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Home My WebLink About20201626.tiff : AN• COLORADO '� Departmentof Public4 .,!... C°'H E Health b Environment RECEIVED MAY 0 5 2020 WELD COUNTY Weld County - Clerk to the Board COMMISSIONERS 1150OSt PO Box 758 Greeley, CO 80632 April 22, 2020 Dear Sir or Madam: On April 23, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Mallard Exploration, LLC - Cinnamon Teal Fed 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator OF CO 4300 Cherry Creek Drive S.,Denver,CO 80246-1530 P 303.692-2000 www.colorado.gov/cdphe I 6�' j Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Direct/ IA Pu 61; G Re v Z eo(.,J cc:PL(TP) HL(L.K),pW(sh/ER/c i/cI ) 2020-1626 6N/A0oGCmS 6/1/2.O MrMaM Air Pollution Control Division r • �r' �''YNotice of a Proposed Project or Activity Warranting Public �CDPHE Comment Website Title: Mallard Exploration, LLC - Cinnamon Teal Fed Pad - Weld County Notice Period Begins: April 23, 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: Mallard Exploration, LLC Facility: Cinnamon Teal Fed Pad Exploration a Production Well Pad. SESW SEC 35 T8N R60W Weld County The proposed project or activity is as follows: The applicant proposes the construction of a condensate tank battery and hydrocarbon liquid loadout on individual construction permits, and a produced water tank battery on a general permit. Applicant is requesting synthetic minor permit limits for VOC and NOx in addition to permitted emissions >25tpy in the non-attainment area (for CO), and this project will therefore require a public comment period. 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 19WE0369 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.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Ben Fischbach Colorado Department of Public Health and Environment YT_a (COLORADO Department of Public 1 I UNlth b Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 (DepartCOLORADO 2 ment of Publfc kIeakh b Environmexrt CDPHE Condensate Storage Tanks)) APEN �`` Form APCD-205 CO ti/ 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.An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. 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 wilt 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 at:www.cotorado.gov/pacific/cdnhe/air-permits. 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: / / AIRS ID Number: Af$ f G'C1 f [Leave blank unless APCD has already assigned a Derr-it P and MRS ID] Section 1 -Administrative Information Company Name': Mallard Exploration, LLC Site Name: Cinnamon Teal Fed Pad Site Location Site Location: SESW 35 8N 60W County: Weld 40.61306,-104.061305 NAICS or SIC Code: 2..lilt' Mailing dress:(include Zip Code) 1400 16th St. Suite 300 Denver, CO 80202 Contact Person: Erin Mathews Phone Number: 720-543-7959 E-Mail Address2: emathews©mallardexptoration.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that°,i ill appear on all documents issued by the APCD.Any changes will require additional paperwork. J--r 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the addressvided. 3960 7 par COLOPADO Form APCD-205 Condensate StorageTank(s)APEN Revision 7'2018 1 Permit Number: TBD AIRS iD Number: I / [Loasv;e blank€mess APCD has already assigned a permit a and AIRS€D] Section 2- Requested Action ❑i NEW permit OR newly-reported emission source Request coverage under traditional construction permit B y {lg a G14e"4' agA.Request coverage under a General Permit e-4- 4 Ay 1 GP01 O 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 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership' 0 Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADomoival.Pourr Acnoas- ❑ 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. Section 3 General Information General description of equipment and purpose: Condensate Storage Tanks Company equipment Identification No. (optional): Condensate Tanks 1-4 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 08/23/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration&Production(E&P)site O Midstream or Downstream(non E&P)site Wilt this equipment be operated in any NAAQS nonattainment area? (] Yes ❑ No Are Flash Emissions anticipated from these storage tanks? 0 Yes 0 No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? ❑ Yes Q 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 No 805 series rules?If so, submit Form APCD-105. (3 Yes Are you requesting≥6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual ❑ Yes ❑� No emissions≥6 ton/yr(per storage tank)? I cotof ADo Form APCD-205 Condensate Storage Tankis)APEN - Revision 7:2018 2 All Permit Number: TBD AIRS ID Number: [Leave blank a ntecs APCD has att'eady assigned a permit k and AIRS ID} Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) -BF I Condensate Throughput: 120,149 121,340 144,179 145,608 4/16/20 Per attached email From what year is the actual annual amount? 2018 Average API gravity of sales oil: 60- 45 degrees RVP of sates oil: Tank design: ®Fixed roof O internal floating roof O External floating roof Storage #t 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 (W) Storage Tank(month/year) (month/year) 4 x 500 bbl Condensate Tanks 5gO- 2,000 Feb-2016 Aug/2018 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 -46646 Cinnamon Teal Fed 35-15HC 05 -123 -46650 Cinnamon Teal Fed 35-16HN ❑ 0 0 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. 6 The CEP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report alt wells that are serviced by the equipment reported on this APEN form, Section 5 -Stack Information Geographical Coordinates (Lotftndo/Longftude or UTM) 40.61306,-104.061305 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) UNK UNK UNK UNK UNK Indicate the direction of the stack outlet:(check one) 0 Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size:(check one) 0 Circular Interior stack diameter(inches): 48" ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): AT" coioq.re Form APCD-2O5 Condensate Storage Tank(s)APEN - Revision 712018 3 I m Permit Number: TBD AIRS ID Number: / 1 [Leave Marta unless APCD has already assigned a permit.`and ARRS IDI 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: VOC, HAP Rating: 11.7 MMBtu/hr Type: Combustor Make/Model:Cimmaron 48" HVECD a Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 99 % -BF 2,373 4/16/20 Minimum Temperature: NA Waste Gas Heat Content: NABtu/scf Per attached Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.017 MMBtu/hr email Description of the closed loop system: ❑ 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)? Vanes psig Describe the separation process between the well and the storage tanks: 3-Phase HLP Separator and 3-Phase Heater Treater Form APCD-205 Condensate Storage Tank(si APEN - Revision 7.'2018 4 I Permit Number: TBD AIRS ID Number: / / [Leave blank unless APCD has already assIgned a perm%and MRS 10] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (x reduction in emission) VOC EGO 95 NOx CO HAPs EGO 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Emission Factors Actual Annual Emissions Requested Annual Permit Pollutant Emission Liadt(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled r Units (AP-42, Emissions Emissions8 Emissions Emissions BasMk etc) (Tons/year) (Tons/year) (Tons/year) (Tons/Year) voc 4265.07 Ibs/bbl SSEF 258.5 307.6 12.9 18'3 369.2 18.5 NOx 0.0037-0'068 IbIMMBtu AP-42 0.6 4 0.6 0.7 0.7 -BF CO 0.0094 0.31 Ib/MMBtu AP-42 4-§2.5 10.9 2.5 3.1 3.1 4/16/20 Per attached email Non-Criteria Reportable Pollutant Emissions Inventory chemical Emission Factor' Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc) (Pounds/year) (Pounds/year) Benzene 71432 0.007 ibs/BBL SSEF 1062.97 804 53.15 48 Toluene 108883 0.005 lbs/BBL SSEF 636 38 Ethylbenzene 100414 6.9E-4 lbs/BBL SSEF 83 5 Xylene 1330207 0.001 lbs/BBL SSEF 157 9 n-Hexane 110543 0.047 0.043 lbs/BBL SSEF 6785.56 5,162 330.28 306 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. 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 emissions fees wilt be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COQ Form APCD-205 Condensate Storage Tanklsi APEN -Revision 712018 5 1 A 4 " .. Permit Number: TBD AIRS ID Number: [leave blank nniess APCD has already assigned a permit a and AIRS ID] Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GM or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. John Tonello Digitally signed by John Tonello Date:2019.02.21 16:30:03-07'00' 02/21/2019 Signature of Legally Authorized Person(not a vendor or consultant) Date John Tonello CEO Name(print) Title Check the appropriate box to request a copy of the: i❑Draft permit poor to issuance O 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$312.50, if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.coloredo.¢ov/cdphe/aocd CO ORSCO FormAPCD-205 Condensate Storage Tank{s}ADEN . Revision 7i7 t$ 6 i 4/24/2019 State.co.us Executive Branch Mail-Cinnamon Teal Fed Pad-Condensate Tanks i.icsA f ,.o.� STATE OF COLORADO Caton CDPHE, Byron<byron.caton@state.co.us> Cinnamon Teal Fed Pad - Condensate Tanks 2 messages Caton -CDPHE,Byron<byron.caton@state.co.us> Wed,Apr 24,2019 at 6:32 AM To:ematthews@mallardexploration.com Erin, i received your message yesterday requesting the condensate tank permit to be an individual construction permit. Thanks for the prompt reply. The submitted APEN for the condensate tanks was marked as requesting a GPOI for the condensate tanks. Please confirm request for an individual permit by return e-mail and i will red-line the submitted APEN accordingly, Best Regards Byron Caton Engineering/Physical Sciences Technician Stationary Sources Program CDPHE COLORADO CO Air Pollution Control Division Department of Public Health b Environment P 303.692.3220 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246-1530 byron.caton@state.co.us l www.colorado.gov/cdphe/aped As of January 1,2014,the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs.Additional fees may apply if an APEN is submitted without the necessary information.An application with missing information may result in longer processing times.Please note that alt APEN submissions should be completed using forms currently supplied by the Division(See Reg. 3,Part A,Section lI.A).Current APEN forms can be found at:https://www.colorado.govfcdphe/APENforms Erin Mathews<emathews@mallardexploration.com> Wed,Apr 24,2019 at 9:45 AM To:'Caton-CDPHE, Byron"<byron.caton@state.co.us> Cc: Kelly Kinsman<KKinsman@h2eincorporated.com> Byron, Mallard is requesting an individual permit, please red-line the APEN accordingly. Thanks, Erin https://mail.google.corn/mail/u/Vik=06fef96471&view=pt&search=all&permthid=thread-a%3Ar7954502178210369213&simpl=msg-a%3Ar5492301103... 1/2 CDPHE Hydrocarbon Liquid Loading APEN , 'i` Form APCD-208 CO --0` Air Pollutant Emission Notice(APEN)and Y Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities,including APEN updates.An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged on additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. 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 at:www.colorado.$ovlcdpihe/apcd. 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: /CI 0.37 AIRS ID Number: (2 3 /A 3 A/ 662, [Leave blank unless APCD has already,assigned a i sa rnrt a and MRS'=,D[ Section 1 -Administrative Information Company Name': Mallard Exploration, LLC Site Name: Cinnamon Teal Fed Pad Site Location Site Location: SESW 35 8N 60W County: Weld 40.61306,-104.061305 NAICS or SIC Code: 2.1's.4 Mailing Address: (Include Zip Code) 1400 16th St. Suite 300 Denver, Co 80202 Contact Person: Erin Mathews Phone Number: 72O-543-7959 E-Mail Address2: ematnews@mallaraexpioralion.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. ii 7S- Form APCD-.208 Hydrocarbon Liquid Loading APEN • Revision 7 2018 1 ; ; Permit Number: TBD AIRS ID Number: [Leav€blank unless APCD has already assigned a permit`and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source O Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage fs requested,the General Permit registration fee of S312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: Please Permit with Individual permit for potential load out. 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: Condensate truck load out Company equipment Identification No. (optional): NA For existing sources,operation began on: NA For new or reconstructed sources,the projected start-up date is: 8/23/2018 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes Q No emissions? Does this source load gasoline into transport vehicles? O Yes 0 No is this source located at an oil and gas exploration and production site? 0 Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual Yes O No average? Does this source splash fill less than 6750 bbl of condensate per year? [3 Yes O No Does this source submerge fill less than 16308 bbl of condensate per year? O Yes ® No COLORADO Form APCD.208 Hydrocarbon Liquid Loading APEN Revision 712018 2 I Amy = Permit Number: TBD AIRS ID Number: l l [Leave blank unless APCD has already assigned a permit u and AIRS tDI Section 4 - Process Equipment information Product Loaded: 0 Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 145,608 bbt/year Actual Volume Loaded: 121,340 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: Average temperature of Saturation Factor: 'F bulk liquid loading: True Vapor Pressure: Psia @ 60°F Molecular weight of lb/lb-mot displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: NA bbt/year Actual Volume Loaded: NA bbl/year Product Density: NA tb/ft3 Load Line Volume: NA ft3/truckload Vapor Recovery Line Volume: NA ft3/truckload 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. COi,flk#pfJ 3 � Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 7 2018 ( Permit Number: TBD AIRS ID Number: leave hiank unle:ss ARCD has a#ready assigned a permit#and AIRS.101 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.61306,-104.061305 NA Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) ❑Circular Interior stack diameter(inches): ❑Other(describe): Section 6 - Control Device Information Ei Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: Rating: MMBtu/hr Type: Make/Model: Combustion ❑ Device: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: % Minimum Temperature: F Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr Pollutants Controlled: Other: Description: Requested Control Efficiency: Form APCD-208 Hydrocarbon Liquid t.oadins;APEN Revision 7.'2018 ! ,� Permit Number: TBD AIRS ID Number: / / [Leave blank unless APCR has alleadyf assigned a permit a and AIRS ID] Section 7- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Methods) Control Efficiency (%reduction in emissions) PM SOx NO: CO VOC HAPs Other: 0 Using State Emission Factors(Required for GP07) V0C Benzene n-Hexane Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑Crude 0.104 Lbs/B8L 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions' Emissions Emissions Ai etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NOx CO VOC 0.236 Ib/BBL State Factor 14.3 17.2 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service( ) Units (AA-J2, Emissions Emissions' Number Mfg.,etc.) (Pounds/y*ar) r (pounds/year) Benzene 71432 0.00041 lb/bbl State Factor 60-50 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.0036 Ib/BBL State Factor 524- 437 2,2,4- 540841 Trimethylpentane Other: 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. �y C4tC7Ra0O Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 7/2018 Permit Number: TBD AIRS ID Number: / [Leave blank unless APCD has already assigned a permit w and AIRS'DI Section 8 -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 wilt be operated in full compliance with each condition of General Permit GP07. John Tonello Digitally signed by John Tonello Date:2019.02.21 16:29:06-07'00' 2/21/2019 Signature of Legally Authorized Person(not a vendor or consultant) Date John Tonello CEO Name(print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance O 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 Regulati m 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 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aped cotapm_ Form APCD 208 Hydrocarbon Liquid l Le ailing APEN Revision 712018 6 1 A .M.".M. COLORADO �Y Air Pollution Control Division COPHE Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0369 Issuance: 1 Date issued: Issued to: Mallard Exploration, LLC Facility Name: Cinnamon Teal Fed Pad Plant AIRS ID: 123/A03A Physical Location: SESW SEC 35 T8N R60W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Condensate Four (4) 500 barrel fixed roof storage 001 Enclosed Combustor Tanks 1-4 vessels used to store condensate 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 submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 * , . COLORADO a4iftikrli Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit atone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type Condensate 001 --- --- 18.5 3.1 Point Tanks 1-4 Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Page 2 of 10 * . - COLORADO Air Pollution Control Division CDPHE Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Condensate 001 Enclosed Combustor VOC and HAP Tanks 1-4 PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point Condensate 001 Condensate throughput 145,608 barrels Tanks 1-4 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 11. 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) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. 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: Page 3 of 10 aCOLORADO 4 Air Pollution Control Division cD'1t Department of Pubhc Health S Environment: Dedicated to protecting and improving the health and environment of the people of Colorado • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 15. The 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. 16. 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. 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 Et MAINTENANCE REQUIREMENTS 18. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 a,„ 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 TESTING AND SAMPLING Initial Testing Requirements 19. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23) 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. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II. C.) nnually 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,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. Page 5 of 10 -.1. COLORADO Air Pollution Control Division COPHt Department of Public Health S Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the ,provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining-final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 26. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 27. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. Page 6 of 10 ar•.<"- COLORADO 414.,-01-6.+cli Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Mallard Exploration, LLC Synthetic Minor Facility Page 7 of 10 COLORADO Air Pollution Control Division COPHE Department of Public Health&£nvtronment 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 965 48 Toluene 108883 763 38 001 Ethylbenzene 100414 100 5 Xylenes 1330207 188 9 n-Hexane 110543 6,195 310 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: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0093 0.0093 AP-42 Chapter CO 0.0424 0.0424 13.5 VOC 5.071 2.54 * 10-1 71432 Benzene 6.63 * 10-3 3.31 * 10-4 EEtP Tanks 108883 Toluene 5.24 * 10.3 2.62 * 10-4 100414 Ethylbenzene 6.85 * 10.4 3.42 * 10-5 Page 8 of 10 is - - 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 1330207 Xylene 1.29 * 10-3 6.45 * 10-5 110543 n-Hexane 4.25 * 10-2 2.13 * 10"3 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This 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, NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH Not Applicable Page 9 of 10 x,a.1- COLORADO Air Pollution Control Division EDPHE Department of Public Wealth&Envirorartent Dedicated to protecting and improving the health and environment of the people of Colorado 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A —Subpart UUUU NSPS Part 60, Appendixes Appendix A Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT4z 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 z° I- COLORADO 11 Air Pollution Control Division r. CDPHE Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0370 Issuance: 1 Date issued: Issued to: Mallard Exploration, LLC Facility Name: Cinnamon Teal Fed Pad Plant AIRS ID: 123/A03A Physical Location: SESW SEC 35 T8N R60W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description Truck Truck loadout of condensate by Loadout 002 submerged fill None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution;Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 9 .-,. COLORADO � ,Air Pollution Control Division ,. CbPHe Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 NOX VOC CO Type Truck Loadout 042 - 17.2 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits'for criteria pollutants OR for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Page 2 of 9 aCOLORADO 44.'4=° Air Pollution Control Division CDPH; Department of Public Health Fr Enuironment Dedicated to protecting and improving the health and environment of the people of Colorado Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC 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 ID AIRS Process Parameter Annual Limit Point Truck 002 Condensate Loaded 145,608 barrels Loadout The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelvemonths' 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. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.) 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.) • 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. Page 3 of 9 .y. .t. COLORADO a .4.0_40 Air Pollution Control Division CDPHE Department of Publac Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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., r. • 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. 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. Page 4 of 9 - -` . COLORADO Air Pollution Control Division CD Department of Punic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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 ofoil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 18. This source is not required to follow a Division-approved operating and maintenance plan. 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. 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: Page 5 of 9 a •r,�~�;- COLORADO Air Pollution Control Division ` .E. Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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 in any enforceable limitation that was established after August 7, 1980,on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. Page 6 of 9 .M.�� . : COLORADO Air Pollution Control Division CDPH€ Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Mallard Exploration, LLC Synthetic Minor Facility Page 7 of 9 a •:r COLORADO Air Pollution Control Division CDPHE Department of Pubiac 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 Pollutant CAS# Uncontrolled Emissions Point (Ib/yr) Benzene 71432 60 002 n-Hexane 110543 524 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: Uncontrolled Emission Pollutant CAS # Factors Source lb/bbl VOC 0.236 Benzene 71432 4.10 * 10-4 CDPHE n-Hexane 110543 3.60 * 10"3 Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Page 8 of 9 •r.•~<r- COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A- Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package #: 396075 Received Date: 2/27/2019 Review Start Date: 5/8/2019 Section 01 - Facility Information Company Name: Mallard Exploration, LLC Quadrant Section Township Range County AIRS ID: 123 SESW SN E.G Plant AIRS ID: A03A Facility Name: Cinnamon Teal Fed Pad Physical Address/Location: SESW quadrant of Section 35, Township 8N, Range 60W 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? Carbon Monoxide (CO) n Particulate Matter (PM) j Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks Permit Initial Condensate Tank _:andensate Tanks 1-4 Yes 19WE0369 Issuance See 19WE0370.O- PA (Pages Permit Initial hidden in this Liquid Loading Truck Loadout Ye- 19WE0370 Issuance workbook) Section 03 - Description of Project The applicant proposes the construction of a condensate tank battery and hydrocarbon liquid loadout on individual construction permits, and a produced water tank battery on a general permit. Applicant is requesting synthetic minor permit limits for VOC and NOx, and this project will therefore require a public comment period. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a :rue 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) Title V Operating Permits (OP) ■ Non-Attainment New Source Review (NANSR) I Is this stationary source a major source? No If yes, explain what programs and which pollutants hen 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) l J Non-Attainment New Source Review (NANSR) Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Four (4) 500 bbl Condensate Storage Tanks Description: Emission Control Device ECD Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 121,340 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 120,149 Barrels (bbl) per year Requested Permit Limit Throughput = 145,608 Barrels (bbl) per year Requested Monthly Throughput = 1.2367 Barrels (bbl) per mont1 Potential to Emit (PTE) Condensate Throughput = 145,608 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2372.59 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 57.5872 scf/bbl Actual heat content of waste gas routed to combustion device = 16,416 MMBTU per year Requested heat content of waste gas routed to combustion device = 19,895 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 19,895 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 5.071 2.54E-01 't ter::.:: Nc i;:,.1.iii.ci�.ie.le. iii _1. Benzene 6.63E-03 3.31E-04 Ste Specific ES, (includes flash) Toluene 5.24E-03 2.62E-04 `; xc Specif;c E.F. (*hides flash,': Ethylbenzene 6.85E-04 3.42E-05 Site Specific E.F. (includes `1as Xylene 1.29E-03 6.45E-05 Site Specific E.F. (includes fla( n-Hexane 4.25E-02 2.13E-03 Ste Specific E.F. (includes flan:.; 224 TMP 0.00E+00 0.00E+00 54te specific ES. (ir:ciudesflasE' Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 0.0000 PM2.5 0.0000 NOx 0.0680 0.0093 CO 0.3100 0.0424 AP-42 Ch.:), . . ir,`;:,.;sip : ,.. , - . 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) VOC 369.2 307.6 18.3 369.2 18.5 3135 PM10 0.0 0.0 0.0 0.0 0.0 0 PM2.5 0.0 0.0 0.0 0.0 0.0 _ 0 NOx 0.7 0.6 0.6 0.7 0.7 115 CO 3.1 2.5 2.5 3.1 3.1 524 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 965 804 42 965 48 Toluene 763 636 38 763 38 Ethylbenzene 100 83 5 100 5 Xylene 188 157 9 188 9 n-Hexane 6195 5162 306 6195 310 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Part D, Section I.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Part D, Section I.G,C Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Part D, Section II.B-C Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVI1.C.2 Part D, Section II.C.2. Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2 of 6 K:\PA\2019\19WE0369.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes This tank battery stores liquids from two new wells. The operator collected pressurized liquid samples from one wellhead separator per well. Operator originally combined these samples by averaging the compositions and modeling through E&P Tanks. However, this method will not properly account for liquid properties, and the operator agreed to instead base emission factors off of the more conservative of the two pressurized liquid samples. The pressurized liquid sample used in emission factor development was collected on 9/18/2018 and analyzed on 9/26/2018 by zedi US Inc. The sample was collected at a pressure of 47 psig and 100F. A sales oil sample was not submitted with this application. Operator instead used API gravity of oil (API = 45, which was supported by COGIS production data) and RVP estimation equation R'./P 0.179*API - 1.699 to estimate an RVP of ^'6.356. Used Promax to verify that E&P Tanks model is conservative. wears zitr. L-.-4.4-n:\wps --et Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point 4$ Process 4$ SCC Code Pollutant Factor Control % Units 001 01 As. u 3 's� s+.* t T €r, C PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.22 0 lb/1,000 gallons condensate throughput VOC 120.7 95 Ib/1,000 gallons condensate throughput CO 1.01 0 lb/1,000 gallons condensate throughput Benzene 0.16 95 lb/1,000 gallons condensate throughput Toluene 0.12 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.02 95 lb/1,000 gallons condensate throughput Xylene 0.03 95 lb/1,000 gallons condensate throughput n-Hexane 1.01 9.5 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 6 K:\PA\2019\19WE0369.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.0.1.a)? • /, 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. 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 11.0.3)? You have indicated that source is in the Non-Attainment 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 Source Req 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? M1c. Go to next 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? Yes Source Req Source requires a permit Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue - 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? Yes Continue - 3. Is this storage tank located upstream of a natural gas processing plant? Yes Source is st Storage tank is subject to Regulation 7, Section X!I.C-F Section XII.C.1 —General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 —Emission Estimation Procedures Section XII.D — Emissions Control Requirements Section XII.E — Monitoring Section XII.F— Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? • Continue - 2. Is this storage tank located at a natural gas processing plant? Storage Tar 3. Does this storage tank exhibit "Flash" (e.g. storing non-stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section Xisi: Section XII.G.2 - Emissions Control Requirements Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? No Continue - 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility?, natural gas compressor station3 or natural gas processing plant? Yes Go to the n 3. Is this condensate storage tank a fixed roof storage tank? Yes Go to the n 4. Are uncontrolled actual emissions`of this storage tank equal to or greater than 6 tons per year VOC? es Source is st Storage tank is subject to Regulation 7, Section XV!I, 8, C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only"stabilized" liquids? No Source is st Storage tank is subject to Regulation 7. Section XVII.C.2 Section XVIl.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) ["472 BBLs]? Yes Go to the n 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tar a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ("10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transferi as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"°as defined in 60.111b? 6. Does the storage vessel meet any one of 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))?; or b. The design capacity is greater than or equal to 151 m31-950 BBL] and stores a liquid with a maximum true vapor pressure° less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 (`472 88L] but less than 151 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressure° less than 15.0 kPa(60.11ob(b))? Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60,Subpart 0000,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Ye' Continue - 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? N; Storage Tar 3. Are potential VOC emissions? from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. 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 HH? Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2 even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: Continue - a. A facility that processes, upgrades or stores hydrocarbon liquids? (63.760(a)(2)): OR b. A facility 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 user3 (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? Storage Tar 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Link is net subject to MACT HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RAG Review RACT 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 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 implemerting 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 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Mallard Exploration. LLC County AIRS ID 123 History File Edit Date 3/3/2020 Plant AIRS ID A03A Ozone Status Non-Attainment Facility Name Cinnamon Teal Fed Pad EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Descript.on PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID 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 0.0 001 19WE0369 Four (4) 500 bbl Condensate Tanks 0 7 369.2 3 1 4 1 0.7 18.5 3.1 0.2 002 19WE0370 Truck Loadout 17.2 0 3 17.2 0.3 003 GP08 Two (2) 500 bbl Produced Water Tanks 9.5 1 .1 5.9 0.1 004 GP02 Caterpillar 3306TA, 205hp, 4SRB 79.2 0.4 36.6 0.3 2.4 0.4 4.8 0.3 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 FACILITY TOTAL 0.0 0.0 0.0 0.0 79.9 396.3 0.0 39.7 5.7 0.0 0.0 0.0 0.0 3.1 42.0 0.C 7.9 0.8 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: True Minor B, T, X, HCHO & Total HH: True Minor 7777: True Minor Permitted Facility Total 0.0 0.0 0.0 0.0 79.9 396.3 0.0 39.7 5.7 0.0 0.0 0.0 0.0 3. 1 42.0 0.0 7.9 0.8 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 3. 1 42.0 0.0 7.9 Pubcom required based on requesting Synthetic Minor permit limits. Total VOC Facility Emissions (point and fugitive) 42.0 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 42.0 Project emissions less than 25/50 tpy Note 1 Note 2 Page 5 of 6 Printed 4/21/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Mallard Exploration, LLC County AIRS ID 123 Plant AIRS ID A03A Facility Name Cinnamon Teal Fed Pad Emissions - uncontrolled (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0369 Four (4' 500 bbl Condensate Tanks 965 763 100 13 6195 4. 1 002 19WE0370 Truck Loadout 60 524 0.3 003 GP08 Two (2) 500 bbl Produced Water Tanks 510 1602 1 . 1 004 GP02 Caterpillar 3306TA, 205hp, 4SRB 357 49 .l6-1 23 54 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.2 0.0 0.0 0.8 0.4 0.1 0.1 4.2 0.0 0.0 0.0 0.0 5.7 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 , 0 0 0.0 001 19WE0369 Four (4) 500 bbl Condensate Tanks 48 38 5 ri 310 0.2 002 19WE0370 Truck Loadout HT; 524 0.3 003 GP08 Two (2) 500 bbl Produced Water Tanks 26 80 0.1 004 GP02 Caterpillar 3306TA, 205hp, 4SRB 357 0.3 0.0 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 0.5 0.0 0.0 0.0 0.0 0.8 6 19WE0369.CP1 4/21/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package #t: 396075 Received Date: 2/27/2019 Review Start Date: 5/8/2019 Section 01 - Facility Information Company Name: Mallard Exploration, LLC Quadrant Section Township Range County AIRS ID: 123 SE '.:+ 35 N 60 Plant AIRS ID: A03A Facility Name: Cinnamon Teal Fed Pad Physical Address/Location: SESW quadrant of Section 35, Township 8N, Range 60W 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? f] Carbon Monoxide (CO) ❑ Particulate Matter (PM) ./ Ozone (NOx &VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point S# Emissions Source Type Equipment Name Permit #f Issuance # Action Control? Required? Remarks See 19WE0369.CP; PA (Pages Permit Initial hidden n this Condensate lank Condensate Tanks 1-4 19WE0369 Issuance workbook) Permit Initiai Liquid Loading Truck Loadout 19WE0370 Issuance Section 03 - Description of Project The applicant proposes the construction of a condensate tank battery and hydrocarbon liquid loadout on individual construction permits, and a produced water tank battery on a general permit. Applicant is requesting synthetic minor permit limits for VOC and NOx, and this project will therefore require a public comment period. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) I I H _ I---) Non-Attainment New Source Review (NANSR) Is this stationary source a major source? No If yes, explain what programs and which pollutants hen SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) I Title V Operating Permits (OP) HI I I I I Non-Attainment New Source Review (NANSR) Hydrocarbon Loadout Emissions Inventory 002 liquid Loading 002 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Truck loadout of condensate by submerged fill Description: Emission Control Device None. Description: Is this loadout controlled? Requested Overall VOC & HAP Control Efficiency %: 0 00 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 121,340 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 0 Barrels (bbl) per year Requested Permit Limit Throughput = 145,608 Barrels (bbl) per year Requested Monthly Throughput = 12367 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 145,608 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) ... ... t . ... , Y... . ..,. .. .S ...2•. 1 .. /..,.' ... .-...-It . . < :Y . .>,•:� f 4- - MMBTU per year .it •:•,-• ;: ,:- ;;, . MMBTU per year I pr. is ;t s r L u�i' v , s htti.rra MMBTU per year Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? - Does the hydrocarbon liquid loading operation utilize submerged fill? The state default emissions factors may be used to estimate emissions. • factor Meaning i Value 1 %/ 7P i } I t' V d p</r I C I e � �2{-,�< / .`N 7 �. _ .. M �rf 14St C{�{tjt ��J )�,Zr� ��T..a tt t,- r y:)",,,.127,4111".)� .w4a.n .H_.wi.m. ..aWaart __-. .-. N Nn _...—___ Wav- �M.—v. ♦.r.._. ,., - .. .--... _..... /�.,' 6 l••_•1 iJ.r_. •—_•—...—...«-.��r ,�...-+t` :O_..�7 . —w.......... ......a .. .-......__?.._._—... .___.�. _ .. $. y�Cot ir, of e; t Mass ract�en Emission ten_f3c ,o,• . llnit5 E Source __.. • £:enzent; 1 ~fir Toktene • •1a1 r £thytberrzene I •r, Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 2.36E-01 2.36E-01 Condensate Loadout State E.F. Benzene 4.10E-04 4.10E-04 Condensate Loadout State ES. Toluene _ 0.00E+00 0.00E+00 4 Ethylbenzene 0.00E+00 0.00E+00 Xylene 0.00E+00 0.00E+00 n-Hexane 3.60E-03 3.60E-03 Condensate Loadout State LF. 224 TMP 0.00E+00 0.00E+00 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.00E+00 _ PM2.5 0.00E+00 SOx 0.00E+00 NOx - - 0.00E+00 CO 0.00E+00 2 0f K:\PA\2019\19WE0370.CP1 Hydrocarbon Loadout Emissions Inventory 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 0.00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 0.00 0.00 0.00 0.00 0.00 0 VOC 17.18 14.32 14.32 17.18 17.18 2919 CO 0.00 0.00 0.00 0.00 0.00 0 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 60 50 50 60 60 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n-Hexane 524 437 437 524 524 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must be operated with submerged fill to satisfy RACT. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements You have indicated above the source is not controlled. The following question does not require an answer. zr2,,,c,--",.,- ..d�ir��;js rissZs�n;z ,« �x Asa ../„r:/ii•r. . Y"!, Y X : ft .u4 •£ r;"- u`f- '�,-Y v..G., / '/. L •C / , ..f' rG.; ..✓,`.%'C f-'-r- ,` ,.F• ✓ :! .'!.'/r.4 ya 's../ '.:s/..,,•• 4,1:-..; ' , _ ; , ;;r�,•ss:s ^�t. 'r,;£s s %ii ';rays i c ,,./ ;a' .. mss, .;„ssr;. ,,,,, r 's„ s/,:..�,/.., ''4v„ , „, ,r;s?. 1%, r a a /.,a a, „r cr<, src r t s, z a,x.,7Ka ✓ru. 's• r St, r :„6' ss s?,rcri rat, Fs y' ui_c,�er / s,; i. ,•y •- � . � fa' .;: ;� .. . r , ,i s .: � ^ss s,..,:sY^rr�.s",s..s.,•x^• s w •" _ '•/��;,c,�., ,� .ss��',•,c,�,1 ,.,,asa ; :;iii'%C„ , .«.; .• -a: :y. •! z, .,.:< �z:z x• ,c .. ..c., x _t•, ., ' ' �� r�s7s%�,.� - � , ,r, .z opt :�,� sr ,sq�''r/• .� ,r�� 's's' ` r r '` ;, ,J�,' :�s .�.�s' .r�s". i/ r .•a Hs/„lax r .r ,• ,:„..,t s"r ,r e2-1- .'r,:4fa t-ami?r / ais• h/,xss/; y //rx r/ s sir. . ! C , fs/s,/ ,.y r�,s'F, z., c.• r s 'ti ryx„y/ 'r i., / / , yy F. ,,. i '% �i � � � �' x,/'4;0 � , .��'' •�,n=: :'a, ,.�' ////,r.,,., / / % ' :� .•iQSMy r,` ,�: f' n 'rth% . �. ' �t' f:. ''. Z � ' / ��' ' S i i r i! i.'�„S""%r// r./�,./��i'i�'/• ,i,','.,'G/'.%%S•.. Section 08 - Technical Analysis Notes As this facility was constructed and not modified before May 1, 2020, the operator has one year to comply with Regulation 7, Part D, II.C.5 control requirements. I have notified the operator of this requirement. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrclled Emissions AIRS Point tt Process # SCC Code Pollutant Factor Control % Units 002 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 c. lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 5.6 0 lb/1,000 gallons transferred CO 0.00 G lb/1,000 gallons transferred Benzene 0.01 0 lb/1,000 gallons transferred Toluene 0.00 0 lb/1,000 gallons transferred Ethyl benzene 0.00 0 lb/1,000 gallons transferred Xylene 0.00 0 lb/1,000 gallons transferred n-Hexane 0.09 0 lb/1,000 gallons transferred 224 TMP 0.00 0 lb/1,000 gallons transferred 3 of 6 K:\PA\2019\19WE0370.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B -APEN and Permit Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 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.I)? 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 II.D.3)? You have indicated that source is in the Non-Attainment 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 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? Yes Go to the n 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 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No ` Go to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No ' Go to next 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 loadou Source requires a permit 7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? No The loadou The loadout must be operated with submerged fill to satisfy RACT. 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. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Mallard Exploration, LLC County AIRS ID 123 History File Edit Date 3/3/2020 Plant AIRS ID AO3A Ozone Status Non-Attainment Facility Name Cinnamon Teal Fed 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 VOC HAPs VOC HAPs ID 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 0.0 001 19WE0369 Four (4) 500 bbl Condensate Tanks 0 7 369 2 3 1 4 1 0.7 18.5 3.1 0.2, 002 19WE0370 Truck Loadout 17 2 0 3 17.2 0.3 003 GP08 Two (2) 500 bbl Produced Water Tanks 9.5 1 .1 5.9 0.1 004 GP02 Caterpillar 3306TA, 205hp• 4SRB 79.2 0.4 36.6 0.3 2.4 0.4 4.8 0.3 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 FACILITY TOTAL 0.0 0.0 0.0 0.0 79.9 396.3 0.0 39.7 5.7 0.0 0.0 0.0 0.0 3.1 42.0 0.C 7.9 0.8 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: True Minor 8, T, X, HCHO & Total HH: True Minor 7777: True Minor Permitted Facility Total 0.0 0.0 0.0 0.0 79.9 396.3 0.0 39.7 5.7 0.0 0.0 0.0 0.0 3. 1 42.0 0.0 7 9 0.8 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 3. 1 42.0 0.0 7.9 Pubcom required based on requesting Synthetic Minor permit limits. Total VOC Facility Emissions (point and fugitive) 42.0 Facility :s eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 42.0 Project emissions less than 25/50 tpy Note 1 Note 2 Page 5 of 6 Printed 4/21/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Mallard Exploration, LLC County AIRS ID 123 Plant AIRS ID A03A Facility Name Cinnamon Teal Fed Pad Emissions - uncontrolled (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) I Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0369 Four (4) 500 bbl Condensate Tanks 965 763 - 1 6195 4.1 002 19WE0370 Truck Loadout -', 524 0.3 003 GP08 Two (2) 500 bbl Produced Water Tanks 510 1602 1 .1 004 GP02 Caterpillar 3306TA, 205hp, 4SRB 357 . _ 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL 'tpy) 0.2 0.0 0.0 0.8 0.4 0.1 0.1 4.2 0.0 0.0 0.0 0.0 5.7 `Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) I Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0369 Four (4; 500 bbl Condensate Tanks 48 38 310 0.2 002 19WE0370 Truck Loadout 524 0.3 003 GP08 Two (2' 500 bbl Produced Water Tanks 26 80 0.1 004 GP02 Caterpillar 3306TA, 205hp, 4SRB 357 ' 0.3 0.0 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 0.5 0.0 0.0 0.0 0.0 0.8 6 19WE0370.CP1 4/21/2020 Hello