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Home My WebLink About20202132.tiff COLORADO C. Nter44044,4° Department of Public Health&Environment Weld County - Clerk to the Board 1150 0 St RECEIVED PO Box 758 Greeley, CO 80632 JUN 16 2020 June 8, 2020 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On June 9, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Edge Energy H, LLC - Akbary / 1A Pad. 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 X61 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,, ; i� Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director * *, Pu b1;c Re v i e(A cc:PL(TP),I406),P4►(3kJ ER/cH/cK) 2020-2132 08/1912o o6(344) , 08/14/,20 -r141. Air Pollution Control Division CNotice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Edge Energy II, LLC - Akbary / 1A Pad - Weld County Notice Period Begins: June 9, 2020 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: Edge Energy II, LLC Facility: Akbary / 1A Pad Well Production Facility Lot 1 of Section 1, Township 8N, Range 67W Weld County The proposed project or activity is as follows: Edge Energy II, LLC is requesting permit coverage for four (4) condensate storage vessels, two (2) produced water storage vessels and hydrocarbon liquid toadout at new synthetic minor oil and gas well production facility located in the ozone non-attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0353, 20WE0354 it. 20WE0355 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air- permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.govtpacific/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: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 _ ,.. . COLORADO Department at Public 1 I . i°'"E Health 6 Environment Denver, Colorado 80246-1530 COLORADO Department of Public 2 I °""E Health b Enwiroaunent Cr 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: 20WE0353 Issuance: 1 Date issued: Issued to: Edge Energy II, LLC Facility Name: Akbary/ 1A Pad Plant AIRS ID: 123/A0D9 Physical Location: Lot 1 SEC 1 T8N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description (D Four (4) 400 barrel fixed roof condensate Enclosed TK 1-4 002 storage vessels connected via liquid Combustor(s) manifold. 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 Page 1 of 11 rte 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 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: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type TK 1-4 002 --- 1.7 30.0 7.5 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. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. 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. Page 2 of 11 r ,. COLORADO toAir Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TK 1-4 002 Enclosed Combustor(s) 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 rates 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 Limits Facility AIRS Equipment Process Process Parameter Annual Limit ID Point 01 Condensate 87,600 barrels TK 1-4 002 Throughput 02 Combustion of pilot 0.2 MMSCF light gas 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digt 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) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. 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 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 • 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) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section 11.8.2. 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 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. 14. 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. 15. 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. 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) OPERATING &t MAINTENANCE REQUIREMENTS 17. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (08M) 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 0ann 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. Within one hundred and eighty (180) days after issuance of this permit, the owner or operator must complete site specific sampling including a compositional analysis of the pre-flash Page 4 of 11 C r.Y - 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 pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. The pre-flash pressurized condensate sample must be obtained from the outlet of the three-phase separator. 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 (in units of lb/bbl condensate throughput) for VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane using Division approved methods. Results of site-specific sampling and analysis must be submitted to the Division as part of the self-certification. The operator must submit to the Division, within 60 days of completion of site-specific sampling or a timeframe as agreed to by the Division, a request for permit modification to use the site-specific emission factors developed through this analysis to estimate emissions and demonstrate ongoing compliance. If the • existing well at this facility (WI Number 05-123-50496) remains shut in for more than one hundred and eighty days (180) after issuance of this permit, the owner or operator must complete the site specific sampling detailed in this condition within 30 days of well start-up. For this condition, well startup shall be defined as the day that pressure returns to the well production equipment. Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Page 5 of 11 COLORADO 10 14W C Air Pollution Control Division Department of Public Health 5 Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 21. The requirements of Colorado Regulation Number 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 (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: Emissions - tons per year Facility AIRS Equipment Current Equipment Point Descri tion Pollutant ID p Threshold Permit Limit ENG-1 001 SI RICE Condensate TK 1-4 002 Storage Vessels Produced PW 1-2 003 Water VOC 50 33.1 Storage Vessels LOAD-1 004 Hydrocarbon Loadout __ APEN Exempt Sources Notes: The APEN exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 22. 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. 23. 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- Page 6 of 11 r .� COLORADO le Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 24. 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. 25. 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 25-7-114.5i(7)(a), C.R.S. 26. 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. 27. 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. 28. 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Edge Energy II, LLC Page 7 of 11 C ):+u,r... COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit for four (4) condensate storage vessels at a new synthetic minor well production facility. 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-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 Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 2,103 106 002 n-Hexane 110543 18,396 920 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Process 01: Condensate Throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 3.74x10-2 3.74x10-2 AP-42 Chapter 13.5 CO 1.706x10-' 1.706x10-' AP 42 Chapter 13.5 VOC 13.7 6.85x10-' CDPHE PS Memo 14-03 71432 Benzene 2.4x10-2 1.2x10-3 CDPHE PS Memo 14-03 Page 9 of 11 C ., y.arr. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl 110543 n-Hexane 2.1x10-' 1.05x10-2 CDPHE PS Memo 14-03 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 reflect the state default emission factors listed in PS Memo 14-03 for condensate storage vessels in Weld County. The NOx and CO emission factors in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively)by a heat value of 2,255 Btu/scf and GOR of 244 scf/bbl. Actual emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput. Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/MMscf lb/MMscf NOx 132.8 132.8 AP-42 Chapter CO 605.43 605.43 13.5 Note: The NOx and CO emission factors in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31-'lb/MMBtu respectively) by a heat content of 1,953 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot gas. Pilot light gas fuel flow is based on a constant rate of 13 scf/hr per enclosed combustor. There is one (1) enclosed combustor used to control emissions at this facility Total actual emissions are obtained from the sum of emissions resulting from the storage vessels and the combustion of waste gas from the storage vessels (Process 01) and the combustion of pilot light gas (Process 02). 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 source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971/oil-and- natural-gas-sector-emission-standards-for-new-reconstructed-and-modified-sources Page 10 of 11 C _ .y......:,.. COLORADO 41.. Ntal'4446. Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC and n-Hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable NSPS 0000a Applicable 10) 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 XXXXXX Page 11 of 11 COLORADO iip Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the heath and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0354 Issuance: 1 Date issued: Issued to: Edge Energy II, LLC Facility Name: Akbary / 1A Pad Plant AIRS ID: 123/A0D9 Physical Location: Lot 1 SEC 1 T8N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Two (2) 400 barrel fixed roof produced Enclosed PW 1-2 003 water storage vessels connected via liquid Combustor(s) manifold. 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 Page 1 of 10 Cr:". COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) F.4.) 4. The operator must complete al 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' AIRS Tons per Year Emission Equipment ID Point PM2.5 NO), VOC CO Type PW 1-2 003 --- 0.3 0.9 1.1 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 limtation 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 412) 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 calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. 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. Page 2 of 10 COLORADO je , Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID PW 1-2 003 Enclosed Combustor(s) 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 rates 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 Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point Produced Water PW 1-2 003 Throughput 131,400 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. 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 Page 3 of 10 r•z—,� COLORADO Air Pollution Control Division C Department of Public Health b Environrrent Dedicated to protecting and improving the health and environment of the people of Colorado 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) 13. 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 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. 14. 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. 15. 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. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operationsand 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 17. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (0&tM) 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 0&tM 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. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements Page 4 of 10 je .. r•:�.- COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process,or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation Number 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 (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: Pollutant Emissions - tons per year Page 5 of 10 -r, COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Equipment Current Equipment Threshold Permit Point Description ID Limit ENG-1 001 SI RICE Condensate TK 1-4 002 Storage Vessels Produced PW 1-2 003 Water VOC 50 33.1 Storage Vessels LOAD-1 004 Hydrocarbon Loadout APEN Exempt Sources Notes: The APEN exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 22. 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 ILB. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. 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. 24. 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. 25. 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. Page 6 of 10 COLORADO • NyeAir Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 26. 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 al) 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. 27. 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. 28. 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Edge Energy II, LLC Permit for two (2) produced water storage vessels at a new synthetic minor oil and gas well production facility. Page 7 of 10 C r e COLORADO Air Pollution Control Division NUO 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 source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 920 46 003 n-Hexane 110543 2,891 145 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 3.66x10-3 3.66x10-3 AP-42 Chapter 13.5 CO 1.67x10-2 1.67x10-2 AP-42 Chapter 13.5 VOC 2.62x10-1 1.31x10-2 CDPHE PS Memo 14-03 71432 Benzene 7.0x10-3 3.5x10-4 CDPHE PS Memo 14-03 Page 8 of 10 ry.- 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 Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl 110543 n-Hexane 2.2x10-2 1.1x10-3 CDPHE PS Memo 14-03 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 reflect the state default emission factors listed in PS Memo 14-03 for produced water storage vessels in Weld County. The NOx and CO emission factors in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,496 Btu/scf and GWR of 36 scf/bbl. Actual emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput. 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: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC and n-Hexane PSD Synthetic Minor Source of: VOC 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 Page 9 of 10 Y» COLORADO Air Pollution Control Division Department of Public Health&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 10 of 10 IUD COLORADO ire 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: 20WE0355 Issuance: 1 Date issued: Issued to: Edge Energy II, LLC Facility Name: Akbary / 1A Pad Plant AIRS ID: 123/A0D9 Physical Location: Lot 1 SEC 1 T8N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description Hydrocarbon liquid loadout from Vapor Balance and LOAD-1 004 storage vessels to tank trucks using Enclosed Combustor(s) submerged fill. 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 Page 1 of 11 C ., ,,,. ...x . COLORADO 4*, Ntgef444*64. Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.wv/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.) I.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 Tons per Year Emission Point PM2.5 NO,t VOC CO Type LOAD-1 004 --- 0.01 0.6 0.1 Point Note: See"Notes to Permit Holder"fo[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 calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. 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. Page 2 of 11 C r: .. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. 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 AIRS Control Device Pollutants Controlled ID Point LOAD-1 004 Vapor Balance and Enclosed VOC and HAP Combustor(s) PROCESS LIMITATIONS AND RECORDS 8. 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 AIRS Process Parameter Annual Limit ID Point LOAD-1 004 Hydrocarbon Liquid 87,600 barrels Loaded 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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.) • Page 3 of 11 rr COLORADO • j Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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.5.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. 12. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 13. 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. 14. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • 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. Page 4 of 11 -rr. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 15. 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. 16. 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)) 17. 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 Ft MAINTENANCE REQUIREMENTS 18. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your 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 19. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 5 of 11 C r:-� COLORADO Mr 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, 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more,a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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. 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 ii 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 (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: Emissions - tons per year Facility AIRS Equipment Current Equipment Point Description Pollutant ID Threshold Permit Limit Page 6 of 11 Cr..: COLORADO ie111 Air Pollution Control Division Department of Public Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado ENG-1 001 SI RICE Condensate TK 1-4 002 Storage Vessels Produced PW 1-2 003 Water VOC 50 33.1 Storage Vessels LOAD-1 004 Hydrocarbon Loadout ___ APEN Exempt Sources Notes: The APEN exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. 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 "finar 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 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 Page 7 of 11 ri - COLORADO Air Pollution Control Division IWO Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issued to Edge Energy II, LLC Issuance 1 This Issuance Permit for hydrocarbon liquid loadout at a new synthetic minor well production 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 source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 37 2 004 n-Hexane 110543 317 16 Note: AR non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl NOx 2.11x10-4 2.11x10-4 AP-42 Chapter 13.5 CO 9.62x10-4 9.62x10-4 AP-42 Chapter 13.5 VOC 2.36x10-1 1.18x10-2 CDPHE PS Memo 14-02 Page 9 of 11 C ,, ,y ...rt, COLORADO / Air Pollution Control Division t�r Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl n-Hexane 110543 3.61x10-3 1.81x10-4 CDPHE PS Memo 14-02 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 reflect the state default emission factors listed in PS Memo 14-02 for condensate loadout. The NOx and CO emission factors in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 2,255 Btu/scf and GOR of 1.376 scf/bbl. Actual emissions are calculated by multiplying the emission factors in the table above by the total hydrocarbon liquid throughput 6) In accordance with C.R.S. 25-7-1141, 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC and n-Hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://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 Page 10 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 MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX • Page 11 of 11 Cobrado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter _ Package#: 428307 Received Date: 3/31/2020 Review Start Date: 5/7/2020 Section 01-Facility Information Company Name: Edge Energy II,LLC Quadrant Section Township Range County AIRS ID: 123 Lot 1 1 8N 67 Plant AIRS ID: A0D9 Facility Name: Akbary/1A Pad Physical Address/Location: . 'riu tg_67w County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment,Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes. If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 002 Storage Tank TK 1-4 Yes 20WE0353 1 Yes Issuance Section 03-Description of Project Edge Energy II,LLC submitted an application in order to permit several sources at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area.With this application the operator is requesting traditional permit coverage for condensate storage vessels,produced water storage ' vessels and hydrocarbon liquid loadout.The operator is also requesting GP02 coverage for one(1)engine.This analysis only addresses the condensate storage vessels. An APEN is required for the condensate storage vessels because uncontrolled requested VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A, !, Section Il 0 3.a).Additionally,a permit is required because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 2 tpy(CO AQCC Regulation 3,Part B,Section II.D.2.a.). Public comment is required for this permit because new synthetic minor limits are being established in order to avoid additional requirements.Additionally,the change in VOC emissions as a result of the project are greater than 25 tpy. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 Nox CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ 0 0 ❑' ❑ 0 Title V Operating Permits(OP) 0 0020002 / Non-Attainment New Source Review(NANSR) ❑ Is this stationary source a major source? No • If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 000000 Title V Operating Permits(OP) 00000000 Non-Attainment New Source Review(NANSR) ❑ ❑ Section Ol-Administrative Information (Facility 123 AOD9 002 AIRS ID: County Plant Point Section 02.Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Four(4)400 barrel fixed roof condensate storage essels connected via liquid manifold. Description: Emission Control Device Enclosed Combustor(s) Description' Requested Overall VOC&HAP Control Efficiency%. 95.0 Limited Process Parameter • Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tanks) Actual Throughput= 73,000.0 Barrels(bbl)per year Requested Permit Limit Throughput= 87,600.0 Barrels(bbl)per year Requested Monthly Throughput= ,'.:_,0 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= 87,600.0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2255.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced= 244.0 scf/bbl Actual heat content of waste gas routed to combustion device= .0136.1 MMBTU per year Requested heat content of waste gas routed to combustion device= ..n,35.S MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 48,109-3 MMBTU per year Control Device Pilot Fuel Use Rate: 13 scfh 0.1039 MMscf/yr Pilot Fuel Gas Heating Value: 1953 Btu/scf '.22.401 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? Yes Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) Condensal* jindludes flash)-Front VOC 13.7000 R nge Conde '(Includes flash)-Front Benzene 0.0240 Range no Toluene 2 3700 Ethylbe zene 0 Xylene _'p0 Condon iincludes Flash)-Front n-Hexane 0.2100 1 Range ' 224IMP C_„Ca0 Control Device Uncontrolled Uncontrolled Pollutant )Ib/MMBtu) (1b/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 0.0075 C 7.041 AP-42 Table 1-4-2:)PM10/PM.2.5) PM2.5 0.0075 AP-42labfoLl-2)PM10/PM.2.5) sox 0.0006 j NOx 0.0680 %(Rtlb - strial Flares(310i)CO :0.3100 AP4UCbdpR4rV3' IpdusttlolFlares(CO) Pilot tight Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/MMsct) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 0,0075 AP-42 Table 1.4-2(PM10/PM.2.5) PM2.5 0.0075 AP-42 Table 1.4-2(PM10/PM.2.5) 500 0.0006 AP-42 Table 1.4-2(50x) NOx 0.0680 AP-42 Chapter 13.5 Industrial Flares(NOx) VOC 0.0054 AP-42 Table 1.4-2(VOC) CO 0,3100 _ AP 42 Chapter 13.5Industrial Flares(CO) Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.100 0.150 0.100 30.6 PM2.5 0.130 0.'SO _ ._, 30.6 SOx - 0.014 a 11 ..; 23 NOx 1.640 1373 VOC 600.06? :5.003 603.21 -.6 CO 7,505 5-260 7.505 ,22,1.9 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 21.02.40 1702.00 67.50 2102,40 905._I Toluene 0.00 0.40 0.01 c. 0.00 Ethylbenzene 0.00 0 00 0.00z 00 0.43 Xylene 0.00 0.00 0 18 =0 n-Hexane 111298.00 15531300 766,50 183.11a.00 »..2 224 TMP 0.00 0-„0 0,90 0.30 0.10 2 of 5 C:\Users\hslaught\Desktop\123A009\20WE0353.CP1 StorageTank(s)Emissions inventory Section 00-Regulato ry Sumary m Analysis • Regulation 3,Parts A,8 .... . Regulation 7,Part D,Section LC,D,E,F .,on 7,Pain v Session 1254 Regulation 7,Part D,Section I.G,C St 7_ ... .laten 7,Sectly'n I.G Regulation 7,Part D,Section II.B,C.1,C.3 Store., nor on 7,Pain'7S_o_ion r B C y i7.3 Regulation 7,Part D,Section II.C.2 ntsrni -ent.. _.,in 7,Po-t 7,Sec¢Icn 11.: Regulation 7,Part D,Section ll.C.4.a.(i) ,.. ,t.latlan i Paco O,Secv r:- Regulation 7,Part D,Section II.C.4.a.(Il) =uletl. Pen"D,Saat I till,b,f Regulation 6,Part A,NSPS Subpart Kb Regulation 6,Part A,NSPS Subpart 0000 NSPS Subpart.00000 Regulation 8,Part E,MACH Subpart HH (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sempllno and Testing Requirements For condensate et crude oil tanks,does the company use the state default emissions factors to "1- 7 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 Iv 80 spy? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 1403. Does the company use a site specific emissions lecterns estimate emissions? A1bh If yes and if there are flash emissions,are the emissions factors based on a presumed liquid sample drawn at thooacility being permitted(for produced water tend,a pressurize liquid sample must be analyzed using flash liberation analysls)?This sample • should be considered representative whicH lI ite-s site-specific and collected within one f the application received ..generally pec' year 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. ' �ft' N/A-the operator used the state default emission factors to calculate emissions. 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 93%for a flare or combustion device? N If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes 1.The operator calculated VOC and HAP emissions In this application using the"state default emissions factors This methodology is acceptable,however,the uncontrolled requested VOC emissions are greater than 80 toy.Asa result,the permit will contain an initial compliance test that requires the operator to develop site specific..emission factors for this source.The operator must also modify the permit to use the site specific emission factors,developed through initial testing,for emission calculations and ongoing compliance demonstrations.This is required because PS Memo 14-03 states the following:."Site-specific emission factors must be developed and used as the basis to estimate emissions in the following circumstances or locations:For exploration and production(E&P)facilities when uncontrolled VOC emissions from a storage tank are greater than or equal to BO tpy when calculated using state emission factors." 2.According to the application,one well produces to this facility.The well name and API number less follows:(]yarns:Akbary#36-3H,API Number:05-123-50496.According to the application,this Well Iscurrerdly shut In.Ass result,COGCC does not currently have any production Information for this well. 3.The produced water storagevessels,hydrocarbon loadout,and onndensate storage vessels are controlled by the same enclosed combustor at this facility.Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled bye common control device.In this case,the highest emitting source is the condensate storage vessels.Asa result,the pilot light combustion emissions are included In this analysis. 4.It should be noted that an emission factor for VOC associated with pilot light combustion is not incorporated into the permit.This is due to the fact that the pilot light only results in a negligible contribution of VOC (0.0006 tpy).This minimal amount of emissions does not impact the total VOC limit for thls source and therefore can be ignored. 5.Initial and periodic opacity testing is not included in the permit because It is addressed by the visible emissorrs observations included in the 0&M plan. 6fff, 4tvffrsYx 6.The operator was provided with a draft permit and APEN redline to review prior to public comment.The operator reviewed both documents and expressed they had no comments on the APES redlines an provided one request on the draft permit.The request and Division response are as follows:(I)Request:"We will review more completely,but I have an initial question/comment regarding the initial sample requirement for the condensate tanks(20WE0353).This facility was shut in soon after startup due to the oil prim crash.It didn't produce long enough for into be able to order a sample((usta few days Ill recall), otherwise we would have provided In the initial application.We are unsure about when It will actually start producing again—R will likely be dependent on oil prices.Is there any language that could be written to allow fora sample to be pulled within a certain timeframe after resuming operation?"Pi)Updated permit leng®ge:Condition 18 In the permit was updated to Include the following language based on discussions with the operator:"If the existing well at this facility(API Number 05-123-50496)remains shut in for more than one hundred and eighty days(180)after issuance of this permit,the owner or operator must complete the site specific sampling detailed in this condition within 30 days of well start-up.Far this condition,well startup shall be defined as the day that pressure returns to the well production equipment.The operator reviewed the updates and expressed they had no further comments on the draft permit.The full discussion thaled to the updated permit language's available in the emalls that have been uploaded to records onager. Section 09-SCC Coding and Emissions Factors(Far Inventory Use Only). Uncontrolled Emissio ns AIRS Point# Process# SCC Code Pollutant Factor Control% Units _ 01 Ried Roof Tank,Condensate,working+breathing+flash ng losses PM10 7 IS b/1,000 gallons Condensate throughput PM2.5 5_„ 0 b/1,000 gallons Condensate throughput 500 7 51 b/1,000 gallons Condensate throughput NOe G.-9 0 b/1,000 gallons Condensate throughput VOC C..i.- 59 b/1,000 gallons Condensate throughput CO ≥_OT 0 b/1,000 gallons Condensate throughput Benzene 5 57 55 b/1,000 gallons Condensate throughput Toluene _.Y_ 95 b/1,000 gallons Condensate throughput Ethylbenzene ".00 95 6/1,[00 gallons Condensate throughput Xylene 0.-0 95 6/3,030 gallons Condensate throughput n-Hexane 0» 95 b/1,000 gallons Condensate throughput 224 TMP 0.00 99 b/1,000 gallons Condensate throughput 3 of 5 C:\Users\hslaught\Desktop\123A0D9\20WE0353.CP1 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below ore determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements ATTAINMENT} 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greaterthan 2 TPY(Regulation 3,Part A,section 11.0.1.a)7 2. Is the construction date(service date(priorta 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and lesion 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPV,NOx greater than 1OTPV or CO emissions greater than 1OTPV(Regulation 3,Part B,Section 11.0.31? I/,....._,rauc..u.atkat source is in the Nan-Artaimnent Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan 1IPS(Regulation 3,Pang,Section 11.0.1.2)7 \(as'':^?ik,Source Requires an APEN.Go to the next question 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 112 and1.14 and Section 2 for additional guidance on grandfather applicability)? Fd0 yJ".Goto next question 3. Aretotal facility uncontrolled VOC emissions greater than 2TPY,NOR greater than 5TPY or CO emissions greater than 1OTPY(Regulation 3,Part 8,Section 11.0.2)7 Yes ,Source Requires a permit 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 l.A.1)? Von Continue-You have Indicated the sde attainment status on the project summary sheet. 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 0,Section l.A.1)7 150 Continue-You have indicated the facility type on the project summary sheet. 3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part 0,Section l.G)7 No Storage Tank is not subject to Regulation 7,Part 0,Section i.G-You have indicated facility type on project summary sheet. 4. Does this storage tank contain condensate? Yes 5. Does this storage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation 7,part 0,Section 1.5.2(? 6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part O,Section 1.0.3.a(ii))? torxt.,,,.a:ri. �IIiriix�p;e rarzfs i;:subinunc.cs lleguletn'nn'➢,1101 A,00',10..0, Part O,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Part D,Section I.C.Z—Emission Estimation Procedures Part D,Section 10—Emissions Control Requirements Part D,Section LE—Monitoring Part 0,Section I.F—Recordkeeping and Reporting 50n,,,on Took D n.n'snhN¢�e 12,,tint siiucl,,r,/,1O,12..rry I.G Part D,Section 1,0.2 Emissions Control Requirements Part D,nestles I.C.La and b—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Colorado Regulation 7,Part 0.Section II 1. Is this storage tank located ate transmission/storage facility? 0., Continue-You have Indicated the source category on the Project Summary sheet 2. Is this storage tank'located at an oil and gas exploration and production operation,well production facility°,natural gas compressor station'or natural gas processing plant°(Regulation 7,Part 0,Section li.C)7 Ion Go forks next question-You have Indicated facility type on project summary sheet. 3, Does this storage tank have a fixed roof(Regulation 7,Part D,Section ll,A.20)? Yes :.Go to the next question 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year sod(Regulation 7,Part D,Section u.C1.c)? Yes Source is subject to parts of Regulation 7,Part D,Sections R.B&C.Gotq the next quetti0n Part 0,Section II.0—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 ll.C.3-Recordkeeping Requirements 5. Does the storage tank contain only stabilized I q d(Regulation 7,Part D,Section II.C.2.b)? INo 'Source is subject to all provisions of Regulation 7,Part D,Section 11,Subsections B&C 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 ate facility that was modified on or after May 1,2020, 6. such that en additional controlled storage vessel is constructed to receive en anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part D,Section II.C.4.a.(i)? No .:'Storage Tank Is not subject to Regulation 7,Part O,Section R.C.4 Is the controlled storage tank located at a wellp d ct facility, t l gas compressor station,or natural gas processing plant constructed on or after-January 1,2021 or located ate facility that was modified on or after January 7. 1,2021,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 11 C4 a(II)7 No 40 CFR.Part 60.Sub art 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(m')['"472 BBIs](40 CFR 60.110b(a))? IN°.: Storage Tank Is not subject NIPS Kb-The storage vessel capacity is below the applicable threshold. 2. Sees the storage vessel meet the following exemption in 60.111b(d)(4)? a.Does the vessel has a design capacity less than or equal to 1,589.874 ms['"10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined in 60.1116? 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)afterluly23,1984(40 CFR 60.110b(a))? NA 4. Does the tank meet the definition of"storage vessel"'in 60.111b7 NA S. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined in 60.1116? NA 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(-29.7 psi]and without emissions to the atmosphere(60.110b(d)(2))7;or NA b.The design capacity Is greaterthan or equal to 151 m5[`950 BBL]and stores a liquid with a maximum true vapor pressures less than 3.5 kPa(60.110b(b))?;or NA c.The design capacity Is greaterthan or equal to 75 M0[-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))? NA 7. Does the storage tank meet either one of the following exemptions from control requirements: NA a.The design capacity is greaterthan or equal to 151 m'(`950 BBL]and stores a l iquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?;or NA b.The design capacity Is greater than or equal to 75 M'[-472 BBL]but less than 151 m°["950 BBL]and stores a liquid with a maximum true vapor pressure greaterthan or equal to 15.0 kPa but less than 27.6 kPa? NA -,r „u Took is notsi,biucite N1PS I(k • • 90 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? Y,' Continue-You have indicated the source category on the Project Summary sheet. 2. Was this storage vessel constructed,reconstructed,or modified(see definitions 90 CFR,60.2)between August 23,2011 and September 18,20157 - WNW,Storage Tank is not subject NSPS 0000-Go to the next question to continue determination of NSPS 0000a applicability. 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 90 CFR,60.2)after September 16,20157 Va3 '5,Go.to the next question 4. Are potential VOC emissions'from the Individual storage vessel greater than or equal to 6 tons per year7 n y "v$.`r`'Go to the next question r 5. Does this storage vessel meet the definition of"storage vessel"'per 60.5430/60.5430a7 1g ,,c Gotothe next question 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH7 No Source Is subject to NSP5 0000a 'Stoat.tank i.t sub'ecl'C>NSFS 00000 Subpart A,General Provisions per§60.5425a Table 3 §60,5395a-Emissions Control Standards for VOC §60.54132-Testing and Procedures §60.5395a(d)-Notification,Reporting and Recordkeeping Requirements §60.5416a(c)-Cover and Closed Vent System Monitoring Requirements 460.5417a-Control Device Monitoring Requirements (Note:H a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to SOPS 0000/0000a per 60.536S(e)f2)/60.5365a(e)(2)even If potential VOC emissions drop below 6 tons par year( 40 CFR,Part 63,Subpart MAR HH.Oil and Gas Production Faelllnles 1. Is the storage tank located at an oil and natural gas production facilitythat meets either of the following criteria: V., Continue-You have indicated the source category on the Project Summary sheet. a.A facility that processes,upgrades or stores hydrocarbon liquids'(61760(2)(2));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 is delivered to a final end user'(63.760(a)13117 2. Isthetank located at a facility that is major'for HAPs7 • No Storage Tank is not subject MAC HH-There are no MAC HH requirements for tanks at area sources 3. Does the tank meet the definition of"storage vessel"°In 63.761? NA 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per 63.7617 NA 5. Is the tank subject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 00007 NA. t Iv- m,, reF{v91t<':'FtRH Subpart A,General provisions per§63.764(a)Table 2 463.766-Emissions Control Standards 63.773-Monitoring M.174 flecordkeeping • §63.775-Reporting RACT Review RAC review is required If Regulation 7 does not apply AND If the tank Is In the non-attainment area.If the tank meets both criteria,then review RACT requirements. • Disclaimer This document assists operators with determining 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 if 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 legal,binding requirement and is not legal,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," end°can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and°required"are intended to describe controlkng requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legal,binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Edge Energy II,LLC County AIRS ID 123 _ History File Edit Date 012012030 Plant AIRS ID A0D9 Ozone Status Non-Attainment Facility Name Akbary/1A Pad EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total 422 0 a 2 A 'I 1,, .. .,. h i' ,, 4 4 'as htFar:<,'un,, r113111'¢e 4SC,i 1c,' 22')HP .>hd 25.39,i,3s ,1C1r. „'2VVl tU,12,4 [144{4;40',(10 tiseCl[Mt"(,e,iteienie1Qe Cl;e 1, ,,r) / ,,03} , , t",J .2 i t, 1.111 0 5 Nee,sae'', 541_i ',4511,.'<l''v'e:fe i anti cove storage 411001ett,: Gjtltilt.j 1%11.34000(j(4 Tye,(,?)400 obi tx ,t s,s,,s 00,000,(1 1)0) i.,3 J.U 0 3 1/2 i 1 '.'.A 0 0 0 0 r,4 13.l =-0 7 1't f,n i‘10,4(e,,,, ,n,,,.1,m e,kt 131' (04,1 alealate V"!rues steluge vessels attalssea.+ U.4 ;1,/002Y.. YsydrUca(bun'_IJi11,)t:na<'.[ U'0 ')l, 1,U o0 ..-", 0 !1, .1.3 00 31, 150 J0 )1 ':0 Non 6';).'.a. .5.x1"'15110)1:'r,n,. ' ,etveldt, eletss 1,, XA One(1)0.5 MMBtu/hr Heater 0.0 0.0 0.3 0.0 0.2 0.0 0.0 0.0 0.3 0.0 0.2 0.0 Insignificant Source XA Fugitives 0.3 0.0 0.3 0.0 Insignificant Source 0.0 0.0, 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.4 0.4 0.0 0.0 28.6 630.7 0.3 15.2 12.6 0.4 0.4 0.0 0.0 4.5 33.1 0.3 13.3 0.9 VOC: Syn Minor(PSD,NANSR and OP) NOx:True Minor(PSD,NANSR and OP) CO: True Minor(PSD and OP) HAPS: Syn Minor n-Hexane HH:Area source-no affected sources 7777:Area source Permitted Facility Total 0.4 0.4 0.0 0.0 28.3 630.7 0.0 15.0 12.6 0.4 0.4 0.0 0.0 4.2 33.1 0.0 13.1 0.9 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.4 0.4 0.0 0.0 4.2 33.1 0.0 13.1 Modeling not required based on O change in • emissions.Pubcom is required b/c new syn minor limits are being established and the change in VOC emissions is greater than 25 tpy. Total VOC Facility Emissions(point and fugitive) 33.4 Facility is eligible for GP02 because<90 tpy(CO) and<45 tpy(NOx and VOC) (A)Change in Total Permitted VOC emissions(point and fugitive) 33.1 Project VOC emissions greater than 25 tpy **Next engineer-confirm site specific emission factors were developed for point 002.The first issuance requires the operator to develop SSEF and modify the permit in order to use the SSEF for emission calculations and ongoing compliance.This requirement is per PS Memo 14.03 which requires the operator to develop and use SSEF"For exploration and production(E&P)facilities when uncontrolled VOC emissions from a storage Note-I tank are greater than or equal to 80 tpy when calculated using state emission factors." Note 2 Page 1 of 2 Printed 6/3/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT MR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs • Company Name Edge Energy II,LLC County AIRS ID 123 Plant AIRS ID A0D9 Facility Name Akbary/1A Pad Emissions-uncontrolled(lbs per year) POINT(PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH .224 TMP H2S TOTAL(ipy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 SI RICE Cummins GTA855,4SRB,225 376.9 51.3 48.4 29 56.3 0,3 HP,SN:25397908 002 20WE0353 Four(4)400 bbl fixed roof condensate 2103 18396 10.2 storage vessels 003 20WE0354 Two(2)400 bbl fixed roof produced 920 2891 1.9 water storage vessels 004 20WE0355 Hydrocarbon Liquid Loadout 37 317 0.2 XA One(1)0.5 MMBtu/hr Heater 10 0.0 XA Fugitives 1.5 3.4 1.2 4.5 10.4 0.4 0.0 0.0 - 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.2 0.0 0.0 1.5 0.0 0.0 0.0 10.8 0.0 0.0 0.0 0.0 12.6 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions e de rninimus Emissions with controls(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP 128 TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 SI RICE Cummins GTA855,4SRB,225 376.9 51.3 48.4 29 56.3 0.3 • HP,SN:25397908 002 20WE0353 Four(4)400 bbl fixed roof condensate 106 920 0.5 storage vessels 003 20WE0354 Two(2)400 bbl fixed roof produced 46 145 0.1 water storage vessels 004 20WE0355 Hydrocarbon Liquid Loadout 2 16 0.0 XA One(1)0.5 MMBtu/hr Heater 10 0.0 XA Fugitives 1.5 3.4 1.2 4.5 '10.4 0.4 0.0 0,0 0.0 0.0 • 0.0 • 0.0 • 0.0 TOTAL(tpy) 0.2 0.0 0.0 0.1 0.0 0.0 0.0 0.6 0.0 0.0 0.0 0.0 0.9 2 123A0D9 6/3/2020 PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Packaged: 428307 Received Date: 3/31/2020 Review Start Date: 5/11/2020 Section 01-Facility Information Company Name: Edge Energy ii,LLC Quadrant Section Township Range County AIRS ID: 123 Lot 1 1 8N> - 67 Plant AIRS ID: A009 Facility Name: Akbary/1A Pad Physical Address/Location: County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment:Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blaisk-For Division Use Only AIRs Point q Permit it (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already 8 Required? Action Remarks assigned) assigned) Permit Initial 003 Storage Tank PW 1-2 Yes 20WE0354 1 Yes Issuance Section 03-Description of Project Edge Energy II,LLC submitted an application in order to permit several sources at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area.With this application the operator is requesting traditional permit coverage for condensate storage vessels,produced water storage vessels and hydrocarbon liquid loadout.The operator is also requesting GP02 coverage for one(1)engine.This analysis only addresses the produced water storage vessels. An APEN is required for the produced water storage vessels because uncontrolled requested V0C emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Section II.B.3.a.).Additionally,a permit is required because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 2 tpy(CO AQCC Regulation 3,Part B,Section II.D.2.a.). Public comment is required for this permit because new synthetic minor limits are being established in order to avoid additional requirements.Additionally,the change in VOC emissions as a result of the project are greater than 25 tpy. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ O ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ O ❑ O O O Non-Attainment New Source Review(NANSR) ❑ El Is this stationary source a major source? No If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ O ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review(NANSR) ❑ O Section 01-Administrative Information Facility AIRS ID: 123 AOD9 003 County Plant Paint Section 02-Equipment Description Details Storage Tank Liquid Produced Worst.,` a Detailed Emissions Unit Two(2)400 barrel fixed roof produced water storage vessels connected via liquid manifold. Description:Description: Emission Control Device Enclosed Combustors( Description: - - Requested Overall VOC&HAP Control Efficiency%: Limited Process Parameter ,Liquid Throughput - Section 03-Processing Rate Information far Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= _ 109,500.0 Barrels(bbl)per year (Requested Permit Limit Throughput= :. 131,400.0 Barrels(bbl)per year Requested Monthly Throughput= 11350.9 Barrels(bbl)per month Potential to Emit(PIE)Condensate Throughput= -':131,400.0 Barrels((bbl)per year ' Seconder/Emissions-Combustion Device(s) Heat content of waste gas= 1496.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced= ;36,0 scf/bbl Actual heat content of waste gas routed to combustion device= r MMBTU per year Requested heat content of waste gas routed to combustion device= MMBTU per year Potential to Emit(PIE)heat content of waste gas routed to combustion device= MMBTU per year Control Device • ' Pilot Fuel Use Rate: . ' scfh . MMscf/yr Pilot Fuel Gas Heating Value: _ __.. __-- Btu/scf : MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? ei Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) ;;r - Produced Water State EF.)inclurtns flash)- VOC ,�;2.B2E-D 1.3..1•0: Front Range&Other y, z',; Produced Water State E.F.(includes flash)- Benzene 't 706E 3.;--re 81 Front Range&Other Toluene y u . -00 Ethylbenzene - x.K-I 0 I 0.002,00 Xylene Ai '"7fl.Pq. 0.00'0-C+', I°9_,...,,'413;4‘,2,. .Z-9113- , Produced Water State E.F.(includes flash)- n-Hexane A_ _=i 3.302s_.,: Front Range&Other 224TMP 100." rani f).0.. Device Uncontrolled Uncontrolled Pollutant )lb/MMBtu) (lb/bbl) Emission Factor souse (waste heat (Produced Water combusted) Throughput) PM10 0.0075 _t AP-92 Table 1.4-2)PM30/PM.2.5j PM2.5 0.0075 AP-42Table 1.4-2)PM30/PM.2S) 50x 0.0006 -,. AP-42 Table 1.4-2(Sax) NOR 0.0600 , 1 AP-42 Chapter 13.5 Industrial Hams(NOR). CO 0.3100 AP 42 Chapter 13.5 Industrial Flares(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) _ Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 PM2.5 50x 0 0.,1 NOx VOC CO Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 .. __ ;.1, 5. PM2.5 c 3239 823 ..32 552'1 .,,.-. 900 i'992 0.322 03307 0.002 .UC'0 2- NOx 02»1 -___- 0.2Cu 0.241 1 241 VOC 1111. _'345 9.7(',7 1:'21.3 ( 0.8:.3 1111. CO 1.197 . _» .,3:0 )097 1 1 C '.3!.i Potential to Emit Actual Emissions Requested FErerlt Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) (Ibs/year) (lbs/year) Ohs/year) Benzene 3.3 800 760500 38 3:4 919.300 45.990 Toluene 9.136 -320 ,10L-0 1 h0 0.090 Ethylbenzene 3 300 1._0 5.304 0.0.0 Xylene a 000 -022 O.001 0 000 0.210 n-Hexane 2330.000 0409°on 120.150 2530.000 144.540 224 TMP 3300 0 030 3.200 52-2 2 of 4 C:\Users\hslaught\Desktop\123AOD9\20WE0354.CP1 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7,Part 0,5ection I.C,D,E,F - Regulation 7,Port D,Secticn.0,C Regulation 7,Part D,Section II.0,C.1,C.3 Regulation 7,Part D,Section II.C.2 Regulation 7,Part D,Section II.C.4.a.)I) Regulation 7,Part D,5ection II.C.4.a.(ii) ccn Regulation 6,Part A,NSPS Subpart Kb Regulation 6,Part A,NSPS Subpart 0000 NSPS Subpart 0000a Regulation B,Part E,MAR Subpart 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? _p If yes,are the uncontrolled actual or requested emissions for a crude all 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? :N/A-this analysis is for produced water storage vessesls. 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? affi,%• .r" 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 IT' .. sample should be considered representative which generally means site-specific and collected within one year of thefliffNIZ application received date.However,ifthe facility has not been modified(e.g.,no new wells brought on-line),then It may be appropriate to use an older she-specific sample. y'N/A-the operator used the state default emission factors to estimate emissions. 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. P Does the company requesta 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 1.According to the application,one well produces to this facility.The well nameand API number is as follows,(i)Name:Akbary 436-3H,API Number:05-123-50496.According to the application,this well is currently shut in.As a result,COGCC does not currently have any production information for this well 2.The produced water storage vessels,hydrocarbon loadout and condensate storage vessels are controlled by the same enclosed combustor at this facility.Asa result,the pilot light emissions arenot calculated In this workbook because they are evaluated with the condensate storage.vessels(20W E0353).Engineeringguidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device.In this case,the highest emitting source Is the condensate storage vessels. 3.Even though NOx and CO emssions from this source specifically are below APEN reporting thresholds,the total MOO and CO emcslonsfrom all sources controlled by the enclosed combustor(produced water storage vessels,condensate storage vessels and hydrocarbon loadout)are greater than APEN thresholds.As a result,the permit for each s urce controlled by the common control.device will Include limits on NO4 and CO emissions. 4.initial and periodic opacity t t g is not included In the permit because it is addressed by the visible emissions observations included in the O&M plan. 5.The operator was provided with a draft permit and APES redline to review prior to public comment.The operator reviewed all the documents and expressed they had no comments. Section 09-5CC Coding and Emissions Factors(For Inventory Use Only), Uncontrolled Emissions AIRS Paint 4 Process 4 SCC Code Pollutant Factor Control%Units 01 4-04403-15 Fixer(Roof Tank,Prafiwlod Water,wotkinfl+breathinguflashing lone- _ PM1D 0 6/1,000 gallons Produced Water throughput _ s - �_a.. PM2.S .91 6/1,000 gallons Produced Water throughput 504 :,._c. 2 b/1,000 gallons Produced Water throughput NO4 c'5 _ 6/1,000 gallons Produced Water throughput VOC _..-• b/1,000 gallons Produced Water throughput CO 1.50 G b/1,000 gallons Produced Water throughput Benzene _._. Os 6/1,000 gallons Produced Water throughput Toluene 000. _5 6/1,000 gallons Produced Waterthroughput Ethylbenzene :.7.. y_ b/1,000 gallons Produced Water throughput Dylene C b/1,000 gallons Produced Water throughput n-Hexane 7.52 39 6/1,000 gallons Produced Water throughput 224 TMP +1:70 95 b/1,000 gallons Produced Water throughput 3 of4 C:\Users\hslaught\Desktop\123A0D9\20WE0354.CP1 Storage Tank RegulatoryAnalysls Worksheet • The regulatory requirements below are determined based on requested emissions. enkraa .Winn 3 Nro A and a-APEX anti PmnR Rewlremems 1.Are A actual ernIsslons ram any alter,pollutants f ram tAlsIndhildual TTAINMENT source treaterthan]mv lReguatan3 PartA zest on Oval]uncontrolled 3.Are total er nn bulky uncontrolled VaC.ernIssbns greater than 5 TV,x aTwor[aunasem greater than l0>Pr IReNkakn3,Pan e,sestnn 40:31]NON.Are lumsxi 1.t.Are emisuons from any urtenapallutank from Ms maivltlusssour ereaterthan1TPY lReful+llon 3,P+rtA.senlen x.O.ia11 sown qIr an APEX.°nmthe natqu Inn z.Reduced Wsseri+nksnaveno ganalameringpmvWom No Go to non qumbn 3.Ale total Malty uncontrolled vo[emil..crenerthani TPY.N°v greater than 5TPv or CO emisunwgrorerthan301Pt Neuh.v.Parta,5enlen Hail? Yes Source ReNwra+permit • Regulation xNaol.C. 1.NO.storage Mnit located in the 6hr ozone control area or anV ozone noll.altalninent area or tint/ma ultContinue-You satesn shat. ehpra as rprmume wa.Ax°aAssaminrneeator p umnta ass Iwp +tip IRegubuon].Pan O.Yroonln3R mkn 3.Is this storage tank located at a natural Vs processing plant, kwn].pan o,xmnn l.alt upragelank Want wyattn aeeuWnnn],Nrt°,Ynlon i.,-vnunaelnairnee ryryp npruxsumm+ry sneer. uiasl em ns lReeua ,.xR • Part',Seal. -Enrussions Control Requirements e.are un em ,Wanxren p rvur V°[,Re¢axon].Part O.senion l.0.3.aIRIR %ea.....chit° Ion[onxol[gmpmem-prewmlon of.tag= Nn gseatlon AF-a mrateeplmeane Reponlne Part O,Sac. and OS Ural Repubemenlslor Alr Pollution Control Equipment-Prevention el Leakage Colorado v aalon Part Yginn n e ssioamonee WnlllNCon..- r m eagonxan and production operation.raF me.dunpnlaatV.wturn e+scompresuer rntbn or natural gas process.,plant.,Regulation',art Il.gi -You hare Indicated faobry type on pr Jea summary sheet. a.Are un p rywrv0g,a=gulssmn],Nttgsmmnll.S.cIF vas....snura.s waknr p of ugulorlon],Pan O,semonsosae.Gatomenatq anon ' Ito u.4z GEmk Prov,s:ons a"tang rteventmnnf Emlwew the non INN .Source Is subject to all provislens ofRegpat nnzpaa asecten :ue+emnnma[ Pon0[o Mona iro9uct1p9pPA11Ratural scour NOWkVNllllltyllltlmPxkral wmnepant constructed on or Aker May 1,zm0 orocamexafad.that was eel on or after Alay1,2020. G.roar ono cu atea areas into got InMmarmnaqu asorprmumdwn.IR¢u aoon>.Nn o.Yv on t[.a.all] xo IsoageTant u not subject t Regulation.7,Nall Section 7.I,]m atna Increase Inthrough of hydrocarbon q rp ucedwnr,Regulation].Part D.Section aalm,maanaraxnJapa' tin I w�nt MICK',raw subpart Kb, NAFNNA Lipoid Roane... 1.Is the W.W.I stoop vessel pace unto-th nor equal to 75 obit motor,m,l-aneelsl,.a[rRaa.33ab1,111 unnn]+nkl+nnt,unlatxxsxA-mennnge vest�wwotYebelnwthe,PpllcebktA,ahple. 3.Does the aerate veaelmeettbefolbvilna orern,bn In 60.11.1bIdIVIR NA a."oust.vessel bas a design capaelty less m1'IO.Om ReLl used for pexokum'or wndenrge stored.processed.or treated purr to custody transfer as defined In 60.1110 3.Was thLs storage vessel conssructed,reconstructed,'mndIll d equal,IMO.. ga[ra[axl+her July niece 1pn[FRsa110134llt NA S.Doestheao,e wool store a'volatile orpoic (Nees defined In 60.11., NA e.Dees thesteraee vemel meetany one of the followtneaddluonal aemoNona. P„-is pall an m:s=nean aldo.abMIl31PNA m'[zmgellana.mre:.ppa®hamu,n m„ue vapor prom.,e WA,S0.11M,),,or design Is reater than or M'[-a]earl Au m'l-Pso ea4+.nmesa bpu,a wlln+mavimum vu p messure k.mw ss.0 walg0.vdn,blRNA oolrequirernentv boa m'(-amBatlnan a.The a one exemptions dstole,aaue withama um trye vapor pressure great..Nan or...1.3.5,Pa but lei man sax kPat or xA h rnee der e>sm`,-an ,put eamanlslm lres0aeLl,naamew'duawtM1,ma:mumnuewpar pressuregala Wan oregw u3x0YNbuek.INnn SYNr AN • In M.,Part SO,subpart 000o1000oz,StAnaaras of Federman.for Cmdn'Aland Natural,.Product.,Innsmissmn and nk,lbutmn 1.Is thisatorapa vessel located at a tad',In the onvharo anr,naWolessproductbnseement.naturalosprocesdneseernankor natural .ion and stooge segment of the Industry] n Pro arnmary sheet. 2.Was Ms storane vessel.constructed.reconstructod.or led Ixe en itbnsm[FRso.zl between August 233.2GII and Ypte tier a on z Ho StoranoTank Is not subject..moo-Go to the not ponion to continue aster ion of xsn°cool applublbty 3.Was this storage vessetconAruned.reconstructed.or o O.1l atter September IS,20151 n pert'r] No rage Tank lanotsuNW N5Ps 0000a. yeq 6.tithe rnrgev won repuuemeotslornorwev.axlnmcSRPan ea p gh or m[FR Nrta1 p NN] NA Ihmg:It a storage wool k pmbusly doo m.mtn Yu:genm hops 0000/oo00a due to emmtons above F tom wrvwrvoe an the applicability determination dare,it Mid remnn suyantoxsn 0000/cocoa per Sasses,ell],/A0.s5M ale AI ANNn R peon.,vo A emtak ns drop!Wow a tons r Yw a • 90 CM Pan wnMAn AN,0a and Gasrmauamn Punkin 1.k Ole+ an oil an inguh.: I.' I[emmu.YouImrelnaateaue ounce ategoryonthe Prplectsummanebet. a.Afaaliry at Moos..upgrades arsto mpcocarhen quiide,6 m501a1R11.1oRfav b. eaty that protases,uperaeeserstores natural gm prim tote point at whIcb natural em enters the natural.trammbslon and stoma source category or is delivered Malin,end user',e3.leolalP111 2.Is Net..located at a lash,that Is malor'for HAMorage]ankisnwwgm wnxx.Tnnn are con MAnx n memsforumsaNrw souses 3.Doeu the tank meet the de.tion ol'storage veuser.ln 63.161, NA a.Does.tank meet the definFoon el'storage vessel wIth the',Mental for Ilmh en,ulonu" NA S.is the tank sublan to control re Wrements under an liPart 50..6 art.or Sub rt 0000, a l+lT bl z Mtn,Reporting PACT Pavlov, 4m.n el tianearez PACT reviewb teaIr OsReprmfon]does not apply AND If Should(b In the nomanalimansarea.Iftn+tank man muamda,them ono.Ma'Mel. T s opaeba NAN Meaning appI/ANNbN of am ant ain rare..., e Clem Air an,its irwermnllnarwIAny NFdAAOANIIN ule La.,Commies.reguNbns.Ails dacumml bona rule wrpulebom ANd gieerrdysis ilcmfaw meynol appN la apaNdn aifuebbn erased upon ANirAA!dANIVNN ssAMsicumalences.TAvareumenf acex no!sM1ergeo-sAANAI Alwanylew,tNAAtN Jan. w any.1. alNA"Miprpuirmmnf end oral Wally Mane.,eJo.event of any cmfiM legxeen Melprpugedaus dwulronte Ibe.pupar Lken AV Act itsrmpkmentAprryulefime, OuaiN ewrbolemNANNOA.rpwel/ms,NIN INAWpe a eeau.e or repdazm we,NNF&ra.The Luadm+mvraeAydfirscribeAPCOiamrlmpupesa.-�Iaz-3wwmn�d;mek"amox,and aan.,simuideero OwtMLorrwl Commissia+rpukimu,but lb/a dot-omen,noes rxI esaablAAApaNNnddp INQAAAJmo-renbgpmrbewsnmcmewmpremwaxm+urtlsgieWrwaa.cJmn avaclamw Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 3: 428307 Received Date: 3/31/2020 Review Start Date: 5/12/2020 Section 01-Facility Information Company Name: Edge Energy II,LLC Quadrant Section Township Range County AIRS ID: 123 Lot1 1 8N 67 Plant AIRS ID: AOD9 Facility Name: Akbary/1A Pad Physical Address/Location: .. County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment:Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOc) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 004 Liquid Loading LOAD-1 Yes 20WE0355 1 Yes Issuance Section 03-Description of Project Edge Energy II,LLC submitted an application in order to permit several sources at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area.With this application the operator is requesting traditional permit coverage for condensate storage vessels,produced water storage vessels and hydrocarbon liquid loadout.The operator is also requesting GP02 coverage for one(1)engine.This analysis only addresses the hydrocarbon liquid loadout. An APEN is required for the hydrocarbon loadout because uncontrolled requested VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Section ll.B.3.a.).Additionally,a permit is required because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 2 tpy (CO AQCC Regulation 3,Part B,Section II.D.2.a.). Public comment is required for this permit because new synthetic minor limits are being established in order to avoid additional requirements.Additionally,the change in VOC emissions as a result of the project are greater than 25 tpy. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ O O ❑ ❑ Title V Operating Permits(DPI O OOOO OOO Non-Attainment New Source Review(NANSR) O ❑' Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O O O O O ❑ Title V Operating Permits(OP) O OOOO OOO Non-Attainment New Source Review(NANSR) O O Hydrocarbon Loadout Erlissions inventory Section 01-Administrative Information (Facility 123 ADDS 004 AIRS ID: County Plant Pant Section 02-Equipment Description Details Detailed Emissions Unit i Hydrocarbon liquid loadout from .storage vessels to tank trucks using submerged fill. Description zsF Emission Control Device >1 Emissions from this source are captured and routed to the enclosed combuaor(s)using vapor balance. Description: ten, Is this loadout controlled? Requested Overall VOC&HAP Control Efficiency H: 95 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= 73,000 Barrels(bbl(per year 'Requested Permit Limit Throughput= 87,600 Barrels(bbl(per year Requested Monthly Throughput= .- Barrels(bbl)per month Potential to Emit(PTE)Volume Loaded= 87,600.Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2255 Btu/scf Actual Volume of waste gas emitted per year= scf/year 1.376061538 Requested Volume of waste gas emitted per year= scf/year Actual heat content of waste gas routed to combustion device= .."MMBTU per year Requested heat content of waste gas routed to combustion device= MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= MMBTU per year Control Device I I 1 Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf MMBTU/yr Section 04-Emissions Factors&Methodologies Does the company use the state default emissions factors to estimate emissions? Yea Does the hydrocarbon liquid loading operation utilize submerged fill? .�Ye5`( The stated=-fault emissions fasters may be used to estimate emissions. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC E Condehsatehoadeohp5TateE F Benzene - CpndensatpLOadoutSfatf .F Toluene - - Ethylbenzene Xylene n-Hexane .. _ - Cebdensate7.uadouCSfateE F 224 TMP .. a Control Device Uncontrolled Uncontrolled Pollutant Emission Factor Source (Ib/MMBtu) )lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 _E_ AT%l2Tabl�1,4.2(RNiI/PM 25) ._ PM2.5 0.0075 __ AP-42Table3',4..2)PM0fPM 2.5) 5Ox 0.0006 - Ar.42Tablel,4-2(5E xs- NOx "0.0680 At-4iChaptae 13sledpstn IFleeoRr(NOx) CO 0.3100 _ f4,42 Chd¢t?Y13.51tttduotrial Flar₹5.(CO) 4- Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM10 PM2.5 SOx - 4n.'., NOx tx ')4= - VOC 2 of 4 C:\Users\hslaught\Desktop\123A0D9\20W E0355.CP1 Hyd ff aiba fl Loodout Emissions.tr,,fentcry Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tuns/year) (tons/year) (tons/year) (tons/year) fibs/month) PM10 .-. _.. PM2.5 500 -. 2,200. NOx CO Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (Ibs/Year) (lbs/yearl llbs/year) Benzene ,. 25 . .... Toluene Ethylbenzene ,.. Xylene ... _ - n-Hexane ,.-. ., .. 224 TMP 0 I ... _, Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7 Part D Section II.C.5. _... ., .__.-.,. (See regulatory applicability worksheet for detailed analysis) 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 1.According to the application,one well produces to this facility.The well name.and API number is as follows:.(i)Name'Akbary#36-311,API Number:05-123-50496.According to the application,this well is currently shut in.Asa result,COGCC does not currently have any production information for this well. 2.The produced water storage vessels,hydrocarbon loadout and condensate storage vessels are controlled by the same enclosed combustor at this facility.As a result,the plot light emissions are not calculated in this workbook because they are evaluated with the condensate storage vessels(20W E0353).Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device.In this case,the highest emitting source is the condensate storage vessels, 3.Even though NOx and CO emissions from this source specifically are below APEN reporting thresholds,the total NOx and CO emissions from all sources controlled by the enclosed combustor(produced water storage vessels,condensate storage vessels and hydrocarbon loadout)are greaterthan APEN thresholds.As a result,the permit for each source controlled by the common control device will include limits on NOx and CO.emissions. 4.Initial and periodic opacity testing is not included in the permit because it is addressed by the visible emissions observations included In the O&M plan. 5.Benzene emissions are below APEN reporting thresholds(I.e.<250 lb/year).As a result,an emission factor will not be included in the permit for this pollutant. 6.The operator was provided with a draft permit and APEN redline to review prior to public comment.The operator reviewed all the documents and expressed they had no comments. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point# Process SCC Code Pollutant Factor Control% Units 004 01 4-00-5)522 ..!S, _ PM10 lb/1,000 gallons transferred PM2.5 Ib/1,000 gallons transferred SOx 4..a-C3 0 lb/1,000 gallons transferred NOn S.oY»0,s 0 lb/1,000 gallons transferred VOC 5..„2 52 lb/1,000 gallons transferred CO 0 lb/1,000 gallons transferred Benzene 9.30,=_-3., )5 lb/1,000 gallons transferred Toluene 0-10C.,00 17 lb/1,000 gallons transferred Ethylbenzene G.0.52=5,0 lb/1,000 gallons transferred Xylene .:5,.Ea0G lb/1,000 gallons transferred n-Hexane F. 3e.G2 _5 lb/1,000gallons transferred 224 TMP 552.501 05 lb/1,000 gallons transferred 3 of 4 C:\Users\hslaught\Desktop\123A0D9\20WE0355.CP1 • Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements Scarce n,in the Nan-Aliulevrem Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. 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)? 'You have indicated Clraat source is In the Non-Attaininent Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section II.D.1.a)? Yes Go to next question. 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)? Yes Go to the next question 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? No Go to next question 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next question 5, is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No,_ Go to next question 6. 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 II.D.2)? Yes +'..The loadout requires a permit (Source requires a permit Colorado Regulation 7 Part D Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility,natural gas compressor station or natural gas processing plant? Yes Go to next question. ?. Dees the f7Elllt.Yshst&a,,thraBehRIit.nf by rptarhpn lIANIfta laadnet tq trepepgrt vehicles greater then or equal to 5,000 barrels? Bourne Is subject to Regulation T Part D section II.C.9. Ii he hydrocarbon liquids loadout source is subject to Regulauna: Section I I.C.5.a.(i)-Compliance Schedule Section II.C.5.a.(ii)-Operation without Venting Section II.C.S.a.(iii)-Loadout Equipment Operation and Maintenance Section II.C.S.a.(iv)-Loadout observations and Operator Training Section II.C.S.a.(v)-Records Section II.C.S.a.(vi)-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining 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 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 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. Condensate Storage Tank(s) APEN Mt��M ikkiY_ro Form APCD-205 C0PHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt 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 tacks 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: Zr,D�E j7. -43 AIRS ID Number: /2_3 /A0p9./ G [Lease btank unless A CD has alread, assigned a perm,:r:and AIRS ID] Section 1 -Administrative Information Company Name': Edge Energy II, LLC t4;? • Site Name: Akbary/ 1A Pad Site Location Site Location: Lot 1 Sec. 1 T8N R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 1301 Washington Ave. Suite 300 Golden, CO 80401 Contact Person: Ben Turner II Phone Number: (720) 599-3650 E-Mail Address2: BTumer@edgeenergyl.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 wilt require additional paperwork. 2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 428303 ® COLORADO Form APCD 205 Condensate Storage Tank(s) APEN - Revision 12/2019 1 ''.lIMM116 Onitonmn Permit Number: 20WE0353 AIRS ID Number: 123 / A0D9/ 002 [Leave blank.unless APCD has already assigned a permit»and AIRS ID) Section 2 - Requested Action ❑r NEW permit OR newly-reported emission source ID 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$312.50 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 ownership"' ❑ 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 8t Notes: 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 Company equipment Identification No. (optional): TK 1-4 For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: 3/4/2020 I I Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: Exploration&Production(E&P)site ❑ Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? ❑� Yes 0 No Are Flash Emissions anticipated from these storage tanks? El Yes 0 No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? ❑ Yes ✓❑ No If"yes",identify the stock tank gas-to-oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes Q No 805 series rules? If so, submit Form APCD-105. _ Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual Q Yes ❑ No emissions≥6 ton/yr(per storage tank)? COLORADO Form APCD-205 -Condensate Storage Tank(s) APEN - Revision 12/2019 2 I Je® � «. Permit Number: 20WE0353 AIRS ID Number: 123 / A0D9 / 002 [Leave blank unless APCD has already assigned a permit x and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bb(/year) • (bbl/year) Condensate Throughput: 73,000 87,600 From what year is the actual annual amour►t? 2020 Average API gravity of sates oil: 40.4 degrees RVP of sales oil: 9.0 Tank design: ❑� Fixed roof ❑ Internal floating roof ❑ External floating roof . Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/veto.) TK 1-4 4-400 bbl 1,600 3/2020 3/2020 I Wells Serviced by this Storage Tank or Tank Batter?(E&P Sites Only) Ii API Number I Name of Well Newly Reported Well I 05 123 50496 Akbary#36-3H Q_ It 0 1 0 1 • 0 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 EiiP 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 Geographical Coordinates (Latitude/Longitude or UTM) 40.69582/-104.8308 ❑ 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. Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec) COMB-1 20 1,000 • TBD i TBD Indicate the direction of the stack outlet: (check one) ❑� Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other piescribe): Indicate the stack opening and size: (check one) Q Circular Interior stack diameter(inches): 72 ❑Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): AtEk COLORADO Form APCD-205 - Condensate Storage Tank(sl APEN - Revision 12/2019 3 1 Permit Number: 20WE0353 AIRS ID Number: 123 / AOD9 / OO2 [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit (VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOCs and HAPs Rating: 9a28 MMBtu/hr Type: Enclosed Combustor Make/Model: MRW Technologies ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 1,000° F Waste Gas Heat Content: 2,255 Btu/scf Constant Pilot Light: Q Yes ❑ No Pilot Burner Rating: 0.025 MMBtu/hr Description of the closed loop system: 0 Closed Loop System • Pollutants Controlled: ❑ Other: 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)? 28 psig Describe the separation process between the well and the storage tanks: Product flows from the wellhead to one heated separator to the storage tanks. Gas is sent to a pipeline. Redlines per updated calculations. (HDS 05/20/2020) Anik COLORADO Form APCD-2O5 - Condensate Storage Tanks; APEN - Revision 12/2019 4 I � . Permit Number: 20WE0353 AIRS ID Number: 123 / A0D9 / 002 [Leave blank unless APCD has already assigned a permit r 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? 0 Yes 0 No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC Enclosed Combustor 100% 95% _ NOx CO HAPs Enclosed Combustor 100% 95% Other: From what year is the following reported actual annual emissions data? 2020 Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP 42, Emissions Emissions Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 13.70 lb/bbl State 500.05 25.00 600.06 30.00 NO„ 0.068 Ib/MMBtu AP-42 N/A 1.37 N/A 1.65 CO 0.31 Ib/MM8tu AP-42 N/A 6.26 N/A 7.5 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: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units Basis (AP-42, Emissions EmissionsB Number Mfg.,etc.) Ohs/year) (lbs/year) Benzene 71432 2.40E-02 b/bbl State 1,752.00 87.60 Toluene 108883 ' N/A NIA N/A N/A N/A Ethylbenzene 100414 NIA _ _N/A N/A N/A N/A Xylene 1330207 N/A N/A N/A N/A N/A r n-Hexane 110543 2 10E-01 Ib/bbl State 15.330.00 766.50 2,2,4-Trimethylpentane 540841 N/A N/A N/A N/A N/A 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-2O5 - Condensate Storage Tank(si APEN - Revision 12/2019 5 COLORADO Iftelth to tani nu* L Redlines per updated calculations. (HDS 05/20/2020) Permit Number: 20WE0353 AIRS ID Number: 123 / A0D9/ 002 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. Signature of Legally Authorized Person (not a vendor or consultant) Date Ben Turner Engineer Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 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 $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303) 692-3175 Air Pollution Control Division OR APCD-SS-B1 (303) 692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment " ® COLORADO r,t A ;y� 4}l.l _Zi)G (.O t_'n Ss ,�Storage Tank( ti('F hl RE.' t' 12 ��(',"'^ 6 I N.w lwn.w Produced Water Storage Tank(s) APEN te ,_.„ Form APCD-207 CDPHE 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 kicks 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: 2 WE 0359- AIRS ID Number: 12- /AgD 1 / 665 [Leave bank unless APCD has already assigned a permit r anc AIRS ID] Section 1 - Administrative Information Company Name': Edge Energy II, LLC --- Site Name: Akbary/ 1A Pad Site Location Site Location: Lot 1 Sec. 1 T8N R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 1301 Washington Ave. Suite 300 Golden, CO 80401 Contact Person: Ben Turner Phone Number: (72O) 599-3650 E-Mail Address2: BTurner@edgeenergyl.com ' Use the full, legal company name registered witi 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. 428304 COLORADO Form APCD-2O7- Produced water Storage Tanklsi APEN - Revision 12/2019 1 in.*, a , Permit Number: 20WE0354 AIRS ID Number: 123 / AOD9/ 003 [Leave blank unless APCD F:as al'eady assigned a permit z`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 0 GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 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 o Change permit limit ❑ Transfer of ownership's ❑ 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: 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. ec ion - enera n orma ion General description of equipment and purpose: Storage of produced water Company equipment Identification No. (optional): PW 1-2 For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: 3/4/2020 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 0 Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes 0 No Are Flash Emissions anticipated from these storage tanks? ❑ 1 Yes 0 No Are these storage tanks located at a commercial facility that accepts oil production 1 Yes No wastewater for processing? ❑ Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? Q Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 0 Yes 0 No 805 series rules? If so, submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions (per storage tank),or are uncontrolled actual Yes ❑ No emissions≥6 ton/yr(per storage tank)? COLORADO Form APCD 207 Produced Water Storage Tank(s)APEN Revision 12/2019 2 ( re"�'n, Permit Number: 20WE0354 AIRS ID Number: 123 / A0D9 / 003 [Leave blank unless APCD has already assigned a permit and AIRS ID Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Produced Water Throughput: 109,500 131,400 From what year is the actual annual amour? 2020 Tank design: ❑r Fixed roof ❑ Internal floating roof 0 External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) PW 1-2 2-400 bbl 800 3/2020 3/2020 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 • 123 - 50496 Akbary#36-3H ❑� 0 0 0 0 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 E&P 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 Geographical Coordinates (Latitude/Longitude or l/TM) 40.69582/-104.8308 ❑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. Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec) COMB-1 20 1,000 TBD TBD Indicate the direction of the stack outlet: (check one) 2 Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) El Circular Interior stack diameter(inches): 72 ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 12/2019 3 I allifer Permit Number: 20WE0354 AIRS ID Number: 123 /A0D9 / 003 [Leave blank un ess APCD has already assigned a permit a and AIRS IDI Section 6 - Control Device Information El Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit (VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOCs and HAPs Rating: 2126 MMBtu/hr Type: Enclosed Combustor Make/Model: MRW Technologies a Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 1,000° F Waste Gas Heat Content: 1496 Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: 0.025 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: O Other: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 28 psig Describe the separation process between the well and the storage tanks: Product flows from the wellhead to one heated separator to the storage tanks. Gas is sent to a pipeline. COLORADO Form APCD-2O7 - Produced Water Storage Tanks) APEN - Revision 12/2019 4 I > v Redlines per application. (HDS 05/20/2020) Permit Number: 20WE0354 AIRS ID Number: 123 /A0D9 / 003 !Leave bank.unless APCD has already assigned a permit 4 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 collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by contra eauinment) emissions) VOC Enclosed Combustor 100% 95% NOx CO HAPs Enclosed Combustor 100% 95% Other: From what year is the following reported actual annual emissions data? 2020 Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)s Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (aP 42, Emissions Emissions Emissions Emissions Basis Mfg,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 2.62E-01 lb/bbl State 14.34 0.72 17.21 0.86 NOx 0.068 Ib/MMBtu AP-42 N/A 0.20 N/A 0.24 CO 0.31 Ib/MMBtu AP-42 N/A 0.91 N/A 1.10 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 APEN5,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. , Section 9 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria ❑, Yes ❑ No 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 Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions8 Number Mfg.,etc.) (lbs/year) (lbs/Year) Benzene 71432 7.00E-03 lb/bbl _ State 766.50 38.33 Toluene 108883 N/A N/A N/A N/A N/A Ethylbenzene 100414 N/A N/A NIA N/A N/A Xylene 1330207 N/A N/A N/A N/A N/A n-Hexane 110543 2 20E-02 lb/bbl State 2.409.00 120.45 - 2,2,4-Trimethylpentane 540841 N/A N/A N/A N/A N/A 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. ® COLORADO Form APCD-207 Produced Water Storage Tank(s) APEN Revision 12/2019 5 .....r , Redlines per actual and requested throughput. (HDS 05/11/2020) Permit Number: 20WE0354 AIRS ID Number: 123 /A0D9 / 003 [Leave blank unress APCD has already assigned a permit 4 and AIRS lD] 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. Signature of Legally Authorized Person (not a vendor or consultant) Date Ben Turner Engineer 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 $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD 207 Produced Water Storage Tank(s) APEN Revision 12/2019 6 I O ti•Vt• Irrnronement "'"'"""" Hydrocarbon Liquid Loading APEN M*fIM� Form APCD-208 CDPHE 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 kicks 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: ZO WC03S- AIRS ID Number: iZ3 /A0 D`1l 669- Leave blank unless APCD has already assigned a permit r"and AIRS ID] Section 1 - Administrative Information Company Name': Edge Energy II, LLC Site Name: Akbary/ 1A Pad Site Location:• Site Location Lot 1 Sec. 1 T8N R67W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 1301 Washington Ave. Suite 300 Golden, CO 80401 Contact Person: Ben Turner Phone Number: (720) 599-3650 E-Mail Address2: BTumer@edgeenergy1.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. 428305 IND COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 1 I Permit Number: 20WE0355 AIRS ID Number: 123 / AOD9/ OO4 ;Leave plank unless A CD has already assigned a permit a and AIRS ID Section 2 - Requested Action Ej NEW permit OR newly-reported emission source ❑� Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- O 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- El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 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: Loadout of liquid hydrocarbons Company equipment Identification No. (optional): LOAD-1 For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: 3/4/2020 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes 0 No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? ❑ Yes 0 No Does this source load gasoline into transport vehicles? ❑ Yes 0 No Is this source located at an oil and gas exploration and production site? 0 Yes 0 No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? 0 Yes 0 No Does this source splash fill less than 6,750 bbl of condensate per year? ❑ Yes 0 No Does this source submerge fill less than 16,308 bbl of condensate per year? ❑ Yes 0 No COLORADO Form APCD-2O8 Hydrocarbon Liquid Loading APEN- Revision 12/2O19 2 I , Permit Number: 20WE0355 AIRS ID Number: 123 / A0D9/ 004 [Leave blank unless APCD has already assigned a permit w and ARS ID] Section 4 - Process Equipment Information Product Loaded: ID Condensate ❑ Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 87,60O bbl/year Actual Volume Loaded: 73,000 bbl/year This product is loaded from tanks at this facility into: Tank trucks (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of °F bulk liquid loading: Molecular weight of True Vapor Pressure: Psia @ 60 "F lb/lb•mol displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ftt 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) 40.69582/-104.8308 0 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. COMB-1 20 1,000 TBD TBD Indicate the direction of the stack outlet: ([heck one) ❑✓ Upward ❑ Downward O Upward with obstructing raincap ❑ Horizontal O Other(describe): Indicate the stack opening and size: (check me) 0 Circular Interior stack diameter(inches): 72 O Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): Ark_ AISN COLORADO Form APCD-2O8 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 3 I MOW Permit Number: 20WE0355 AIRS ID Number: 123 / AOD9/ 004 ;Leave blank unless A;PCD has already assigned a permit A 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. M./ Loading occurs using a vapor balance system: Requested Control Efficiency: 100% % Used for control of: vOCs and HAPs Rating: 93.96 MMBtu/hr Combustion Type: Enclosed Combustor Make/Model: MRW Technologies Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: 1,000 °F Waste Gas Heat Content: 2,255 Btu/scf Constant Pilot Light: 0 Yes 9 No Pilot Burner Rating: 0.025 MMBtu/hr Pollutants Controlled: ❑ Other: 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? ❑� Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined,values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SO NO. CO VOC Vapor Balance/Enclosed Combustor 100% 100%1 95% HAPs Vapor Balance/Enclosed Combustor 100% 100^:/95; Other: 0 Using State Emission Factors (Required for GP07) VOC Benzene n-Hexane r❑ 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? 2020 Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP 42, Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM N/A N/A N/A N/A N/A N/A N/A SO„ N/A N/A N/A N/A N/A N/A N/A NO. 0.068 IbIMMBtu AP-42 NIA 0.01 N/A 0.01 CO 0.31 lb/MMBtu AP-42 N/A 0.04 N/A 0.04 VOC 0.236 Iblbbl State 8.61 0.43 10.34 0.52 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 APEN5, 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. COEORAOO Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 12/2019 4 M..:H., Redlines per application and email. (HDS 05/20/2020) Permit Number: 20WE0355 AIRS ID Number: 123 / A0D9/ OO4 [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 0 No If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions6 Number Mfg.,etc.)etc.) (lbs/year) (lbs/year) Benzene 71432 4.16E-04 Ib/bbl State 30.37 1.52 Toluene 108883 N/A N/A N/A N/A N/A Ethylbenzene 100414 N/A N/A N/A N/A N/A Xylene 1330207 N/A N/A N/A N/A N/A n-Hexane 110543 3.61E-03 Ib/bbl State 263.53 13.18 2,2,4-Trimethylpentane 540841 N/A N/A N/A N/A N/A Other:N/A N/A N/A N/A N/A N/A N/A 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. • Signature of Legally Authorized Persom (not a vendor or consultant) Date Ben Turner Engineer Name (print) Title Check the appropriate box to request a copy of the: E 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 $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 12/2019 5 I ® a.rl��.a i Hello