not originally includeworking and breathing calculations for produced water tanks so calculations were requested and provided with application revisions on 12/21/20. They show insignlfica
contributor, from working and breathing losses (increases of -0.06 tpy uncontrolled; —0.002 tpy.controlled).
A limit for NOx will not be included in the permits since NOx emissions from combustion of gas frorn all sources routed to common combustors associate
rsholdsfor NOx
eration anlaysis on
he sample to quantify and: characterize
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point #
0101
Process # SCC Code
01
th this point (00 0, 012, 014).is less than reporting
Uncontrolled
'Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons Produced Water throu
PM2.5 0.00 0 lb/1,000 gallons Produced Water throu
SOx *REF! d lb/1,000 gallons Produced Water throu
NOx 9.00 0 lb/1,000 gallons Produced Water throu
VOC C.z'.5 92 lb/1,000 gallons Produced Water throu
CO 0<Of 0 - Ib/1,000. gallons Produced Water throu
Benzene 0.01 91 lb/1,000 gallons Produced Water throu
Toluene 0,00 s, 1b/1,000 gallons Produced Water th rou
Ethylbenzene 0.00 97 lb/1,000 gallons Produced Water throu
Xylene 9,v^u 97 lb/1,000 gallons Produced Water throu
n -Hexane GAG 97 Ih/1,000 gallons Produced Water throu
224 TMP 0;00 57 16/1,000 gallons Produced Water throu
CAUSBfisskl6aNes\Desktop \Remote Work \My Packages Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulatian 3 Parts and B -ADEN and Permit Requirements
S5 c. is in the NemAttainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, section ll.D.S.a)?
2. Produced Water Tanks have no grandfathering provisions
3. Are total facility uncontrolled VOC emissions greater than STPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)7
You finonnulient,13ist worsets,n the Non-nuolnment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY (Regulation 3, Part A, Section ll.D.l.a)?
2. Produced WaterTanks have no grandfathering provisions
3. Are total facility uncontrolled VOC emissions greaterthan 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7
Ea_, -e motfr,: a permit
Colorado Regulation', Part D, Section LOP & G
1. Is this storage tank located In the 8 -hr ozone control area or any oznon-attainment area or attainment/maintenance area (Regulation 7, Part D, Section l.A.1)7
2, Is this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation 7, Part O, Section IA.1)7
3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section 1.G)?
4. Doemhis storage tank contain condensate?
5. Does this storage tank exhibit "Flash"(e.g. storing non -stabilized liquids) emissions (Regulation 7, part D, Section l.G.2)?
6. Are uncontrolled actual emissions of this storage tank equalto orgreMer than 2 tons per year VOC (Regulation 7, Part D, Section 10.3.a ii)?
IStotu-suhie oRexi4at -,..c i.C.F
■
Part D, Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Part%Section I.C.2—Emission Estimation Procedures
Part D, Section I.D—Emissions Control Requirements
Part 0, Section I.6— Monitoring
Part 0, Section I.F—Recordkeeping and Reporting
Storuge rank Is not subject to Regtoatiou>, Sennen`..G
Part D, Section 1.G.2- Emissions Control Requirements
Part D, Section I.C.l.a and b —General Requirements for Air Pollution Control Equipment —Prevention of leakage
Colorado Regulation]. Part D. Section II
1. Is this storage tank located at a transmission/storage facility?
2. Is this storage tank' located at an oil and gas exploration and production operation, well production facilRiP,natural gas compressor stations or natural gas processing plant (Regulation], Part O, Section lLC)7
3. Does this storage tank have a fixed roof (Regulation 7, Part O, Section lLA.2O)7
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tans per year VOC (Regulation ], Part D, Section ll.Cl.c)7
ISta subject toReguNYInu .-act
Part 0, Section ILB—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D, Section II.C.1- Emissions Control and Monitoring Provisions
Part 0, Section II.C.3 - Recordkeeping Requirements
5. Does the storage tank contain only "stabilized'liquids (Regulation 7, Part O, Section ll.C.2.b)?
Igor - a,.kissubincts'oRegulatiou2.PA,
D.56et!u
Part 0, Section II.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located atafacility that was modified on ar after May 1, 2020, such
6. that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part O, Section lLC4.a.(i)?
IS-cragetank isstbiocttoRegulat'san7.?e,.D,5ec il:.:.3.ali),b-f
Is the controlled storage tank located at a well piaduciion facility, natural gas compressor natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or afterlanuary 1,
7. 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section II.C.4.a.(II)7 M1a
I 5.r .. Tank in not sublect to Renola=io<7,t,tD.5c Jan II.C.0.+(ill. b -f
40 CFR, Part 6O.5ubnart Kb. Standards of Perfarmancefor Volatile Organic Dquld Storage Vessels
1. Is the individual storage vessel capacity greaterthan or equal to 75 cubic meters (0) 1-472 BBLs] (40 CFR 6O.11O6(a))7
2. Does the storage vessel meet the following exemption in 6O.111b(d)(4)7
a. Does the vessel has a design capacity less than or equal to 1,589.874 le [-10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custody transfer' as defined In 6O.11167
3, Was this storage vessel constructed,reconstructed, or modified (see definitions 4O CFR, COT) after luly 23, 1994 (40 CFR02.110b1a))7
4. Does the tank meet the definition of "storage vessel"' in 6o.111b7
5. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined In 6O.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa MO] psi] and without emissions to the atmosphere (6O.11O6(d)(2))7; or
b. The design capacity is greaterthan or equalto .1 ms (`950 BBL) and stores a liquid with a maximum true vapor prmsuree less than 35 kPa (6O.11O6(b))?; or
c. The design capacity Is greater than or equal to 75 Ma 0472 BBL] but less than 151 ms [-950 BBL) and stores a liquid with a maximum true vapor pressuree less than 15.0 kna(60.11Ob(b))7
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity Is greater than or equalto 151 ma [`950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 35 kPa but less than 5.2 kPa?; or
b. The design capacity Is greater than or equalto 75 Ms (^'472 BBL) but less than 151 ms [-950 BBL] and stores a liquid with a maximum true vapor pressure greaterthan or equal to 150 kPa but less than 27:6 kPa7
I5torageTank is not subject to nISPs u •
Ye
Yes
No
No
Yes
No
Vagr:':�e
40 CFR. Part 60. Subpart 0000/0000a. Standards of Performance for Crude 011 and Natural Gas Productfon,Transinission and Distribution
1. Is this storage vessel located at a facility In the onshore o8 and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this storage vessel constructed, reconstrvrted, or modified (see definitions 4O CFR,502) between August 23, 2011 and September., 2015?
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 4OCFR, 5O2) after September 38, 20157
4. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tans per year?
5. Does this storage vessel meet the definition of"storage vessel"' per 60.5430/60.54300
6. Is the storage vessel sub ert to and controlled In accordance with requirements for Mora vessels In 4O CFR Part 6O Sub art Kb or. CFR Part 63 Sub art HH7
I=to-ar c Tenk is not subieetto NSPSOO.C
(Nate: If a storage vessel Is previously determined to he subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC an the applicability determination date, it should remain subject. NSPS 0000/0000a per
6O5365(e)(2)/6O.5365a(e)(2) even if potential VOC emissians drop below 6 tons per year]
40 CfR, Part 63, Subpart MALT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an all and natural gas produrtion facility that meets either of the following criteria:
a. A facility that processes, upgrades or Mores hydrocarbon liquids'. (52.76O(02)n OR
b. A facility that processes, upgrades or stares natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(an31)?
2. Is the tank located at a facility that is majors for HAPs?
3. Does thetank meet the definition of"storage vessel"°in 63.7617
4. Does the tank meet the definition of'storage vessel with the potential for flash emissions'' per 63.7617
5. Is the tanksubject to mmrol requirements under 4O CFR Part 6O, Subpart Kb or Sub art 00007
I?radu_ed Water Sinregetank n nix suninntun ndt.CT HH
Subpart A, General provisions per 463.764 (a) Table 2
463.766- Emissions Control Standards
555.775 -Monitoring
Recordkeeping
03.775 -Reporting
RAC' Review
RACT review is required if Regulation 7 does not apply AND if the milk is In the non -attainment area. lithe tank meets bath criteria, then review RAC' requirements.
Source Requires an APEN. Go to
Go to next question
Souris Requires a permit
Continue - You have Indicated th
Continue - You have Indicated th
Storage Tank Is not subject to Re
on ue- You have Indicated th
Go to the next question- You ha
Go to the neat question
Source issubjectto parts of Reg,
'Source is subject to all provision,
lea to the next question
Go to the next question
Storage Tank is not subject NSPS
Yes
Cominue - You have indicated th
Storage Tank Is not subject NSPS
Go to the next question
Storage Tank is not subject NSPS
Mal
Mum
Ives (continue- You have Indicated th
Storage Tank not subject MAC
Hydrocarbon Loadout Emissions inventory
Section 01 -Administrative Information
'Facility Al RS ID:
123
County
9FED
Plant
011
Point
Section 02 -Equipment Description Details
Detailed Emissions Unit Loadout of condensate fromtanks to tank trucks
Description:
Emission Control Device Enclosed Combustors.
Description:
Is this loadout controlled?
Requested Overall VOC & HAP Control Efficiency X:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded=
'Requested Permit Limit Throughput =
Yes
95
83,688 Barrels (bbl) per year
92,057 Barrels (bbl) per year
92,057 Barrels (bbl) per year
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Actual Volume of waste gas emitted per year =
Requested Volume of waste gas emitted per year=
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2345.42 Btu/scf
21162_ scf/year
2„3792 scf/Year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Requested Monthly Throughput= 7819 Barrels (bbl) per month
520 MMBTU per year
572 MMBTU per year
572 MMBTU per year
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
Section 04 -Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
scfh
Btu/scf
C.0 MMscf/yr
0,0 MMBTU/yr
e state default emissions factors may be used to estimate emissions.
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl)
(lb/bbl)
(Volume Loaded)
(Volume Loaded)
Emission Factor Source
VOC
Benzene
Toluene
Ethylbenzene
X lene
n -Hexane
224 TMP
2.360E-01
4.10E-04
O.OOEl-00
0.00E+00
000500
3.60E-03
0.09E,00
Control Device
Pollutant
0.00E 09
1.80E-04
0.00E+00
'" tiSste Loadout State E.F.
'• , _ _ —te Loadout State E.f '-:
— e Loadout State E.F.
—tetoadout State E.F.
Loadout State E.F.
eiLoadout State E.F.
e Loadout State E.F.
Uncontrolled
(Ib/MMBtu)
Uncontrolled
0b/bbp
(waste heat combusted)
(Volume Loaded)
Emission Factor Source
PM10
PM2.5
SOx
NOx
0.0075
0.0075
0.0006
0.0680
0.3100 1.93E-03
Pilot Light Emissions
CO
Pollutant
Uncontrolled
(Ib/MMBtu)
Uncontrolled
(Ib/MMscf)
(Pilot Gas
Throughput)
(Waste Heat Combested)
2Table 1.4-2 (PM10/PM.2.5):
�'2Table 1.4-2 (PM10/PM.25)
able 1.4-2 (50x)
pier 13.5Industrial Flares(NOx)
er.13.5 Industrial Flares (CO)
Emission Factor Source
PM10
PM2.5
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
SOx
NOx
VOC
CO
18 dr:lasers\beades\Desktop \Remote Work \My Packages\Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP3
Hydrocarbon L oadout Emissions Invent
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
Itons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
Itons/year) (tans/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
50x
NOx
VOC
CO
0.00
0.00
0.00
0.00
0,010
0
0.00
0.00
Chid
- 0.00
G.00
0
0.00
0.00
..._,.
0.00
OM
0
0.02
0.02
_..:_
0.02
0019
3
10.86
9.88
_..,.
10.86
0,543
92
0.09
G,08
0.08
0.09
G.03 -s
15
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/Year)
Requested Perrnit Limits
Uncontrolled Controlled
Ilbs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene r
Xylene
n -Hexane
224 TMP
38
34
2
38
2
0
0
0
0
0
.. 0
0
J
0
0
0
0
,.
0
0
331
301
331
17
0
0
0
G
_
Section 06- Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
The hydrocarbon liquids loadout source is subject to Residatice 7 Pant O Section II.C.S.
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 Technical Analysis Notes
giistorage tanks at this facility feed liquids to apipeline via lease automated custody transfer unit(LACT). This point addresses loadout emissions when truck loading is necessary. There are check valves to ensure that the liquid loading emissions cannot
- flow back to the water tanks or the tanker truck during loadout and vapors are routed to enclosed combustors.
Applicant used data from ProMax to estimate vapors combusted from loadout. This results in a more conservative(i.e. higher emssions) than when calculated using methodology (and default values in Memo 14-03) generally used by the Division. As such,
talcs provided by applicant will be accepted. _
A limit for NOx will not be included in the permits since NOx emissions from combustion of gas from all sources routed to common combustors associated with this point (007, 009, 011, 013) is less than reporting thresholds for NOx.
Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only).
AIRS Point ti
011
Process if SCC Code
O3 4-000001-32 Crude Oil: Submerged __awing Normal Service i =0.6)
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 _.00 0 lb/1,000 gallons transferred
5Ox 0-00 0 lb/1,000 gallons transferred
NOx GUI 0 lb/1,000 gallons transferred
VOC _.., 95 lb/1,000 gallons transferred
CO _.05 0 lb/1,000 gallons transferred
Benzene 0.01 95 lb/1,000 gallons transferred
Toluene 0.00 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.00 95 lb/1,000 gallons transferred
n -Hexane 0.09 95 lb/1,000 gallons transferred
224 TMP 0.00. 95 lb/1,000 gallons transferred
)
19 cff$Wsers\beades\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received In Oct 2020\20WE0809.CP1
Hydrocarbon Load°. Regulatory Analysis Worksheet
The regulatory requirements below are determined based an requested emissions and throughput.
Colorado Regulation 3 ParteA and 9-APEN and Permit Requirements
[Source No the allon Alvismen. AN,
ATTAINMENT
ntrdled actual emissions from n is pollutants from this individual so ter Mani PY[Regulation 3, Part A, Section 11.O.1.ai?
2. Are
rthe loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.11?
3. IS Mel.. ration loading less than 10,000 Bailors(238 BBls) of vede oil per day on an annual average basis?
Is the loadout operation loading less.. 6,750 bbls per year of condense. viasplash PIP
fil
5. Is Me load out operation loading less Man tin 16,308 bids per year of condensate Ma submerged fill procedure?
6. Memdlfacility uncontrolled VOCemissions greater Man 5 TN,N. grearerthan 10TV&CO emissions greater than mar, faeguhau'm 3, Part 52Seclion 11.0.3)?
-. r
[4n « eradicated that-ucr_c a.L.r.,.r>Yta.nment Area
NONATTAINMENT ha
1. Are polled emissions from arty criteria pollutants from this individual source greater than1TPY (Regulation 3, fart A,Secb'n Il.e.l.a)?
2. Is the loadout located at an exploration and CroducVn site (e.g., well pad) [Regulation 3, Part %SectinIGO.l.11i
Is the leadwt0,ratlon loading less Man 10,000 gallons 123rBets) d a oil per day man annual average basis?
A.Is the loadout ration loading lea Man 6,750 bids per r &condensate viasplash FIR
5. IsMe loadout operation loading less than 16,308 obis per year &condensatevia submerged fill procedure?
5. Are total facility uncontrolled VOC emissions from the greater Man 2 TN, NOx greater than 5 TPY orCO emissions greater than 20 TPY(Regulation 3, Part B, Section 11.0.2)?
•
Colorado Regulation 7 Part 0 Section
2. is t. condensate Storage tank hydrocarbon liqUids loadout located eta well production natUral gaS CoMpreSSOr station or natural gas processing plant?
2 the facility have rhydrocarbon :.to transport vehicles greater Man or equal ts_5,Ea arrels?
ITV we is ve-Wastar, hm PartD a;e ae5.
Svtion S.a.lil-Compliance Schedule
Settion II.GS.a.liil-Operation without Venting
section S.a.fii)-Load°[ Equipment Operation and Maimenance
Section .a.(iy)-Loadwtobsenatians and Operator Training
Section II.C.5.a.(v)-Records
Section II.C.S.a.(VII-Requirements for Mr Pollution Control Equipment
Disclaimer
This document euista operators teth detenMnirg applicability of certain requirements of the Clean Alr Act, its implementing regulations, and Air Quality Control Commission regulations. This document's rota
rule oregulation, and the analysis it contains may not apply toe padkuiaraluab'n based upon the individual facts and circumstances. The document does not change or substitute for any law, regulation or
any other legally binding requirement and is not legally enforceable. In the event deny cant list between the language of this document end the language tithe Mean Air Act., its implementing regulations,
and Air Quality CodMCommissbr regulations, the language d the statute or regulation will control. The use of =amendatory language such es "recommend," -may,"-should-and tan.' Is Intended to
describe APCQ lntemeetegoae and recommendations. Mandatory terminology such as 'Must. and "required. are intend tadescdbe controlling requirements and the terms tithe Clean AirAct and Air
Quedty Control Commission regulations, but fits document does not establish legaly bind g requirements N and (itself..
YF% NY
Go to neat question
Go bathe nee question
Go to next question
Go to next question
Go to next question
The loadout requires a permit
Go to next question.
Source is subject to Regulation T Part°Section II.C5.
12
Hydrocarbon Loadout Ein ssions :r=ye!
Section 01 -Administrative Information
'Facility AlRs ID:
c , 923
County
&EEO . 012
Plant Point
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
J:oadont ofcondensatet:Min tanks Fo tank trucks
Requested Overall VOC & HAP Control Efficiency %:
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
Requested Permit Limit Throughput=
Potential to Emit (PTE) Volume Loaded =
44,117 Barrels (bbl) per year
..-1` 54,095 Barrels (bbl) per year
F."'-54,095 Barrels (bbl) per year
Requested Monthly Throughput= 4594 Barrels(hbl) per month
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Actual Volume of waste gas emitted per year=
Requested Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
245`.42 Btu/scf
13305 scf/year
143.::4 scf/year
Potential to Emit (PTE) heat contest of waste gas routed to combustion device =
305 MMBTU per year
3366 MMBTU per year
335 MMBTU per year
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
Section 04- Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
scfh
Btu/scf
00 MMscf/yr
00 MMBTU/yr
Tnr stated e.._s,.:.',to:+estm::re
Emission Factors
Hydrocarbon Loadout
Emission Factor Source
Pollutant
Uncontrolled Controlled
(16/661) (lb/bbl)
(Volume Loaded)
(Volume Loaded)
VOC
2.36E-07.
1.16E-02
Condensate Loadout State E.F.
Condensate Loadout State E.F.
Indensata toadout St to E F.
CondensateCrindensate LoadoutS ie E. F.
Condensate toadout to E.F.
Condensate Loadout State E.F.
Condensate LoadoutSteteE.F.:-
Benzene
4.10E-04
205E-05
O.DOE IO
Toluene
C00eri0
Ethylbenzene
3006,00
0.00E+90
Xylene
3.00E,00
O.00EnC0
n -Hexane
360E.03
187E-04
224 TMP
0.00E+n0
0.00E-00
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/b131)
()waste heat combusted)
(Volume Loaded)
PM10
.0.0075
4.63E-05
'>42 Tab
.242 a
AP -42 Chapter 13.5- Industrial Flar'es(NOx)
AP -42 Chapter 13.5 industrial Hares (CO)
PM2.5
.0.0075
4.63E-05
SOx
0.0006
365606
NOx
0.0680 - -
4.22E-04
CO
0.3100
1.93E-03
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf)
(Waste Heat Combusted)
(Pilot Gas
Throughput)
PM10
0.0E09
PM2.5
0.0000
SOx
0.0000
NOx
- ..
0.0300
VOC
0 0000
CO
..
0.0000
21 rlf:9tllsers\beades\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WEOB09.CP3
Hydrocarbon Loadout Emissions Inventory
Section OS - Emissions Inventory
-
Criteria Pollutants
Potential to Emit
Uncontrolled
(tans/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM30 -
PM2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
9
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0,01
0.01
0,01
9.01
0.011
2
6.38
5,80
0.29
6.38
0.319
54
0.05
OAS
0.05
0.05
0.052
.,
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
22
20
1
22
1
9
0
0
0
0
0
0
0
0
0
0
9
9
0
0
195
177
9
195
10
0
0
0
p
0
Section 06 - Regulatory Summary Analysis _
Regulation 3, Parts A, B
Sourcerequires a permit
Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
The hydrocarbon liquids loadout source is subject to Regulation 7 Part O Section II.C5.
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 - Technical Analysis Notes
The storage tanks at this facility feed liquids to a pipeline via lease automated custody transfer unit (LACT). This point addresses loadout emissions when truck loading is necessary. There are check valves to ensure that the liquid loading emissions cannot
flow back to the water tanks or the tanker truck during loadout and vapors are routed to enclosed combustors.
Applicant used data from ProMax to estimate vaporscombusted from. loadout This results in a more conservative (i.e.::higher anissions) than when calculated using methodology (and default values in Memo 14-03) generally used by the Di on. As such, .
calcs provided by applicant will be accepted.
A limit for NOx will not be included in the permits since NOx emissions from combustion of gas from all sources routed to comnon combustors associated with this point (008, 010, 012, 014) is less than reporting thresholds for NOx.
Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only'
AIRS Point N
012
Process #
O1
SCC Code
4-06-091-32 Crude Oil: Submerged Loading Normal S.erdce (So0.6).-
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
50x 0.00 0 lb/1,000 gallons transferred
NOx 0.01 0 lb/1,000 gallons transferred
VOC 5.6 95 lb/1,000 gallons transferred
CO 9.05 0 lb/1,000 gallons transferred
Benzene 0.01 95 16/1,000 gallons transferred
Toluene 0.00 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 16/1,000 gallons transferred
Xylene 0.00 95 lb/1,000 gallons transferred
n -Hexane 0.09 9$ lb/1,000 gallons transferred
224. TMP 0,00 95 lb/1,000 gallons transferred
22 aHLVIlsers\beades\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Hydrocarbon loadott Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
Colorado Regulation 3 Parts end B -MEN and Permit Requlremertla
lEice eOmmn Innnsta,nm_:. Pries
AINMFM
1. emlssiom loam any criteria pollutants Imo Ws ell d) (Regulation
3. greater than section v. DIRegulacan3, Partq Section II.O.I.a))
2 s[he loadout loratedm.operatioan n M .,nd pss tha 10.60 gall ns(238l MIof crude Parts,onannual
3. k the load°t operation loading less than 1,.000 gallons year fcmdecrude oil per day onanannual average basis)
4. Is the loadout oration loading less than 66]50 bbbss per yeyear ofconndensatvia splasherg
5. ktheload°topentionIwaion less Man Man thiscervre ofcondensateC0emgadrill procedure?
6. Are total polity uemrtrdlad VOC emission greater Nan5TPY. NOx greater than to TPYVCO emissions greater Paolo STY (Regulation 3,Part &Section 11.031?
I'rnMee MEG.. that tab,. in the N e ..mmen_Arm
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from Mk individual source greater than lin.(Regulation 3, Part A, Section ll.O.1411
. Is the loadout located. an exploration and pmducnon Me (e.g., well pad) lRegelatl'on 3, Pan B, Section COIN?
3. Is Me load°t operation loading less than 10,600 gallons 1238 BBL. of crude oil per day on an annual average basis)
4 Me load. operation loading less than 6,750 bb0 per year of cone.. via splash rail)
5. Is the load°. operation loading less Man 16,308 bbls per year of condense. via submerged fill pr°edure?
6. Are total facility uncontrolled VOC emissions from the greater Nan 2TPY, NOx greater than 5 TPy or Co emissions greater Man 10T. [Regulation 3, Par. Section 11.0
t
Colorado Regulation T Part 0 Section 1665.
1. Is this condensate storage tank hydrocarbon liquids loadout Mca.d at a well production facility, natural gas compressor station nr natural gas processing plant)
2. Oces the facility haveathroughput of hydrocarbon Ilpuidz loadout to transport vehicles greater than or equal to 5,000 barrels?
firMv
Section II.C.S.a.10-Compliance Schedule
Secdon S.a.(.-Operation without Venting
Section S.a.liii)-loadout Equipment Opemdonand Maintenance
Section ll.C.5.a.liv)-Load°. observations and OperatorTraining
Section II.C.S.a.lvl-Rees.
Section II.CS.a.lvil-Requirements for NT Pollution Cenral Equipment
Dix -claimer
This &cement assists operators with determining applicability ofcertain requirements of the Glean Air Act its implementing rcgulab'wu, ard/lirquay Cwrtol Commission regulations. This dcmmnt is net a
rule orregulaton, and the anaysis it contains may not apply toe particular situation based upon the Individual facts and circumstances. This Ncument d®a'mRchange cc substiMe for any law, regulation, or
any other *rally bird, requirement and is not legally enforceable In the event any male, between the lergue5a of this document and the language d the Clean Air Act, its implementing regulations,
/ m
and Air (reality Control Commission regulations, the language tithe statute or regulation will control The use ofnanmandatwy language such as.'ecommed,""may,""should,"and "can,"Is intended to
describe PPM interpretations and reco ,n.nJ.rtions. Mandatory terminology such as "must- and'YequirecT are intended to describe controlling regwremands under the tent. of the Clean Air Act and Air
Oust, Coned Commission regulator, but this document rtes not establish legally hinting requirements in and of dseM.
No<<
No
No
Go to neat question.
Go M the next question
Go to ext question
No M next question
Coto.. question
The I®dout requires a permit
Go to xSource is subject to Regulation T Part 0 Section ILG5.
Separator Venting Emissions Inventory
Section 01 - Administrative Information
Facility AlRs ID:
123
County
9FED''
Plant
013
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Gas venting from low-pressure separators (bulk separators) to enclosed combustors during vapor recovery unit (VRU) downtime. This
point is for gas vented from separators associated with Anderson wells.
Enclosed' combustors
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Natural-Gasuilented �y-. ,
Ves meteris currently ms�alled and q�e atfonal
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
0.7 MMscf per year
95
Requested Permit Limit Throughput=. 1.441 MMscf per year
Requested Monthly Throughput= _._ MMscf per month
I
Potential to Emit (PTE) Throughput =
MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
'.. scfh
Btu/scf
0.0 MMscf/yr
Section 04 - Emissions Factors & Methodologies
Description
The bulk separator (low pressure separator) receives condensate that has been separated at the inlet separators(approx. $6psi)aquids flash in the bulk separator and are emitted to the enclosed combustors during VRU
M W 37.1
Weight %
Other inert
CO2
N2
methane
ethane
0.00
3:16
0.09
12.83
17.07
propane
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
31
4.82
15.95
3.72
4.74
0:40
27
0.30
2.21
0.89
0.29
0.00
0.14
0.11
0.01
0.02
0.66
Total
VOC Wt %
Ib/Ib-mol Displacement Equation
Ex=Q'MW•XX/C
C:\UsPkWelfiles\Desktop\Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Separator Venting Emissions Inventory
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(Ib/MMscf) (Ib/MMscf)
(Gas Throughput)
(Gas Throughput)
Emission Factor Source
VOC
65376.7045
32"68.835?
Benzene
Toluene
141.2301
104.2599
11.8344
23.2775
7.0615
5.2130
0.5917
1,1639
62.0229
0,0391
Ethylhenzene
Xylene
n -Hexane
224 TMP
1240.4576
0.7824
Pollutant
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) Ib/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
Emission Factor Source
PM10
PM2.5
0.0075 ,
0.0075.
0.0006
0.0680..
0.3100AV
15,5840
15.5840
1.2303
SOx
NOx
CO
142,2247
6483774
AP -42 Table 1:44 (PM10/PM3.5)
AP -42 Table 1.4-2 (PM10/PM 2.5)
AP 42 Table 1.4-2 (SOx)
AP -42 -Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
Pollutant
Pilot Light Emissions
Uncontrolled Uncontrolled
(Ib/MMBtu) Ib/MMscf
(Waste Heat
Combusted)
(Pilot Gas Throughput)
Emission Factor Source
PM10
PM2.5
0,0000
0.0000
0.0000
0.0000
0.0000
0.0000
SOx
NOx
VOC
CO
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.0
0.0
0.0
0,0
0.0
2
0.0
0.0
0.0
0,0
0.0
2
0.0
0,0
0,3
0.0
0.0
0
0.1
0.1
0.1
0.10
0.10
17
47.1
23.54
'_,18
47.07
2.354
400
0.5
0.2
0.2
0.47
0.467
79
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ihs/year) (113s/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylhenzene
Xylene
n -Hexane
224 IMP
203
102
_
203
10
150
75
4
150
8
17
9
0
17
1
34
17
_
34
2
1786
893
s
1786
89
1
i
0
1
0
Section 06 - Reeulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section II.B, F
Regulation 7, Part 0, Section II.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is subject to Regulation 7, Part C--, Section 11.6.2, F
The control device for sass separator is net subject to Regulation 7, part O, Section IL6,2.o
CAUsgEsIdfe'laties\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Separator Venting; Emissions Inventory
r
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has
not been modified (e.g., no new wells brought an -line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific g_1 sample from the equipment being permitted and conduct an emission factor analysis to demonstrate
that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application on an annual basis,
Will the operator have a meter installed and operational upon startup of this point?
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180
days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a.control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial andperiodic compliance testing in accordance with P5 Memo 20-02
»' a ha.e mdieet_4 het Js_.;_,.mto _d mn , -.a rr.,l . ,-.-.._- _d.l he fmiL-s.n_ quc;t�eas do not -ek...re os. a is�+e
Section 08 -Technical Analysis Notes
Gas separated from produced liquids due to pressure drop in the bulk separators (flash gas) is compressed into the sales gas line via compressors: In the case that VRUs are down; the separator gas is combusted at ECDs. A gas flow meter`
measures the volume of gas routed to the combustors, -
A limit for NOx will not be included in the permits since NOx emissions from combustion of gas from all sources routed to common combustors associated with this point (007,:009, 011, 013) is less than reporting thresholds for NOx.
AIRS Point #
013
Process # SCC Code
01 3-"0-40.1-60 Flares
Pollutant Uncontrolled Emissions Factor Control % Units
PM10
PM2.5
SOx
NOx
VOC
co
Benzene
Toluene
Ethylhenzene
Xylene
n -Hexane
224 TMP
1s.6
15.6
1.2
142.2
65376.7
648.4
141.2
104.3
11.8
23.3
1240.5
0.8
JS il;r.?--rt<`=J75l;.f
4 Iblt9MSCF
95 Ib; fe5irtSCF
95 ihiMPASCF
94 lbjF.9M5CF
94 iloWaASCF
94 list elSCF
95 i6(F`A4ASCF
Section 09 -SCC Coding and Emissions Factors (For Inventory Use_Only),
C:\Us2EskliGatles\Desktop\Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Stnn the NanJAttalnment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.S.a)7
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)7
'Von bade indicated that source Ls iv. the Nor,JAttalnment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section II.D.l.a)7
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, section 11.0.2)7
So,Ace requires a permit
Colorado Regulation 7, Part 0, Section II
1. Was the well newly constructed, hydraulically fractured, or recotnpleted an or after August 1, 20147
'Source is subject to Regulation 7. Part 0, Seaton
Section 11.8.2— General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section ITT - Control of emissions from well production facilities
Alternative Emissions Control (Optional Section).
Is this separator controlled by a backup or alternate combustion device (i.e., not the primary control device) that is not enclosed?
IThe control device for this separator is net subject to Regulation 7. Part 0, Saxton
Section I1.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with detemrining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any congict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," `may,"'should,"and "can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Source Re
Source Re
The contri
Separator Venting Emissions Inventory
Section 01 -Administrative Information
Facility AIRS ID:
123
County
9FED
Plant
014
Point
Section 02 - Equipment Description Details
Gas venting from low-pressure separators (bulk separators) to enclosed combustors during vapor recoveryunit (VRU) downtime. This
point is for gas vented from separators associated with Shull wells.
Detailed Emissions Unit Description:
Enclosed combustors
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Separator
Actual Throughput =
0.96. MMscf per year
95
Requested Permit Limit Throughput =..::. 1.92:. MMscf per year
Requested Monthly Throughput= 0.2 MMscf per month
Potential to Emit (PTE) Throughput =
MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
2091.5 Btu/scf
scf/bbl
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
scfh
Btu/scf
0.0 MMscf/yr
Section 04- Emissions Factors & Methodologies
Description
The bulk separator (low pressure separator) receives condensate that has been separated at the inlet separators (approx. 86psi). Liquids flash in the bulk separator and are emitted to the enclosed combustors during VRU
calculate emission factors..
MW
37:1
Weight %
Other inert
0.0
C02
3.2
N2
0.1
methane
12.8
ethane
. 17.1
propane
.: 31.3
isobutane
4.8
n -butane
16.0
isopentane
3.7
n -pentane
4.7
ryclopentane
0.4
n -Hexane
1.3
cyclohexane
0.3
Other hexanes
2.2
heptanes
0.9
methylcyclohexane
rr 0:3
224-TMP
0.0
Benzene
0.1
Toluene
0.1
Ethylbenzene
0.0
Xylenes
0.0
C8+ Heavies
............. 0.7
Total
VOC Wt %
Ib/Ib-cool Displacement Equation
Ex=Q'MW'XX/C
C:\Use&kifekles\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Separator Venting Emissions'nventoly
Pollutant
Separator Venting
Uncontrolled
(Ib/IVINIscf)
Controlled
(Ib/MMscf)
65376.7045
1240:4576 EME
Pollutant
Pollutant
Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
Ib/MMscf
(Gas Throughput)
MMIBEINIMI
�. O,O68Q
..:0.3100 41
Pilot Light Emissions
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
Ib/MMscf
(Pilot Gas Throughput)
Section OS - Emissions Inventory
6.0000
Emission Factor Source
Emission Factor Source
Emission Factor Source
Criteria Pollutants
Potential to Emit
Uncontrolled
(tans/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.0
0.0
0.0
0.0
0.0
3
0.0
0.0
0.0
0.0
0.0
3
0.0
0.0
0.0
0 0
0.0
0
0.1
0.1
0.1
0.14
0,14
23
62.8
31.38
1.57
62.76
3.133
533
0.6
0.3
0.3
0.62
0.622
106
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TM
271
136
7
271
1e
200
1v`0
..
200
10
23
11
1
23
1
45
22
1
45
2
2382
1191
60
2382
119
2
_
0
2
0
Section 06-Regulatary Sumn Analysis
Regulation 3, Parts A, B
Regulation 7, Part D, Section II.B, F
Regulation 7, Part D, Section 11.8.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is sobiect to Regulation 7, Part O, Section 118,2, F
The control device for this separator is not subject to Regulation 7, Part D, Section U.8.2.e
CAUsaE;ktielkles\Desktop \Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Separator Venting Emissions inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?Y,esq
This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if 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 Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate
that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
If yes, the permit will contain: -
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Yes
If no, the permit Will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180
days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
ae m mitared process iaraiuex=.. I,..r_.ural ga..en#=;#- Tha O11Oe/ing ou
Section 08 -Technical Analysis Notes
Gas separated from produced liquids due to pressure drop in the bulk separators (flash gas) is compressed into the sales gas line via compressors. In the case that VRUs are down, the separator gas is combusted at ECDs. A gas flow meter
measures the volume of gas routed to the combustors.., -
A limit for. NOx will not be included In the permits since NOx emissions from combustion of gas from all sourcesrouted to common combustors associated with this point (008, 010, 012,014) is less tha
Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only).
AIRS Point #
014
Process if SCC Code
01 3-10-001-80 Flares
ortingthresholds for NOx.
Pollutant Uncontrolled Emissions Factor Control % Units
PM10 0 Ih/f MSCF
PM2.5 ...... 0' IbIMMSCF
SOx 1.2 0 lb/MMSCF
NOx 142.2 0 ihrM SCF
VOC 65376.7 95 =6/ MMSCF
CO 648.4 0 Ib/MM5CF
Benzene 141.2 95 Ihi-MMSCF
Toluene 104.3 95 Ib/MMSCF
Ethylbenzene 11.8 95 Ib/MMSCF
Xylene 23.3 95 Ib/MiMSCF
n -Hexane 1240.5 95 Ib/Mlv?5CF
224 TMP 0.8 95 lb;'MMSCF
C:\Us8tbldldaldes\Desktop\Remote Work \My Packages \Package 436017 (Mallard Anderson -Shull) received in Oct 2020\20WE0809.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below ore determined based.on requested emissions.
Colorado Regulation 3 Parts and B-APEN and Permit Requirements
Source is in the Non.Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, section ll.0.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 30 TPY or CO emissions greater than to TPY (Regulation 3, Part B, Section 11.0.3)?
km have indicated that sour..e Is In Me Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than l TPY (Regulation 3, Part A, Section ll.O.l.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section 11.0.2)?
ISqur requires a permit
Colorado Regulation T, Part D, Section 11
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014?
!Smote is subject to Regulation:. Part 0, Section ll.B.2,F
Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F - Control of emissions from well production facilities
Alternative Emissions Control (Optional Section).
a. Is this separator controlled by a back-up or alternate combustion device (Le., not the primary control device) that is not enclosed?
'The co. of device for this sepermet is not subject to Regulation i, Fart 0, Section li.B.2.e
Section II.B.2.e — Altemative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Qualify Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change orsubstitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend,"'may,""should," and 'can,"is
intended to describe APCD interpretations and recommendation. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Source Re
Source Re
'Source is�
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Mallard Exploration, LLC
123
9FED
Anderson Facility
History File Edit Date
Ozone Status
12/3/2020
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
1.6
40.6
0.0
7.2
0.4
From Feb 2020 tab
Previous Permitted Facility total
0.0
0.0
0.0
0.0
1.6
39.8
0.0
7.2
0.4
tiQ'i
0,I
L r M -ma r .yb' i � i l?sP>17
0.0
0.0
ON rep, (i c,a Iv^pdi. 4)15p
.-
147 N 44
LoadoiAt ., .j , c,il to N'iii'..,, ;-
0.0
0.0
, i._a U 2 !"
,S1
PivEi_;7
:.I s u,g,rr
0.0
00
P02
.. ;,!p
0.0
0.0
006
GG'10
Cnd tanks 5-500 bbl (andersonl
Converted to point 007
Loadout(anderson)
Converted to Point 011
PW water tanks 5-500 bbl (anderson)
Converted to point 009
Separator venting tnderson)
Convened to point 013
Cnd tanks 5-500 bbl (Shull)
Converted to point 006
Loadout (shun
Converted to point 012
PW tanks .5-500 bbl ishulll
Converted to point 0'10
Separator' venting (snug)
Converted to point 014
007
20WE0809
Condensate tanks (Anderson)
0.8
1,226.8
3.4
27.4
0.8
19.04
3.4
0.4
New
008
20WE0810
Condensate tanks (Shull)
0.7
682.7
3.2
15.2
0.7
17.97
3.3
0.4
New
009
20WE0811
Produced water tanks (Anderson)
0.0
7.8
0.1
0.4
0.0
0.20
0.1
0.0
New
010
20WE0812
Produced water tanks (Shull)
0.0
3.3
0.0
0.1
0.0
0.10
0.0
0.0
New
011
20WE0813
Loadout (Anderson)
0.0
10.9
0.1
0.2
0.0
0.55
0.1
0.0
New
012
20WE0814
Loadout (Shull)
0.0
6.4
0.1
0.1
0.0
0.32
0.1
0.0
New
013
20WE0815
Separator venting (Anderson)
0.1
47.07
0.5
1.1
0.1
2.36
0.5
0.1
New
014
20WE0816
Separator venting (Shull)
0.1
62.76
0.6
1.5
0.1
3.14
0.6
0.1
New
015
GP02
Cummins G5.9 (sn74409564)
10.6
1.20
11.7
0.1
0.4
0.60
1.7
0.1
New
016
GP02
Cummins G5.9 (sn:74110351)
10.6
1.20
11.7
0.1
0.4
0.60
1.7
0.1
New
XA
Compressor blowdowns
0.8
0.80
FACILITY TOTAL
0.0
0.0
0.0
0.0
22.9
2,050.9
0.0
31.3
46.2
0.0
0.0
0.0
0.0
2.6
45.7
0.0
11-.5
1.1
VOC: Syn Minor (NANSR, PSD and OP)
NOx: Minor (PSD, NANSR and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor n -hex & Total
ZZZZ: Syn Minor
Permitted Facility Total
0.0
0.0
0.0
0.0
22.9
2,050.1
0.0
31.3
46.2
0.0
0.0
0.0
0.0
2.6
44.9
0.0
11.5
1.1
Excludes units exempt from permits/APENs
(4) Chanige in Permitted Emissions
0.0
0.0
0.0
0.0
1.0
5.1
0.0
4.3
PN is required based on new syn minor limits
Note 1
Total VOC Facility Emissions (point and fugitive)
(4) Change in Total Permitted VOC emissions (point and fugitive)
45.7
Facility is eligible for GP02 since APEN
reportable emissions are below 45 tpy VOC.
Modeling is not required since emissions of all
pollutnats are below significance thresholds used
for modeling
5.1
Applicant removed all equipment from facility (pts 001-005) and replaced with new equipment (007-016) associated with new wells. Please see point information notes in PTS and email 9/29/20 (in records) for more information.
Note 2
This modification (which was originally authorized by GP10), is establishing new synthetic minor limits for new equimpent. In addition, increase of VOC is greater than 25 tpy VOC and as such, public notice is required.
Note 3
Total emissions from all "APEN reportable sources" is less than 45 tpy VOC (44.9 tpy). As such, source qualifies for GP02
Page 32 of 34
Printed 1/19/2021
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Mallard Exploration, LLC
County AIRS ID 123
Plant AIRS ID 9FED
Facility Name Anderson Facility
Emissions - uncontrolled (Ibs per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224TMP
TOTAL(tpy)
001
GP02
Cummins GTA855P1, sn: 25328617
0.0
002
18WE0944
Loadout of crude oil to trucks
0.0
003
18WE0947
Crude oil tanks (3000 bbl)
0.0
004
18WE1180
Produced water tanks (1000 bbl)
0.0
005
GP02
RICE 203 Hp
0.0
006
GP10
Cnd tanks 5-500 bbl (anderson)
0.0
Loadout (anderson)
0.0
PW water tanks 5-500 bbl (anderson)
0.0
Separator venting (anderson)
0.0
Cnd tanks 5-500 bbl (Shull)
0.0
Loadout (shull)
0.0
PW tanks 5-500 bbl (shull)
0.0
Separator venting (shull)
0.0
007
20WE0809
Condensate tanks (Anderson)
5702
4235
552
865
41279
2186
27.4
008
20WE0810
Condensate tanks (Shull)
3161
2348
306
480
22956
1214
15.2
009
20WE0811
Produced water tanks (Anderson)
325
145
9
15
210
0.4
010
20WE0812
Produced water tanks (Shull)
136
61
4
6
88
0.1
011
20WE0813
Loadout (Anderson)
38
331
0.2
012
20WE0814
Loadout (Shull)
22
195
0.1
013
20WE0815
Separator venting (Anderson)
203
150
17
34
1786
1
1.1
014
20WE0816
Separator venting (Shull)
271
200
23
45
2382
2
1.5
015
GP02
Cummins G5.9 (sn74409564)
119
16
15
18
0.1
016
GP02
Cummins G5.9 (sn:74110351)
119
16
15
18
0.1
TOTAL (tpy)
0.1
0.0
0.0
4.9
3.6
0.5
0.7
34.6
0.0
1.7
46.2
33
20W E0809.CP1
1/19/2021
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY- HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Mallard Exploration, LLC
123
9FED
Anderson Facility
Emissions with controls (lbs per vear
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
TOTAL (tpy)
001
GP02
Cummins GTA855P1, sn: 25328617
0.0
002
18WE0944
Loadout of crude oil to trucks
0.0
003
18WE0947
Crude oil tanks (3000 bbl)
0.0
004
18WE1180
Produced water tanks (1000 bbl)
0.0
005
GP02
RICE 203 Hp
0.0
006
GP10
Cnd tanks 5-500 bbl (anderson)
0.0
Loadout (anderson)
0.0
PW water tanks 5-500 bbl (anderson)
0.0
Separator venting (anderson)
0.0
Cnd tanks 5-500 bbl (Shull)
0.0
Loadout (shull)
0.0
PW tanks 5-500 bbl (shull)
0.0
Separator venting (shull)
0.0
007
20WE0809
Condensate tanks (Anderson)
87
65
8
13
629
33
0.4
008
20WE0810
Condensate tanks (Shull)
82
61
8
12
593
31
0.4 ,
009
20WE0811
Produced water tanks (Anderson)
8
4
1
1
5
0.0
010
20WE0812
Produced water tanks (Shull)
4
2
1
1
3
0.0
011
20WE0813
Loadout (Anderson)
2
17
0.0
012
20WE0814
Loadout (Shull)
1
10
0.0
013
20WE0815
Separator venting (Anderson)
10
8
1
2
89
0.1
014
20WE0816
Separator venting (Shull)
14
10
1
2
119
0.1
015
GP02
Cummins G5.9 (sn74409564)
119
16
15
18
0.1
016
GP02
Cummins G5.9 (sn:74110351)
119
16
15
18
0.1
TOTAL (tpy)
0.1
0.0
0.0
0.1
0.1
0.0
0.0
0.7
0.0
0.0
1.1
34
20WE0809.CP1
1/19/2021
APCD
09-28-2020
Received
-B.> .
Condensate Storage Tank(s) APEN
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 10 VV6 Q80Gi
AIRS ID Number: 123 / 9FED / 1
(leave blank unless APCD has already assigned a permit ti and AIRS ID)
Section 1 - Administrative Information
Company Name': Mallard Exploration, LLC
Site Name: Anderson/Shull Production Facility
Site Location: SESW Sec 31 T9N R59W
Mailing Address:
(include Zip Code) 1400 16th St. #300
Denver, CO 80202
Site Location
County: Weid
NAICS or SIC Code: 211111
Contact Person: John Tonello
Phone Number: 720-543-7951
E -Mail Address2: jtonello@mallardexploration.com
t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020 1 I
430000
mgCOLORADO
! Demelmadtgftler
Nola Imbeemot
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑r NEW permit OR newly -reported emission source
0
Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $353.13
must be submitted along with the APEN filing fee.
- OR -
El MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
- OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDmONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: Please issue individual permit for Condensate Tanks.
This is for the Anderson tank battery.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Storage of condensate at E&P facility
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 7/1 /2020
Normal Hours of Source Operation: 24
hours/day 7 days/week 52
weeks/year
Storage tank(s) located at: 13 Exploration & Production (E&P) site ❑ Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
GI
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
GI
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day?
GI
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.00262
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
■
O
Are you requesting z 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions k 6 ton/yr (per storage tank)?
Yes
No
D
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
tCOIORADO
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Projected
478-34-7704- 1,812,237
From what year is the actual annual amount?
Average API gravity of sales oil: 43.9 degrees
Tank design: ❑r Fixed roof
❑ Internal floating roof
-Per revised talcs received
12/21/2020. -B.E.
+4 1,993,460
RVP of sales oil: 11.6
❑ External floating roof
N/A
5 x 500 bbl
2500
3/2020
7/2020
See Attached
❑
❑
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 The E8P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
40.701296/-104.023419
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
sR
NIA
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
Q Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): Unknown
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
iCOLORADO
Uepmuenfel Pub.
Math 6 Ynetromwie
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section .
Vapor
(] Recovery
Unit (VRU):
Pollutants Controlled: VOCs, HAPs
Size: 84 bhp
Make/Model: Cummins G5.9
Requested Control Efficiency: 100 %
VRU Downtime or Bypassed (emissions vented):
20 30.5% %
*based on 6017,748 bi l/yr
during VRTJ downtime.
❑ Combustion
Device:
Pollutants Controlled: VOCs, HAPs
Rating: MMBtu / hr
Type ECD Make/Model:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
95
98
Waste Gas Heat Content: 23452324 Btu/scf
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating:
0.1162
MMBtu/hr
—2 x 50 scth
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 20 psig
Describe the separation process between the well and the storage tanks: HLP separator, bulk separator
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
� eaiouAoo
� 4 DepartmereanhalsOc
HaaRAtr Sleben
Permit Number:
AIRS ID Number: 123 / 9FED 1
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
VOC
VRU, ECD
95
NOx
CO
HAPs
Other:
VRU, ECD
95
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
VOC
NO.
CO
1.23 Ib/bbl
Site Specific Sampling
2-25:447 115. 9 1+37217.34
270.5361226. '8 13.527- 19.04
0.75
0.69
0.69
0.75
0.31
IblMMBtu
AP -42 Chapter 13.5 4.--966- 3.12
1:966- 3.12
-2.360- 3.42
2364- 3.42
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑✓ Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP emissions from source:
..
\
.r-527395-
Benzene
71432
0.00286
lb/bbl
She Specific Scalping
HM 96225,18' 79
Toluene
108883
0.00212
Ibibbl
SileSpecific Sanping
778.236- 3,8.0 38:912-59
Ethylbenzene
100414
0.0003
ibibbi
site specific
572
8
Xylene
1330207
o.00v4
Po/bbl
site specific
787
12
n -Hexane
110543
0.0207
lb/bbl
Site Specific Scraping
77685:98537,527
378:299572
2,2,4-Trimethylpentane
540841
0.0011
lb/bbl
Site SpedficScalping
404497 1,98
2se85- 30
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions. -Redlines per email 12-21-2020 to reflect uncontrolled emissions rooted to V RU (controlled a.t
100% efficiency) and increase requested throughput and adjust throughput during VRU
downtime. See revised talcs recd 12-21-20.
Form APCD-205 - CoWdlensate Storage Tank(s) APEN - Revision 07/2020
COLORADO
5 I gelSigeateeteltatelc
s iae
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
John Tonello (Sep 25. 2020 13:20 CDT)
Sep 25, 2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello
CEO
Name (print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
✓❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 and the General For more information or assistance call:
Permit registration fee of $353.13, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
COLORADO
6 I
11�M 6 invhwmLL
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Mallard Exploration
Source Name:
Anderson Condensate Storage Tanks
Emissions Source AIRS ID2:
123-9FED
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05-123-43618
Anderson Fed 6-5-1HN
❑
05-123-43627
Anderson Fed 6-5-2HN
❑
05-123-43624
Anderson Fed 6-5-4HN
❑
05-123-43617
Anderson Fed 6-5-5HN
❑
05-123-43620
Anderson Fed 6-5-6HN
❑
05-123-43625
Anderson Fed 6-5-7HN
❑
05-123-43630
Anderson Fed 6-5-8HC
❑
05-123-43614
Anderson Fed 6-5-9HN
❑
05-123-43628
Anderson Fed 6-5-10HN
❑
■
■
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014
APCD
09-28-2020
Received
Condensate Storage Tank(s) APEN
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 20 wE 081 d
AIRS ID Number: 123 / 9FED /008
[Leave blank unless APCD has already assigned a permit It and AIRS ID]
Section 1 - Administrative Information
Company Namet:
Site Name:
Site Location:
Mallard Exploration, LLC
Anderson/Shull Production Facility
Site Location
SESW Sec 31 T9N R59W county: Weld
Mailing Address: 1
(Include Zip code) 1400 16th St. #300
Denver, CO 80202
NAICS or SIC Code: 211111
Contact Person: John Tonello
Phone Number: 720-543-7951
E -Mail Address2: jtonello@mallardexploration.com
t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
436011
COLORADO
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $353.13
must be submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: Please issue individual permit for Condensate Tanks.
This is for the Shull tank battery.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Storage of condensate at E&P facility
For new or reconstructed sources, the projected start-up date is: 7/1/2020
Normal Hours of Source Operation: 24
Storage tank(s)located at:
hours/day
7
days/week
52
weeks/year
❑✓ Exploration Et Production (EtiP) site ❑ Midstream or Downstream (non EitP) site
Will this equipment be operated in any NAAQS nonattainment area?
p
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
Yes
No
O
■
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
Yes
No
p
■
If "yes", identify the stock tank gas -to -oil ratio:
0.00265
m'/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
❑
Yes
No
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
cotoewao
2 I ! 4
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 4 - Storage Tank(s) Information
-96&994 999,400
16986— 1,099,340
From what year is the actual annual amount? Projected
Average API gravity of sales oil: 43.9 degrees
Tank design: 0 Fixed roof ❑ Internal floating roof
-Per app revisions received 12-21-2020
-B.E.
RVP of sales oil: 11.6
❑ External floating roof
`
*,'& ..„ytw°i
e tyl,it._ gsc,..,z-t, .
N/A
5 x 500 bbl
2500
3/2020
7/2020
} i ,T'Ra A, T- $$ n d .. +� Y v� 'i @ ii+R.�
!p. .?v nb:re�.X II..�e3�.�°di.'� J'�`..FC�0.�. - �� �,��
- -
See Attached
■
- -
■
- -
■
- -
■
- -
■
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
b The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
a'
r.
N/A
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
El Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter (inches): Unknown
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 0712020
3 ®COLORADO
', ��
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section .
Vapor
• Recovery
Unit (VRU):
Pollutants Controlled: VOCS, HAPs
Size: 84 bhp Make/Model: Cummins G5.9
Requested Control Efficiency: 100 % "based on 567,613 bbl/yr
during VRU downtin-e.
VRU Downtime or Bypassed (emissions vented): 28 51.6 %
❑ Combustion
Device:
Pollutants Controlled: VOCS, HAPs
Rating: MMBtu/hr
TYPe: ECD Make/Model:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
95
98
Waste Gas Heat Content:
Constant Pilot Light: ID Yes ❑ No Pilot Bumer Rating:
2346
0.1173
Btu/scf
MMBtu/ hr
—2 burners
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 20 prig
Describe the separation process between the well and the storage tanks: HLP separator, bulk separator
X 50 se.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
coiaaAco
4 I I ter''
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? ❑r Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
VOC
VRU, ECD
95
NOX
CO
HAPs
Other:
VRU, ECD
95
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
VOC
12514-2620.6 •
-5442- 16.36
144-241 682.7
1.242
lb/bbl
Site Specific Sampling
7.-295- 17.96
NOX
CO
0.068 lb/t\411,4 B t u
AP -42, Ch13.5 0.65
0.65
0.71
a-::259— 3.23
0.71
0.31
Ib/MMBtu
AP -02 Chapter 13.5
%$49- 2.95 —4.-048 2.95
1.259- 3._-
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
-Redlines per email 12-21-2020 to reflect uncontrolled emissions muted to VRU (controlled at
100% efficiency) and increase requested throughput and adjust throughput during VRU
downtime. See revised calcs recd 12-2t-20. -B.11
Section 9 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
0 Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
_t
rr
Benzene
71432
0.00288
mlbbl
SUSpecific 6empinp
568.7872,874
27.840- 74
Toluene
108883
0.00214
lb/bbl
Site Specific Sempin0
413.576 2,135
-20.679- 55
Ethylbenzene
100414
0.00O8
lbibbl
Site Specific
279
7
Xylene
1330207
0.00044
lbibbl
Site Specific
437
11
n -Hexane
110543
0.0209
lbibbl
Site SpecificSampin0
4;843-:03920,8
9 302A52 539
2,2,4-Trimethylpentane
540841
0.0011.0
lbibbl
Site Specific
1,104
29
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
404 COLORADO
weA�
5 I xwmeu,w.wmu
Permit Number:
AIRS ID Number: 123 / 9FED /
(Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
c7ohm 7,/fetto
John Tonello ::Sep 25, 2020 13:20 CDT
Sep 25, 2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello
CEO
Name (print) Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
❑� Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with S216.00 and the General For more information or assistance call:
Permit registration fee of S353.13, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Small Business Assistance Program
(303)692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2020
eoLoRAoo
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Mallard Exploration
Source Name:
Shull Condensate Storage Tanks
Emissions Source AIRS ID2:
123-9FED
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05-123-43664
Shull Fed 31-32-1HN
■
05-123-43663
Shull Fed 31-32-2HC
❑
05-123-43677
Shull Fed 31-32-3HN
❑
05-12343670
Shull Fed 31-32-4HN
■
05-123-43613
Shull Fed 31-32-5HN
❑
05-123-43619
Shull Fed 31-32-7HN
❑
05-12343623
Shull Fed 31-32-8HC
■
05-123-43629
Shull Fed 31-32-9HN
❑
■
■
■
■
■
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
APCD
09-28-2020
RECEIVED
-B.E.
Produced Water Storage Tank(s) APEN
Form APCD-207
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 20 VUEO$ `I AIRS ID Number: 123 / 9FED / 0001
[Leave blank unless APCD has already assigned a permit M and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
Mallard Exploration, LLC
Anderson/Shull Production Facility
Site Location
SESW Sec 31 T9N R59W County: Weld
Mailing Address:
(Include Zip Code) 1400 16th St. #300
Denver, CO 80202
NAILS or SIC Code: 211111
Contact Person: John Tonello
Phone Number: 720-543-7951
E -Mail Address2: itonello@mallardexploration.com
t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020 1 I
436007
®COLORADO
Ar�OLuVamw�mt
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
0
Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP05 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $353.13
must be submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name'
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes: Please issue individual permit for produced water tanks.
This is for the Anderson tank battery.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Storage of produced water at E&P facility.
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 7/1/2020
Normal Hours of Source Operation: 24
hours/day 7
days/week 52
weeks/year
Storage tank(s) located at: El Exploration & Production (E&P) site ❑ Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
p
■
Are Flash Emissions anticipated from these storage tanks?
l7
Yes
■
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
Yes
No
■
I5I
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
Yes
No
■
17
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
■
D
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
O
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
>tGCOLonAve
2 I �.
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit " and AIRS ID]
Section 4 - Storage Tank(s) Information
Projected
From what year is the actual annual amount?
Tank design:
❑r Fixed roof
❑ Internal floating roof
❑ External floating roof
-Per revises, Cale,
received 12/21/20
N/A
5 x 500 bbl
2500
3/2020
7/2020
See Attached
El
El
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including ADEN updates.
6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
40.701296/-104.023419
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
e
N/A
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
El Upward ❑ Downward
❑ Horizontal ❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): Unknown
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Form APCD-207 - Produced Water Storage Tanks) APEN - Revision 07/2020
Coto''''
3 ! � ,"k
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section .
Vapor
❑✓ Recovery
Unit (VRU):
Pollutants Controlled: VOCs, HAPs
Size: 84 bhp Make/Model: Cummins G5.9
Requested Control Efficiency: 100 %
%'per requested throughput durir.
VRli` downtime (782,924 bbl/yr)
VRU Downtime or Bypassed (emissions vented): 20 52,1
❑ Combustion
Device:
Pollutants Controlled: vOCs, HAPs
Rating: MMBtu/hr
Type: ECD Make/Model:
Requested Control Efficiency: 95 %
% 1335
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating:
-1-1-3575
Btu/scf
MMBtu / hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 85 psig
Describe the separation process between the well and the storage tanks: HLP separator
COLORADO
Form APCD-207 - Produced Water Storage Tank(s) ADEN - Revision 07/2020 4 j
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit# and AIRS ID]
Section 8 Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Q Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6 :
VOC
VRU,ECD
95%
NOx
CO
HAPs
Other:
VRU, EGO
95%
From what year is the following reported actual annual emissions data? Projected
Use the followin table to re+ort the criteria +ollutant emissions from source:
NOX 3.4E-5 lb/bbl AP -42 Cht3.5 0.02 0.02
CO 2.5E-4 I lb/bbl 1P-42 0113,5
0.09 0.09
VOC 0.0104 Ib/bbr Site Specific Sampling 1.674& 7.13 -o,e84 0.19 -2:ens 7.84 -6tse-0.20
0,02 0.(2
0.10 0.10
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions. *Redlines per email 12-21-2020 to reflect uncontrolled emissions routed to VRU (controlled at
100% efficiency) and increase requested throughput and adjust throw bput during VRU
downtime. See revised talcs recd 12-21-20.
-B i?..
Section 9 - Non -Criteria Pollutant Emissions information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑ Yes 0 No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
�., it
Benzene
71432
2.2.E-04
lb/bbl
295
8
Toluene
108883
9.6E-05
lb/bbl
182
-
Ethylbenzene
100414
6.0E-06
lb/bbl
Site specific
g
0.2
Xylene
133O2O7
1.0E-05
lb/bbl
14
0.4
n -Hexane
11O543
1.4E-04
lb/bbl
191
5
2,2,4-Trimethylpentane
540841
7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
s Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Forrn APCD-207 - Produced Mater Storage Tank(s) APEN - Revision 07/2020
iftueeteexeo
5 Ii�
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit #i and AIRS ID]
Section 10 s Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Joke Tm2tk) Sep 25, 2020
John Tonello (Sep 25, 2020 13:20 CDT)
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello CEO
Name (print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 and the General For more information or assistance call:
Permit registration fee of $353.13, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
43OO Cherry Creek Drive South
Denver, CO 8O246 -153O
Make check payable to:
Colorado Department of Public Health and Environment
Small Business Assistance Program
(303)692-3175
OR
(303)692-3148
APCD Main Phone Number
(303) 692-3150
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
COLORADO
6► IDepot...� erl Pula.
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Mallard Exploration
Source Name:
Anderson Water Storage Tanks
Emissions Source AIRS ID2:
123-9FED
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05-123-43618
Anderson Fed 6-5-1HN
❑
05-123-43627
Anderson Fed 6-5-2HN
❑
05-123-43624
Anderson Fed 6-5-4HN
❑
05-123-43617
Anderson Fed 6-5-5HN
❑
05-123-43620
Anderson Fed 6-5-6HN
❑
05-123-43625
Anderson Fed 6-5-7HN
❑
05-123.43630
Anderson Fed 6-5-BHC
❑
05-123-43614
Anderson Fed 6-5-9HN
❑
05-123-43628
Anderson Fed 6-5-10HN
❑
■
■
Footnotes:
I 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
APCD
09-28-2020
RECEIVED
Produced Water Storage Tank(s) APEN
Form APCD-207
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or locks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: zovv50g 12 AIRS ID Number: 123 / 9FED / Q O
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Mallard Exploration, LLC
Site Name: Anderson/Shull Production Facility
Site Location: SESW Sec 31 T9N R59W
Mailing Address: 1
(include Zip Code) 1400 16th St. #300
Denver, CO 80202
s
Site Location
County: Weld
NAILS or SIC Code: 211111
Contact Person: John Tonello
Phone Number: 720-543-7951
E -Mail Address2: jtonello@mallardexploration.com
' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
436012
COLORADO
'I I MAIO MS**tr�x
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit 4 and AIRS ID)
Section 2 - Requested Action
✓❑ NEW permit OR newly -reported emission source
Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP05 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $353.13
must be submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
OR -
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: Please issue individual permit for produced water tanks.
This is for the Shull tank battery.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Storage of produced water at E&P facility.
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 7/1/2020
Normal Hours of Source Operation: 24
Storage tank(s)located at:
hours/day 7 days/week 52
weeks/year
El Exploration a Production (EEtP) site ❑ Midstream or Downstream (non EftP) site
Will this equipment be operated in any NAAQS nonattainment area?
GI
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
•
Yes
■
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
Yes
No
p
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
■
Yes
❑✓
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
O
Are you requesting z 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions a 6 ton/yr (per storage tank)?
❑
Yes
No
•
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
COLORADO
2 ISIP n>y.mr...Pubac
try,
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Projected
From what year is the actual annual amount?
Tank design: ❑ Fixed roof
620,256 526,090
❑ Internal floating roof
-744;349 631,308
❑ External floating roof
'Per revised talcs
received
12-21-2620
N/A
5 x 500 bbl
2500
3/2020
7/2020
See Attached
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including ADEN updates.
6 The EU Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
40.701296/-104.023419
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
N/A
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
Upward ❑ Downward
❑ Horizontal ❑ Other (describe):
Indicate the stack opening and size: (check one)
Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): Unknown
Interior stack width (inches): Interior stack depth (inches):
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
46;cot.oRAD0
3 ;
Permit Number:
AIRS ID Number: 123 / 9FED f
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section .
Vapor
0 Recovery
Unit (VRU):
Pollutants Controlled: VOCs, HAPs
Size: 84 bhp
Requested Control Efficiency:
Make/Model: Cummins G5.9
100
VRU Downtime or Bypassed (emissions vented): -20- 58.5 %
-Per requested throughpdu during
VRU downtime (370,939 bbl/yr
❑ Combustion
Device:
Pollutants Controlled: VOCs, HAPs
Rating: MMBtu/hr
Type: ECD Make/Model:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
95
98
Waste Gas Heat Content:
Constant Pilot Light: El Yes ❑ No Pilot Burner Rating:
1135.5
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 85
Describe the separation process between the well and the storage tanks: HLP separator
psig
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
4 I MC
DivectresolatPabft
COLORADO
PI**elmteanment
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCa has already assigned a permit # and AIRS I0]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? I] Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
VOC
NOx
CO
HAPs
Other:
VRJ, ECD
95%
VR1J, ECD
95%
From what year is the following reported actual annual emissions data? Projected
p criteria pollutant
Use the following table to report the cnt emissions fsource: _
VOC
NOx 4.6E-05 lb/bbl
CO
0.0104 lb/bbl
Slte Specific Sampling 4:5468 7,74
AP42 C;h13.5 0.01.
2.1E-04 11)/bbl
AP42 (11113.5 0.03
-0:032- 0.08
0.01
0.03
0.7762 3.29
0.01
0.04
-0:on9- 0.10
0.01
0.04
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. if source has not yet started operating, provide
projected emissions. 'Redlines per email 1221-2020 to retlect uncontrolled emissions routed to VR1J
(controlled at 100% efficiency) and increase requested throughput and adjust throughput
during VRI? downtime. See revised talcs recd 12-21-20.
Section 9 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑ Yes El No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
x.. ASPS ,A *'}�
`.�}y
^^
Benzene
71432
2.2E-04
lbibbl
114
3
Toluene
108883
9-6E-05
lbibbl
51
1
Eth (benzene
100414
5.7E-06
l'o/bbl
Sitc-specific
3
0.1
X lene
1330207
1.0E-05
lbPohl.
0.2
n -Hexane
110543
1.4E -n4
ibiobi
73
2
2,2,4-Trimethylpentane
540841
--
7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
5,4O[
thamermael Relic
COLORADO
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
L7oGth 7 frreao
John Trvu�!`c �.S��;t I`�. 1'�7C� I X20 CDT
Sep 25, 2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello CEO
Name (print) Title
Check the appropriate box to request a copy of the:
• Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 and the General For more information or assistance call:
Permit registration fee of $353.13, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Small Business Assistance Program
(303)692-3175
OR
(303)692-3148
APCD Main Phone Number
(303)692-3150
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2020
COLORl�DO
6 I a® .
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Mallard Exploration
Source Name:
Shull Water Storage Tanks
Emissions Source AIRS ID2:
123-9FED
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05-123-43664
Shull Fed 31-32-1HN
❑
05-123-43663
Shull Fed 31-32-2HC
❑
05-123-43677
Shull Fed 31-32-3HN
■
05-123-43670
Shull Fed 31-32-4HN
■
05-123-43613
Shull Fed 31-32-5HN
■
05-123-43619
Shull Fed 31-32-7HN
❑
05-123-43623
Shull Fed 31-32-8HC
■
05-123-43629
Shull Fed 31-32-9HN
■
■
■
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014
1
Hydrocarbon Liquid Loading APEN
Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 20 w E 0813 AIRS ID Number: 123 / 9FED / 011
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
Mallard Exploration, LLC
Anderson/Shull Production Facility
Site Location
SESW Sec 31 T9N R59W county: Weld
Mailing Address:
(include Zip Code) 1400 16th St. Suite 300
Denver, CO 80202
NAICS or SIC Code: 211111
Contact Person: John TOnello
Phone Number: 720-543-7952
E -Mail Address2: itonello@mallardexploration.com
i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 07!2020
43600°
i te!
DepoRseidPulas
COIO/ADO
r
Permit Number: AIRS ID Number:
123 /9FED/
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 2 - Requested Action
1p NEW permit OR newly -reported emission source
Q Request coverage under construction permit
❑ Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of S353.13 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes: This APEN/permit is specifically for the Anderson facility
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Anderson facility - liquid loading of condensate product
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 7/1/2020
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
GI
■
Is this equipment located at a stationary source that is considered a Major Source of (HAP)•
emissions?
Yes
No
D
Does this source load gasoline into transport vehicles?
Yes
No
■
NI
Is this source located at an oil and gas exploration and production site?
Yes
No
0
■
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annualII
average?
Yes
No
D
Does this source splash fill less than 6,750 bbl of condensate per year?
Yes
No
17
■
Does this source submerge fill less than 16,308 bbl of condensate per year?
Yes
No
■
GI
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 07'2020
coLottAuo
1
Permit Number: AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit g and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: Q Condensate ❑ Crude Oil
❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loadeds:
92,057
bbl/year
Actual Volume Loaded:
This product is loaded from tanks at this faci ity into: Tank trucks
(e.g. "rail tank cars" or "tank trucks")
83,688
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature of
bulk liquid loading:
F
True Vapor Pressure:
Psia @ 60 `F
Molecular weight of
displaced vapors:
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loadeds:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.701296/-104.023419
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Indicate the direction of the stack outlet: (check one)
✓❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
El Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): Unknown
Interior stack width (inches): Interior stack depth (inches):
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 07/2020
agco►oaAoc
3 Irepl.rtment at Public
� N
i
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit . and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ Loading occurs using a vapor balance system:
Requested Control Efficiency: %
❑ Combustion
Device:
Used for control of: VOC, HAPs
Rating:
Type: ECD
MMBtu / hr
Make /Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: `F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑r Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Overall Requested
Control Efficiency
(9: reduction in emissions)
PM
SOx
NOx
CO
VOC
ECD
95
HAPs
ECD
95
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? Estimated
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Unfts
Source
(AP -42,
Mb., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/gear)
Controlled
Emissions
(tons/year)
PM
SO.
NO.
CO
VOC
0.236
WWI
PS Memo 1402
9.88
0.19
10.86
0.54
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 07/2020
ASO iCOIO1ADO
4 IC
Permit Number:
AIRS ID Number:
123 /9FED/
(Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
0 Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(lbs/year)
Controlled
Emissionsb
(lboyear)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.0036
/brow
PS Memo 1402
301.28
15.06
2,2,4-Trimethylpentane
540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
Jo6tfrr 7Owaio
Srp25_ ;02C 13,20 C DT'.
Sep 25, 2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello CEO
Name (print)
Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
(] Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 and the General
Permit registration fee of $353.13, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303)692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303)692-3150
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 07/2020 5
SO
ieowR►oo
a porammel.rae
w.u..,..an.w
Hydrocarbon Liquid Loading APEN
Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 20 MOs t4- AIRS ID Number: 123 / 9FED /OIL
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
Mallard Exploration, LLC
Anderson/Shull Production Facility
Site Location
SESW Sec 31 T9N R59W County: Weld
Mailing Address:
(include Zip Code) 1400 16th St. Suite 300
Denver, CO 80202
NAILS or SIC Code: 211111
Contact Person: John TOnello
Phone Number: 720-543-7952
E -Mail Address2: jtonello@mallardexploration.com
t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-2O8 - Hydrocarbon Liquid Loading APEN - Revision 07/2020
436013
I ®!COLORADO
1 igiT nt=
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑� NEW permit OR newly -reported emission source
❑ Request coverage under construction permit
❑ Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of $353.13 must be
submitted along with the APEN filing fee.
-oR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
:I Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes: This APEN/permit is specifically for the Shull facility
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Shull facility - liquid loading of condensate product
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 7/1/2020
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
GI
■
Is this equipment located at a stationary source that is considered a Major Source of (HAP)•
emissions?
Yes
No
O
Does this source load gasoline into transport vehicles?
Yes
No
■
GI
Is this source located at an oil and gas exploration and production site?
Yes
No
GI
■
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annualII
average?
Yes
No
D
Does this source splash fill less than 6,750 bbl of condensate per year?
Yes
No
17
■
Does this source submerge fill less than 16,308 bbl of condensate per year?
Yes
No
■
GI
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 07/2020
itOlOlA00
ate IIftilaterboftarrot
Permit Number: AIRS ID Number:
123 /9FED/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: Condensate ❑ Crude Oil ❑ Other:
If this ADEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loadeds:
54,095
bbl/year
Actual Volume Loaded:
This product is loaded from tanks at this facility into: Tank trucks
(e.g. "rail tank cars" or "tank trucks")
49,117
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature of
bulk liquid loading:
°F
True Vapor Pressure:
Psia @ 60 °F
Molecular weight of
displaced vapors:
lb/Ib-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loadeds:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
I b/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Lomitude or d7M)
40.701296/-104.023419
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
N/A
Unknown
Unknown
Unknown
Unknown
Indicate the direction of the stack outlet: (check one)
EI Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): Unknown
Interior stack width (inches): Interior stack depth (inches):
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 07/2020
3
Permit Number:
AIRS ID Number: 123 / 9FED/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ Loading occurs using a vapor balance system: Requested Control Efficiency:
❑ Combustion
Device:
Used for control of: VOC, HAPs
Rating:
Type: ECD
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: -F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: (] Yes ❑ No Pilot Burner Rating: MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SOx
NOx
CO
VOC
ECD
95
HAPs
ECD
95
Other:
Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
❑r Condensate 0.236 Lbs/BBL 0.00041 Lbs/B8L 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/681_ 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? Estimated
Use the followine table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
OP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissionsb
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOx
NOx
CO
VOC
0.236
lb/bbl
PS Memo 14-02
5.90
0.29
8.38
0.32
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 07/2020
4 1 Alta
Max
COLORADO
i.�ew
Permit Number:
AIRS ID Number:
123 /9FED/
[Leave blank unless ARCD has already assigned a permit k and AIRS ID]
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 Ibs/year?
❑ Yes No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
OW -42, _
fit., etc.)
Uncontrolled
Emissions
pear)
Controlled
Emissions6
Obe/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
2,2,4-Trimethylpentane
540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
,70he 7 Aleao
xdui T re ic'SeF: ;5, /CM CDT'
Sep 25, 2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello CEO
Name (print)
Title
Check the appropriate box to request a copy of the:
✓l Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 and the General
Permit registration fee of $353.13, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-S5-61
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 07/2020
COLORADO
5 I ate=
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 2.4 E Q g' I - J AIRS ID Number: 123 / 9FED / 013
[Leave blank unless APCD has already assigned a perrnit r: and AIRS ID]
Section 1 - Administrative Information
Company Name': Mallard Exploration, LLC
Site Name: Anderson/Shull Production Facility
Site Location: SESW Sec 31 T9N R59W
Mailing Address:
(Include Zip Code) 1400 16th St. Suite 300
Site Location
County: Weld
NAILS or SIC Code: 211111
Denver, CO 80202 Contact Person: John Tonello
Phone Number: 720-543-7952
E -Mail Address2: jtonello@mallardexploration.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-211 Gas Venting APEN - Revision 07/2020
436003
COLORADO
w�iam erwnr,e
Permit Number:
AIRS ID Number: 123 / 9FEci/
[Leave blank unless APCD has already assigned a permit 11 and AIRS ID)
Section 2 - Requested Action
✓❑ NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership° ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: This APEN/permit is specifically for the Anderson facility
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Anderson facility- bulk separator gas venting
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
7/1/2020
El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
Form APCD-211 Gas Venting APEN - Revision 07/2020
days/week weeks/year
El Yes
❑ Yes
❑ Yes
❑ No
No
El No
® icocoo•oo
2 t � ,.:';
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has atready assigned a permit r and AIRS ID]
Section 4 - Process Equipment Information
❑i Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #:
# of Pistons:
Volume per event:
Capacity: gal/min
Leak Rate: Scf/hr/pist
MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Gas Venting
Process Parameterss:
Liquid Throughput
Process Parameterss:
Vented Gas
Properties:
❑r No
Vent Gas
Heating Value:
2091.5
BTU/SCF
Requested:
1.44
MMSCF/year
Actual:
0.72
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
37.068
VOC (Weight %)
66.844
Benzene (Weight %)
0.1444
Toluene (Weight %)
0.1066
Ethylbenzene (Weight %)
0.0121
Xylene (Weight %)
0.0238
n -Hexane (Weight %)
1.2683
2,2,4-Trimethylpentane (Weight %)
0.0008
Additional Required Documentation:
Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
s Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
Form APCD•211 Gas Venting APEN - Revision 07/2020
3 I i®COLORADO
i,� .
Permit Number:
AIRS ID Number: 1 23 / 9FED /
[Leave blank unless APCD has atready assigned a permit 1 and AIRS ID]
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or I/TM)
40.701296/-104.023419
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Indicate the direction of the stack outlet: (check one)
Ei Upward ❑ Downward
❑ Horizontal ❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter (inches): Unknown
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOC HAPs
Rating:
Type: ECD
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 95 %
Minimum Temperature:
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 Gas Venting APEN - Revision 07/2020
4 I eI
AperhavetalINIAk
COLORADO
&Wel
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6►:
Pollutant
Control Equipment Description
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
5O,
NO.
CO
VOC
ECD
95
HAPs
ECD
95
Other:
From what year is the following reported actual annual emissions data? Estimated
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOx
NO.
CO
VOC
65,376.69
lb/MMscf
Site Specific
23.53
1.18
47.07
2.35
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(lbs/year)
Controlled
Emissionsb
(lbs./year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
1,240.46
Ib/MMsd
Site Specific
893.13
44.66
2,2,4-Trimethylpentane
540841
Other:
Yes ❑ No
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-211 Gas Venting APEN - Revision 07/2020
5I
POW elevollimus
icOtoRADO
i
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
()he Tif2tta
John Tone llo (Sep 25, 2020 1'5:20 CDT}
Sep 25, 2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello CEO
Name (print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175
OR
(303)692-3148
APCD Main Phone Number
(303) 692-3150
Form APCD-211 Gas Venting APEN • Revision 07/2020
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 20 W OTI U AIRS ID Number: 123 / 9FED / 61,q -
[Leave blank unless APCD has already assigned a permit t and AIRS ID]
Section 1 - Administrative Information
Company Name': Mallard Exploration, LLC
Site Name: Anderson/Shull Production Facility
Site Location: SESW Sec 31 T9N R59W
Mailing Address: 1400 16th St. Suite 300
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 211111
Contact Person: John Tonello
Phone Number: 72Q_543-7952
E -Mail Address2: ponello@rnallardexploration.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-211 Gas Venting APEN - Revision 07/2020
4.36014
As® COl at•Mae e
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit and AIRS ID)
Section 2 - Requested Action
0 NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name; ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
- OR
▪ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Ft Notes: This APEN/permit is specifically for the Shull facility
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
' For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Shull facility- bulk separator gas venting
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
7/1/2020
ID Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
Form APCD-211 Gas Venting APEN - Revision 07/2020
days/week weeks/year
El Yes
❑ Yes
❑ Yes
❑ No
ci No
El No
leOICO ORAoo
2 ';I�.,'..:
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has atready assigned a permit = and AIRS ID]
Section 4 - Process Equipment Information
❑i Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? Yes
Gas Venting
Process Parameterss:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
Vent Gas
Heating Value:
2091.5
BTU/SCF
Requested:
1.92
MMSCF/year
Actual:
0,96
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
37.068
VOC (Weight %)
66.844
Benzene (Weight %)
0.1444
Toluene (Weight %)
0.1066
Ethylbenzene (Weight %)
0.0121
Xylene (Weight %)
0.0238
n -Hexane (Weight %)
1.2683
2,2,4-Trimethylpentane (Weight %)
0.0008
Additional Required Documentation:
ID Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX is n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
Form APCD-211 Gas Venting APEN - Revision 07/2020
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a peemit s and AIRS ID]
Section 5 - Geographical/Stack Information
Geographical Coordinates
aatitude/Longitude or UM)
40.701296/-104.023419
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Indicate the direction of the stack outlet: (check one)
0 Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
El Circular Interior stack diameter (inches): Unknown
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed:
❑ Combustion
Device:
Pollutants Controlled: V®C, HAPs
Rating:
Type: ECD
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
MMBtu/hr
Make/Model:
95
98
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr
El
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 Gas Venting APEN - Revision 07/2020
4 AO
Doody:at
COLORADO
aPirbUc
NaYM6IDn4aave nt
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Yes ❑ No
f yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Overall Requested
Control Efficiency
(X reduction in emissions)
PM
SO.
NO.
CO
VOC
ECD
95
HAPs
ECD
95
Other:
From what year is the following reported actual annual emissions data?
Estimated
Use the fotlowin>2 table to resort the criteria aollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled '
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SO.
NO.
CO
VOC
65,376.69
lb/MMscf
Site Specific
31.38
1.57
62.76
3.14
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑r Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Bas
Units
Source
(AP -S2,
Mfg., etc.)
Uncontrolled
Emissions
(ibs/year)
Controlled
Emissions6
(ibs/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
1,240.46
INTIMed
Site Specific
1,190.84
59.54
2,2,4-Trimethylpentane
540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-211 Gas Venting APEN - Revision 07/2020
5 I �cote
l'""""'"'"'
Permit Number:
AIRS ID Number: 123 / 9FED /
[Leave blank unless APCD has already assigned a permit z and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
John Tonello (Sep 25, 2020 13:20 CDT)
Sep 25, 2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
John Tonello CEO
Name (print) Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
❑r Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 to: For more information or assistance call:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246.1530
Small Business Assistance Program
(303)692-3175
OR
(303)692-3148
APCD Main Phone Number
Make check payable to: (303)692-3150
Colorado Department of Public Health and Environment
Form APCD-211 Gas Venting APEN - Revision 07/2020
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6 i � l,� awe
Hello