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Home My WebLink About20202354 x:"- COLORADO tiill Department of Public al Heth b Environment RECEIVED Weld County - Clerk to the Board 1150 0 St Box PO Box 758 JUL 2 3 2020 Greeley, CO 80632 WELD COUNTY COMMISSIONERS July 20, 2020 Dear Sir or Madam: On July 21, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Enerplus Resources (USA) Corporation - Irish Well 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 &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator c,, o 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I { 1.-A Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director ,,,. #!, Pi lb,I :c Rev;e(,J Cc:PL.CrP),HL(DS),Pi./(1MIEa/cN/c c), 2020-2354 Og/05/20 OG(3-0 07/29/20 EN Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Enerplus Resources (USA) Corporation - Irish Well Pad - Weld County Notice Period Begins: July 21, 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: Enerplus Resources (USA) Corporation Facility: Irish Well Pad Well Production Facility SWSE of Section 26, Township 8N, Range 67W Weld County The proposed project or activity is as follows: Enerplus Resources (USA) Corporation is requesting to modify the crude oil storage vessels, hydrocarbon liquid loadout and separator venting sources at an existing well production facility located in the ozone non-attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 18WE1126, 18WE1127 It 18WE1129 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: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public 1 , cu>ue Health b Envtromunent , COLORADO Wrirf Mr Pollution Control Division r c nrn nt u'PubL_.h teak h b r,r 1me"1 Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 8WE 1126 Issuance: 2 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Irish Well Pad Plant AIRS ID: 123/9FD9 Physical Location: SWSE SEC 26 T8N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Six (6) 400 barrel fixed roof crude oil Enclosed TANKS 005 storage vessels connected via liquid Combustor(s) manifold. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. 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 NOX VOC CO Type Page 1 of 10 .�.-. ( COLORADO Air Pollution Control Division GDPH - i Le &Itrtent:5'Put Nealth6 rIvirt.rtrne.t1 Dedicated to protecting and improving the health and environment of the people of Colorado TANKS 005 --- 0.5 11.1 2.0 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, 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. 3. The owner or operator must use the emission calculation methods and emission factors found in Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. 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 TANKS 005 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Process Parameter Annual Limit ID 01 Crude Oil 120,000 barrels TANKS 005 Throughput 02 Combustion of pilot 0.3 MMSCF light gas The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS Page 2 of 10 _, , ' COLORADO llution Control Division C©PNE Dre,xlebneqt V Pubir_Health b Ermr,svat-e Dedicated to protecting and improving the health and environment of the people of Colorado 6. 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) 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 9. 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. 10. 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. 11. 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. 12. 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 Page 3 of 10 ICOLOR ADO '-' . Ipite I Air Pollution Control Division ,...., 'JeS` .„,„,,,„„0.Pub7a_Heald I$ernin;foTleA Dedicated to protecting and improving the health and environment of the people of Colorado 13. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. All previous versions of this permit are cancelled upon issuance of this permit. 17. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • 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 4 of 10 O Air Pollu tion A Control Division t6PHH D n'Ot 1i Ce PuL.e Health&_r2v c(,rrtent Dedicated to protecting and improving the health and environment of the people of Colorado 18. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Equipment AIRS Equipment Emissions - tons per year Pollutant ID Point Description Threshold Current Permit Limit GLENG02 002 SI RICE GLENG01 003 SI RICE Produced PRD WTR 004 Water Storage Vessels Crude Oil VOC 50 24.7 TANKS 005 Storage NOx 50 7.0 Vessels LOAD1 006 Hydrocarbon liquid loadout Separator 009 Separator Venting GEN01 011 SI RICE Insignificant _ _ ___ Activities Notes: APEN exempt and Permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 19. 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. 20. 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 Page 5 of 10 • Ale -xw- ' COLORADO - , 1 Air Pollution Control Division CDPHE Dt1)41a1.*ttwtti O Pub}a_kk iOi B:flv'r' rrn `!! Dedicated to protecting and improving the health and environment of the people of Colorado 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 January 10, 2020 Issued to Enerplus Resources (USA) Corporation Issuance 2 This Issuance Issued to Enerplus Resources (USA) Corporation Increase permitted throughput from 102,718 Page 6 of 10 ! COLORADO Air Pollution Control Division CD Deo7nrnt,nt o Pub- Healkl i 6 trlvtrt:Aune"A Dedicated to protecting and improving the health and environment of the people of Colorado barrels/year to 120,000 barrels per year. Update emission factors and control scenario. Include limit on pilot light combustion. Issued as final approval. Page 7 of 10 ( COLORADO Air Pollution Control Division L6PNE otlafirrwTa a'Pub7at Health B virurvtle-„ 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 556 28 005 Toluene 108883 88 5 n-Hexane 110543 3,619 181 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Process 01: Crude Oil Throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 7.04x10-3 7.04x10-3 AP-42 Chapter 13.5 CO 3.21x10-2 3.21x10-2 AP-42 Chapter 13.5 VOC 3.672 1.836x10-1 EaP Tank version 71432 Benzene 4.627x10-3 2.313x1O4 3.0 Page 8 of 10 CO Po llution R A c O Ai< oDivision CDPHE CjeL 3?2?"tY'11 Cs'Pubtx_Ffealrti _rw2rt;itrrie e Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl 110543 n-Hexane 3.016x10-2 1.508x10-3 Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%. The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with EftP Tank version 3.0. The pressurized liquid sample used as an input for the Ei:tP Tank simulation was obtained from the outlet of the three- phase separator for the Pot O' Gold 8-67-35-2C well on 06/26/2020. The sample temperature and pressure are 118°F and 65 psig respectively. The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using a GOR of 45.7319 scf/bbl and heat content of 2,263.25 Btu/scf. Actual emissions must be calculated by multiplying the emission factors in the table above by the total crude oil throughput. Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) NOx 101.03 101.03 AP-42 Chapter 13.5 CO 460.58 460.58 AP 42 Chapter 13.5 Note: The NOx and CO emission factors above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a higher heating value of 1485.75 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 11 scf/hr. There are a total of three (3) enclosed combustors used to control emissions from this source. As a result, the total pilot light rate is 33 scf/hr. The total volume of pilot gas flow is determined by monitoring the hours each enclosed combustor operates with an operational pilot light. Total actual emissions are obtained from the sum of emissions resulting from the crude oil throughput (process 01) and the combustion of pilot light gas (process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. Page 9 of 10 HCOLORADO Pollution Control Division Dr r,tr er;1 cs!Pub FfealUi 6 Trwit=i+rt1 "d Dedicated to protecting and improving the health and environment of the people of Colorado 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC &t NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC &t NOx MACT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://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 10 of 10 COLORADO Mr Pollution Control Division ClPYiE ( alxictiEtfell o "ubtr-Health Er thy-fru tote' -'. Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 8WE 1127 Issuance: 2 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Irish Well Pad Plant AIRS ID: 123/9FD9 Physical Location: SWSE SEC 26 T8N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description Hydrocarbon loadout from storage Vapor Balance and LOAD1 006 vessels to tank trucks using submerged enclosed combustor(s) fill. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Page 1 of 11 ICOLORADO Mr Pollution Control Division Depaoileit Pul*ir ttealtti Eriv=rurvrt ? Dedicated to protecting and improving the health and environment of the people of Colorado Equipment ID AIRS Tons per Year Emission Point PM2.5 NO, VOC CO Type LOAD1 006 --- 0.01 0.3 0.1 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 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. 3. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants Controlled ID Point Vapor Balance and Enclosed LOAD1 006 Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit ID Point LOAD1 006 Hydrocarbon liquid 120,000 barrels loaded The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. Page 2 of 11 [ COLORADO Air Pollution Control Division cC,PHE I C *2mert Pubtae€ieilth C En.,truvrn:, Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 6. 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) 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.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. 9. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 10. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 11. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): Page 3 of 11 ICOLORADO ,�..} Air Pollution Control Division [ I m are cg Pui't₹e t fei1ih G tar rL trnle52 Dedicated to protecting and improving the health and environment of the people of Colorado • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 12. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 13. 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)) 14. 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 15. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to Page 4 of 11 , COLORADO Air Pollution Control Division C©PHE Cyr rtrr, a,c.#Pubt,_t(eilth 6 C r,,,,me`,1 Dedicated to protecting and improving the health and environment of the people of Colorado demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. All previous versions of this permit are cancelled upon issuance of this permit. 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1)ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5)tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Page 5 of 11 ' COLORADO Air Pollution Control Division L Tare e 0!PuLlr;f{tldlrI & rI rr.,twr!e 1 Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. 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 (Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Equipment AIRS Equipment Emissions - tons per year Pollutant ID Point Description Threshold Current Permit Limit GLENG02 002 SI RICE GLENG01 003 SI RICE Produced PRD WTR 004 Water Storage Vessels Crude Oil VOC 50 24.7 TANKS 005 Storage NOx 50 7.0 Vessels LOAD1 006 Hydrocarbon liquid loadout Separator 009 Separator Venting GEN01 011 SI RICE Insignificant Activities Notes: APEN exempt and Permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the Page 6 of 11 .r Air Pollution ADO oDivision c©PHE Detx3gMent Cs'Pub1r fleet'&":WM{'tte'=a Dedicated to protecting and improving the health and environment of the people of Colorado permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Page 7 of 11 COLORADO Air Pollution Control Division Deoaflinen1 Puble F`feekth a t5v,rv'i'u'iIO',1 Dedicated to protecting and improving the health and environment of the people of Colorado Issuance Date Description Issuance 1 January 10, Issued to Enerplus Resources (USA) Corporation 2020 Issued to Enerplush Resources (USA) Corporation Decrease permitted throughput from 171,197 Issuance 2 This Issuance barrels/year to 120,000 barrels/year. Update to include current regulatory requirements and citations. Establish new synthetic minor limits. Issue as final approval. Page 8 of 11 ' COLORADO Air Pollution Control Division LOPE . € DeDaftv,teni EA Pubic_'Ffealtti 6 Err.ETLA‘Pien1 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 16 1 006 Toluene 108883 3 1 n-Hexane 110543 100 5 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 006: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl NOx 1.17x10-4 1.17x104 AP-42 Chapter 13.5 CO 5.36x10-4 5.36x10-4 AP-42 Chapter 13.5 VOC 1.01x10-1 5.04x10 3 AP-42 Chapter 5.2, Equation 1 Page 9 of 11 ! COLORADO Air Pollution Control Division SPHE [SEya+ytrw i Cv'Puttto#i Ph C Erma Dedicated to protecting and improving the health and environment of the people of Colorado The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 3.4 psia M (vapor molecular weight) = 50 lb/lb-mot T (temperature of liquid loaded) = 530 °R Controlled emission factors are based on the enclosed combustor(s) control efficiency of 95% and vapor balance collection efficiency of 100%. As a result, the overall control efficiency is 95%. The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively)in the table above were converted to units of lb/bbl using a GOR of 0.763 scf/bbl and heat content of 2,263.25 Btu/scf. Actual emissions must be calculated by multiplying the emission factors in the table above by the total hydrocarbon liquid loaded from the storage vessels to tank trucks. 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 Et NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Et 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.Rov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z Page 10 of 11 COLORADO je,„,, , Air Pollution Control Division a)aftrnerm 04 Pub He3ie b Zevtn_rtrne• Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 r-_,g COL a �►Afr Pa ivision Deza,ITnent_'Publ4 t(ealftt E,:cYV r rr1E",'. Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 8WE 1129 Issuance: 2 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Irish Well Pad Plant AIRS ID: 123/9FD9 Physical Location: SWSE Section 26 T8N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description Flaring of natural gas vented from two (2) Separator 009 two-phase separators and two (2) three Open Flare(s) phase separators during gas pipeline downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. 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.) 2. 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 Page 1 of 11 ,, . ti R A D ' Mr Pollution of Division CDPHf i Dt-t,evn nt O'Putr_He;alrh b trMrn,ri e:1 Dedicated to protecting and improving the health and environment of the people of Colorado 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.) 3. 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.) 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: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type Separator 009 --- --- 8.5 2.8 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, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled Page 2 of 11 oR,,iICOLORADO NtaiI Air Pollution Control Division Dtx rtme,71 b"Pubk t{e t,6 t.flir�n,rtYe". Dedicated to protecting and improving the health and environment of the people of Colorado Emissions from the two-phase separators Separator 009 and three-phase separators are routed to VOC and HAP an open flare during gas pipeline downtime. 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 rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) ) Process Limits Equipment ID AIRS Process Process Parameter Annual Limit Point Natural gas vented from two (2) two-phase 01 separators and two (2) , 11.7 MMSCF Separator 009 three-phase separators and routed to the open flare. 02 Combustion of pilot light 0.1 MMSCF gas The owner or operator,must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the two-phase separators and three-phase separators and routed to the open flare using an operational continuous flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 10. The owner or operator must monitor and record the time (hours) during which gas vented from the two-phase separators and three-phase separators is routed to and controlled by the open flare. The time during which two-phase separator and three-phase separator gas is routed to the open flare shall not exceed 744 hours (1 month) in a calendar year. The owner or operator will calculate the total hours during which two-phase separator and three-phase separator gas is routed to the open flare per calendar year and keep a compliance record on site or at a local field office with site responsibility, for Division review. Page 3 of 11 O aC6PHEI AirPottuti R A Dol Di ision ! Det.xie ne'lt o'Pubb_Health h:nvtrGPtrnle-e Dedicated to protecting and improving the health and environment of the people of Colorado 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 II I.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Part D, Section II.B.2.e. The open flare must 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 open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto- igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. The separators covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 15. 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 a MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (01*M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements Page 4 of 11 _. _ 4.- 1 Air Potlution CLti R A O Control Division COPHE L fU71en1 c,'Ptak..Heair,I Ft Ewe orne"i7 Dedicated to protecting and improving the health and environment of the people of Colorado 17. The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the commingled natural gas vented from the two- phase separators and three-phase separators in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site- specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. All previous versions of this permit are cancelled upon issuance of this permit. 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr)in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 5 of 11 OaCOPHE CAi C O R A D llution Division f Devagnlel.o'Pubb_ffealSh 6:rmrertme,. Dedicated to protecting and improving the health and environment of the people of Colorado For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation Number 3, Part D 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 (Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Equipment AIRS Equipment Emissions - tons per year t Pollutant Current Permit ID Point Description Threshold Limit GLENG02 002 SI RICE GLENG01 003 SI RICE Produced PRD WTR 004 Water Storage Vessels VOC 50 24.7 Crude Oil NOx 50 7.0 TANKS 005 Storage Vessels LOAD1 006 Hydrocarbon liquid loadout Separator 009 Separator Venting GEN01 011 SI RICE Page 6 of 11 ,,iic0L00 Air Pollution Control Division CDPN€ O y,,iMerit 0,Pubb f fearli b 1:rmr,_vme d Dedicated to protecting and improving the health and environment of the people of Colorado ___ ___ Insignificant Activities Notes: APEN exempt and Permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and Page 7 of 11 x COLORADO Mr Pollution Control Division OP I C 'v3r+.rient %UK,kieBiilt G Envirmf'i ie Dedicated to protecting and improving the health and environment of the people of Colorado administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 January 10, 2020 Issued to Enerplus Resources (USA) Corporation Issued to Enerplus Resources (USA) Corporation Point 008: Cancel and remove source from permit. Issuance 2 This Issuance Point 009: Decrease permitted throughput from 75.4 MMscf/year to 11.7 MMscf/year. Include limit on pilot light combustion. Update emission control scenario. Approve open flare as back-up control device. Page 8 of 11 - ICOLORADO Air Pollution Control Diviiirnn COME Ck-Varil 0 Pub_.Freon(&Envuunrfl€' Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:-https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,107 56 Toluene 108883 737 37 Ethylbenzene 100414 96 5 Separator 009 Xylenes 1330207 203 11 n-Hexane 110543 5,061 253 2,2,4- 540841 157 8 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 11 ," , COLORADO 44641 Mr Pollution Control Division CDPNE Lit O!r e^i a Pubb.He31.th e T_flvir%furt it-d Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 009: Process 01: Waste gas vented from the two-phase separators and three-phase separators and routed to the open flare. Weight% Uncontrolled Controlled CAS # Pollutant of waste Emission Emission Source gas Factors Factors (lb/MMSCF) (lb/MMSCF) CO --- 460.58 460.58 AP-42 Chapter 13.5 VOC 41.58 28,805.22 1,440.26 Gas Analysis 71432 Benzene 0.1365 94.6 4.73 Gas Analysis 108883 Toluene 0.0908 62.92 3.15 Gas Analysis 110543 n-Hexane 0.6242 432.49 21.62 Gas Analysis Note: The controlled emissions factors for this point are based on the open flare control efficiency of 95%.The VOC and HAP emission factors listed above are based on the results from two site specific two-phase separator extended gas analyses that were obtained on 09/07/2018.The most conservative total HAP weight%, individual weight fraction to total HAP weight fraction ratio and molecular weight from each sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10) were used to determine the emission factors. The sample temperature and pressure for the sample obtained from the Sligo 8-67-26-23C well are 105°F and 89 psig respectively.The sample temperature and pressure for the sample obtained from the Pot O' Gold 8-67-35-2C well are 106.8°F and 88 psig respectively.The CO emission factor above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor(0.31 lb/MMBtu)by a higher heating value of 1485.75 Btu/scf.Actual emissions are calculated by multiplying the emission factors in the table above by the total metered two-phase and three-phase separator gas routed to the open flare. Process 02: Combustion of pilot light gas • Weight°/0 Uncontrolled Controlled CAS # Pollutant of waste Emission Emission Source gas Factors Factors (lb/MMSCF) (lb/MMSCF) CO --- 460.58 460.58 AP-42 Chapter 13.5 Note: The CO emission factor above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor(0.31 lb/MMBtu) by a higher heating value of 1485.75 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 11 scf/hr.There is one flare equipped with a single pilot light that controls emissions from this source.The total volume of pilot gas flow is determined by monitoring the hours the open flare operates with an operational pilot light. Total actual emissions are obtained from the sum of emissions resulting from the waste gas vented from the two-phase and three-phase separators (process 01) and the combustion of pilot light gas (process 02). Page 10 of 11 Asz', ! COLORADO Air Pollution Control Division 6Pff i L ,trlw,,i O Put ie tie tr 6 rmn.prne-,7 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 Et NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Et NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.Rov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 6: 422892 Received Date: 12/10/2019 Review Start Date: 6/11/2020 Section 01-Facility Information Company Name: Enerplus Resources(USA)Corporation ''��` es✓ Quadrant Section Township Range County AIRS ID: 123 SWSE I 26 8N "67 Plant AIRS ID: 9F D9 Facility Name: Irish Well Pad Physical Address/Location: • County:. Weld County Type of Facility: Exploration&Production Well Pad What industry segment Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? -.Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point k Permit It (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already 6 Required? Action Remarks assigned) assigned) Permit 005 Storage Tank TANKS Yes 18WE1126 2 No Modification Section 03-Description of Project Enerplus submitted a permit application to modify sources at an existing major well production facility.With this application,the operator is requesting to modify the crude oil storage vessels,hydrocarbon loadout and separator venting sources.This analysis only evaluates the crude oil storage vessels. With this application,the operator is requesting to increase the permitted throughput routed to the enclosed combustors from 102,718 barrels/year to 120,000 barrels/year.Additionally,the NGL skid has been removed from the facility.As a result,the entirety of the waste gas vented from the storage vessels is routed to and controlled by the enclosed combustors.The permit will be updated to reflect this control scenario.Finally,the site specific emission factors are being updated with this application. Public comment will be required for this permit modification because new synthetic minor limits are being established.In other words,the facility emissions are now below the serious non-attainment threshold of 50 tpy. Self-certification for the first issuance of this permit was received on 07/07/2020 and approved on 07/08/2020.The modifications as a result of this project do not warrant sending the permit back through the self-certification process.As a result,the permit will be issued as final approval. Sections 04,05&06-For Division Use Only I Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O O ❑ E O O Title V Operating Permits(OP) O O O O O O O O Non-Attainment New Source Review(NANSR) ❑� O Is this stationary source a major source? 10`0 ( 'u If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ O ❑ ❑ O O Title V Operating Permits(OP) DEED O O O O Non-Attainment New Source Review(NANSR) ❑ ❑ Section 01-Administrative Information 'Facility Al Rs 10: 323 9FD9. 003 County Plant Point Section 02-Equipment Description Details Storage Tank Liquid — `. Detailed Emissions Unt Six(0)400 barrelfived roof crude oil storage vessels connected vu liquid manifold, Description: Em ss on Control Device Endased Campus#ads} Description: Requested Overall HOC&HAP Control Efficiency%: 95.0 Limited Process Parameter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput Barrels(bbl)per year Requested Permit Limit Throughput= 120,0000:Barrels(bbl)per year Requested Monthly Throughput= „1523 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= :120,000.0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 22R/a.3 Btu/scf Volume of waste gas emitted per BBL of liquids Produced= z 4filscf/bbl Actual heat content of waste gas routed to combustiondevice= MMBTU per year Requested heat content of waste gas routed to combustion device= <t 41"..i MMBTU per year Potentialta Emit(PTE)heat content of waste gas routed to combustion device= _..+_- MMBTU per year Control Device Number of pilot lights: -'3 Pilot Fuel Use Rate: 11 scfh I z MMscf/yr Pilot Fuel Gas,Heating Value: 1405.70 Btu/scf ,s i MMBTU/yr Section 04-Emissions Factors&Methodologies W illthis storage tankemhflash emissions? P&P Tank Flow Rate 310,442.50 bbl/year Pollutant Emissions(tpy( VOC 210,430 Benzene 0.x24 Toluene 06¢0 Ethylbenzene 0 '``f %ylenes IX n-Hexane 1.786 2,2,4-IMP Emission Factors Crude Oil Tank Uncontrolled Controlled Pollutant (Ib/hhl) (Ib/bbl) Emission Faster Source (Crude Oil (Crude Oil Throughput) Throughput) VOC Benzene Toluene Ethylbenzene .- _ MVlene b.00.300.0.0 _-_ n Hexane -0/'43t..410 Mr4r1S4Vile-03:454%;44' 224 TMP Control Device —Uncontrolled Uncontrolled_ Pollutant (Ib/MMetu( (l6/bbl( Emission Factor Source (waste heat (Crude Oil co mbusted) Throughput) PM10 ; bdl .3100 00 ' y q- Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBte) (Ib/MMscf) Emission Factor.Sourcs (Pilot Gas Heat (Pilot Gas Comhus#ed) Throughput) PM10 0.0075",n,"' ,t' PM2.5 0007 ,,;^'n ?. SOx R000G G NOx r/`-t.0'A064 ;+„ ,01Gat VO[ if;0054,,. aaa CO ,Fs 03i0D.. see 3000C _... _..-. Section OS-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) Ohs/month) PM10 1000 _...2 .l.v 3 -.-a PM2.5 0.024 iC? _ ;r.d., 0 040 $.:. SOx 0000 _0,0 0.::0 004 - NOx G_ul 0 01.0 _=s7 137 VOL 'z.2S4asses e.se 00.-o.251 is ale CO 1.302 O.OSi J._..: 2.542 _03?. >._ Potential to Emit Actual Emissions o Requested Permit Limits Hazardous Alt Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) Ohs/year) (Ibs/year) (Ibs/year) Benzene 503.21 0.00 Toluene 33:13 _ Ethylbenzene t00 6AO u:to )(ylene 0.09 0.0, 000 - n-Hexane a. 0.90 0010090 ..- 224TMP e_ e.sa Rs-" ... _e 2 of 4 C:\Users\hslaught\Desktop\1239FD9\18WE1126.CP2 Section 96-Regulatory Summary Analysis Regulation 3,Parts A,B .---- Regelallot 7,Part D,5ectiun I.C,0,E,F Regulation 7,Part 0,sectlon I.G,C = ... Regulation 7,Part D,Section ll.B,Cl,: C.3 - - _ Regulation 7,Part D,Section II.C.2 .. _„9a Regulation 7,Part D,Secton IlC4.a.(i) - 1-ty t_'. Regulation 7,Part D,Secton IlC4.a(ii) - _ Regulation 6,Part A,NIPS Subpart Kb .a, cqr,...,�,>,„„_..v.>,7.... Regulation 6,Part A,NSPS Subpart 0000 }: .,_a 70,^°, • NIPS Subpart 00000 _..._ .S0c Off'."-tea Regulation 8,Part E,MACT5ubpare HH 8015 :iALT (See regulatory applicability worksheet for detailed analysis) Section 57-Initial and Periodic Sampling.and Testing Requirements For condensate or crude 0l tanks,does tie company seethe state default emissions factors t estimate emissions? Ryes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to b greater than or equalto 20 tons VOC per year,OR arethe uncontrolled 4 ,. actual or requested emissions for a.condensate storagetank estimated to be greater than or equal to 80 toy? ..__i,.�t. �N/A-the operator developed site specific emission factors. Ryes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use asitespecific emissions factor to estimate emissions? T , If yes and if there are fl b th factors based on a pressurized liquid sample drawn atthe facility being perm ite?(for produced water tanks, pressurize liquid sample must he analyzed usngflash liberation alys)Th pl should be considered representativewh h generally means site-specific and collected within year ofthe applIcation received date.However,fthe facility has not been modified(e.g.,no new wells brought on Ine),then it may be appropiateto use an old site-specific sample. g ;?,s; If no,the permit will contain an"Initial Compliance"testing requirement to develop asitespecific emissions factor based on guidelines in PS Memo 14-03 Does the company requests control deuce efficiency greater than 9S%for a flare or combustion device? .-_n_ •I It yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section es-Technical Analysis Notes 1.Accordi0gto the APEN,two-wells produce to this faclry.The well names and API numbers are as follows()Name:Pot O'6old8-673520,API 05-123-44918,and(i)Name:Sligo 8-6724.23C,API'0512344921. Both wells were fractured and began production nJuly 2018.COGCC data indicates the API gravity for each well is less than 40u s a result,the classification as crude oil is appropriate.Each of the wells produces from the Codell formation. 2.The sample used to establish ems Ion factors was obtained from the outlet of the three-Phase separator for the Pot O'Gold 06735 2C well on06/26/2020:Tits sample was submitted as part of the selfcertificaton requirements included in the first issuance of the permit Thls sample is acceptable for the following reasons:(i)No new wells have been added to the facility since thesamplewas obtained.(ii)The sample was obtained from the outlet of the three-phase s paator,which N the separator directly upstream of the storage vessels(WI The existing wells have not been recompletedorrefratturedsince the sample was obtained.For the reasons listed,the initial testing included in the firstissuance of the permit will be removed from this Nsuance. 3 The site specificemplewas used in conjunction with en PIP Tanks v.30 simulation to determnes[_specific emission factors and comburt n emissions.The results of the Tanksmulation(e. ns(spy),: em ssio em ssio GOft and how content) avallablefor reference in Sections 03 and 04 above. 4.The[rude all storage vesseN,produced water storage vessels and laadout operations are controlled bytle same thee enclosed combustors As a result,engneerng guidance indicates that combustion emissions(i:e NOx and CO)from allthe sources are summed together n order to determine APEN applcablry,In this case,total NOx and.COemusonsfom all the sources are above APEN reportingthresholbe.As result,the pima for each sourceshould contain on limits and ernissionfactors for both NOx and CO. S.Since thecrudeoll st ragevi sel,poduced water rturage vessels and loadout are controlled bya control devce,pilot light emissions re grouped with the highest emitting source covered by an individual permit.In this case,the crude oil storagevessels a'e the highest emit-Nog source As a result,pilot light ems ountedfor with this analyse The permit for the crude oil storage vessels also contains a throughput limit for pilot combustion.Emsslon factors and calculaton methods for pilot light combustion emissions are also included n the notes to permit holder.This i000nmutior 00 Goaded 10 the permit because pilot light emissions contribute to the averall emi s from mthes source.Additionally it is important to include this information becausethroughput tracking and emission calculation methods are different roan those used to estimateemissions based.on the crudeoll throughput.This clarry is important for ccuratelyquaniffying actual ems ns at this facility. 6.Self-certification for the first Issuance of the permit was submitted on07/07/2020 and approvedon 07/08/2020.As a result,thendal opacity testing and sampling requirements Included in the first issuance will be movedfromthsssuance of the p mM1 The'annual sampling requirement was removedfromthe permit because facility wide permitted VOC emissions are less than 40tpy.Dueto this,ongoing sampling sno longer a standard requirement Finally,ongorgopactrytestings addressed bythe 0&M plan.A h,periodic opacitytesting has been removedfromthis issuance of the permit. 7.As discussed in the project summary,the Naskid has been removed from location.Due to this,the permit has been updated tot ove any reference to the NGLOOri 8.A VOC emission factor for 01011,050 combustion is not noludetl in the permit because the totelVOC emissions associated with pilot light combustion are negligble(0001.tpy)and do not impact the overall VOC 9.An updated APEN was submitted In March 2020.This APES Indicates that a portion of m captured a vapor recovery unit(097).However,the operator has ndcatedthey are not taking credit for any emissions re co routed to the VRU.While some of the ems cietedwith the requested throughput may be routed to theVRU,the operator has assumed the entire throughputs routed to and controlled by the emissions r assn enclosed combustors: 10 Benzene and,Hexane e the only HAPs above APEN reporting thresholds(i.e.25016/year).As a result,the permit will include emission factors for these pollutant: 11.The operator was provided with a draft permit and APES redline to review prior to pubic comment Th operator reviewed both documents and provided comments.The operator's comments and the Division ,. response are available in the enrol records that have been uploaded to Records Manager. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Pointe Process ft SCC Code Pollutant Factor Central%Units 01 4f -TP('{(,y(#}eadT4 1"1tyjg{'2't2.}wyi tbOe 1igl )epp0S .„ t PM1D _a2 _ b/1,000 gallons Crude Oil throughput PM2.5 q c 0 6/1,000 gallons Crude Oil throughput SOx C b/1;000 gallons Crude Oilthroughput NOx L".27 b/11000 gallons Crude Oilthrcughput VOC - ,..,:. -- 6/1,000 gallons Crude Oil throughput CO 6/1,000 gallons Crude Oilthraughput Benzene _ ... b/1,O0D gallons Crude Oil throughput Toluene 6/1,000 gallons Crude Oil throughput Ethylbenzene :._ b/1,00D gallons Crude Oil throughput Xylene h. 1/1,000 gallons Crude Oil throughput n-Hexane b/1,000 gallons Crude Oil throughput 224 TMP .._„ _3 1/1,000 gallons Crude Oilthroughput • 3 of 4 C:\Users\hslaught\Desktop\1230FD9\18 WE1126.CP2 • Starage Tank Pegulatary Analysis Worksheet The regulatory requirements below are determined hosed on requested emissions. mlwam .ulamn3 a -APEane PermdRequireme. PrAINm5 0^ lralletl actual,.arern 3.Part A.cton aravandaa.arometon4/1.014and not ms.m any ate.onat.after viaiaauivin ngaragetan.euthp essthan aneaterthan ^oao¢+uon>oarxn„s�+P,mEo^aaimraaasr.nal:.,a+na,mm�arnn+r+ppmbll,rvv nfa l.............em t.,.., ......ilan m iDTvv eoemxmn g eawm iDTP,IA c..1 i P+ne s+ uD,l( 1.Are uncontrolled emnlonrrnm - pu.lsourseeaertn+n,Tw,peNlatln s,van',Section lroeale Yat's��'=',source Aewlra an Av5x.6nnlFe neat guenion t.Is the a aAa/EDNIanJlnotmoadea after wltn+aunE•tank thrwehput last than 4.00 gallons per year pee yes Memo tausfor aaanlonlgulden®un eranelamv appllobJlryl? ANib`4,."' a s.Pre total nronroe emsq a erthani'M..Kw greater OnsTpr or CO embn.m ereater than 1D71,IA¢ulanan e,..(3,3enlonn.D.ip re>ia::xutaft:r p u Paula,.T PuD,action hn.ra 6 1.Jtl,k storage Onli Ion.In tIle%Art ./Ma area Iliac on Lasp Arnim +M1nt. I...raga tank Incatetl at Oil end 6a,operallen,thatstme,or Ilan. rp produced water AND that at or upstream on natural, plant i,Pan o.scamp IAA)pCont..-V.havind.w, fad.type the pro,.summary sheet. 3.Is'Ills storage la...eclat a natural gasssmg da,�llw eummn 7..asemon1,Gu ug sloraeelank b not subjectto Regulator,i.Pan o,6eo:on 1,6 You nave,Retread melolY type on vmlmtummaw sheet. 5.Oons this storage tan,.II,C.Flash•le.e.storIng non-stabilized ten emneens,nexmat.p.part osemmn ta.av 6.Amen n 0/o thanitnn+pnrynrVDDIAeNlanenT.P.rlDsatenlD.6.aalu, p�t�f"y enl a ten rental 6Aammnt—Preuntnn nrw¢a¢n p.., .._:.....:.,:, pr,...::,.•. I Colorado aivwuanz Pan o,smang 1.Is thisatongetank ata tr....ion/storage facet, ea.oil and ps,laratioh and production operation.wpp uctmn,asdnY.ntua Vtnmpr ert+tonor natural er puenion- unave India.rte./type nvlectummrysheet 3.Does this as tell a,be un a npervn.Vae lA:Nlarpn p,Pan D.seawnn.e.i.aQ Yffi,g '.Sourrce is sidled to pans or ReNeton>.vsn uses.ns n.aer.6o to the next question enrol • nl Equip mane hmenAondEmissons s.Dont eotlma es Ire nD,semm�ll.c3al? INov..'..lb rce sugmtoall provhmnser INNlatmn7.Pangsamon R,suhsecbora ac 0/1':[ rnJll.Cz_gtspoke+pa:onlmnn tetoap T+nksInteewnnurPolluxoncomrol[qu:pment en taw - nauraessmmipated atat on ornwura Nsofhprongvamnnnror pJoner merMay iibmo thwwemmJ.onarehar �II 6.such F additional sew rxerv.an+ntenrea nsrease ntnreuehputelhproahon guerorprmuaa water!Regulation r c.a.a.1? N %'�.JsoraxTanY snot sgbtettto 0.e¢umon?.Part D.clamp.Cd 7.i qtrnla,t awePatt me. nthZ07:1a 4Toc ronTkIro;:ur dwa„,ane aaot trTI.:,:ntA.ra:„Iod, onerar POCK Nit 6,50mart Rand.,olPeriormamelorVolallie Organ, era. Is the storage vessel greaterthan a equal rtA?i.6m,ldDerr..a.0,all? N0/ loraNTanxsnottubienxsPskb i.storage uesw apectysbalwtheapp,xahamretn0/ i.Duet mean NA JJ a.Does the vasel lima des.n1,30[1,1..41 ar ["10030066t,m tl.proeeeted,ertreaedprinrmeanny Inl.r as.defined In6n.,,,nP tr eEu(seedeflmllans CFP, )+Dermyii1sul,<J fxren1.1aEpp;am NA sA:a'ssl eaawat. °,8,nr2.mA0Pal-,a.iptllah017,heetathIB tathea,matph.l.I6n.11A1]171:17 7. min's.echo m'p5w gap a.aaoenaligma w,u amavlmumnue pap p urr esstmn s.0/kwlw.n ele,p Dnma.The deign opacity Is greateran 01 equal to m MOO5centrall1A°es lqu,awJnaAn.,numtwev+Per equal to 1175 NA M.i-aneeutnt lessth+n,nm,-630 BBLI and sores+liquid with a maximum vue vaporpressure greater than or eaivallo15.nkn but let+Shan 27.6 kPa? .DrrA.P+nbe.6uAp+nDoDD/ognoa.Nanm�adPw,amwnae(mendeDAand Nata�I6a+Pmmnlm.Trenamrrrinpananlnrl�ten 1.1.11SMIALL vessel...I at a tacky Intne onshore 01 and ,nn,oproductrenp<<gao:,a��Ypame.:;a=praretslngseementor ngural SP6DDIXI the nenpbea:ontownlmuedeterminaxanarx6P60DDDaapplaamnrv. 4,Are poteralal VOL EMIMS,01110elnaMclualsZaraernereatei n0/yea. Na;s r eTnkIsnnthe nat , N6PSDnooa. 5.Doe..storage vessel meet the definition...storage yea, =;0/6,15 M 6.Istne oregev oaten won.eeunmennmraoreeevro.l:In agcfA Pas 60/ ngbormefAPan6e yew A.±�% Nola; wblen oo/DDDoadntoemlasim:sewn6 loot poryearvoe an Om J.,erminalloll eats,bsnouwrema,nwelmmx6PS ODDD/DDDDa p.r 6D.ssliai,Av`6o:s,N`ael4.., a wIPIAAA mlmwnsdrap beew6tnsp vearl i,n.theettample l yea,,Oil and neural a rod al,raehtvmw meets either oft.lolloWing em: I• Iconnn.You have thesaufra categoryon.Prwen sum.ry n . +.Afaallrythat proemx,. .orworesh,•droorno g s`,6i.T5Dlalan:DA u.1 gz prior.the porn,at whim natural gat enters the natural ps ,Ionnaatornewuraaegorror rtm,Iweetaa final gib user'03.T6,031R for Ws, R!el,,.ataraNTanklsnatub,eneaaCT.-T,erearenomAr(xlrrequ:rementsfertenesatareasowem NNTflw'+:Subs.lsme RPanso.subnngbarsubnnmw0? 6,? 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Disclaimer doc ument ass isb open tors wim def7H.0yappd-wbdlydmbin rat,u+en=b of Glee Air Ac(IlslmpkrrenIAIINA iaLma.NTAAI0uaity O0AAAI ewmussrm++gukLons.TM1ramcumunlb rid rdM:aaodynis ii cartaw maynd applylo a peiicuka atwbbn based dpm lhermMNuelradx end circumstances TW any law.regulelim, `enyor regulation,brmbarolINamed anAArmilagally earrceabk.ln,be even./any cankbe document �z,Ismen.praswabn,: deAVDdalily Dmbol Commliaaim reswalln a uemnpaapamtha ahll?I A AOdm:'m wm+A,lmlµrn We d nan.menminy language aural as aeo„mmm.'may.'-.m wd,•aad neo;r0/Wen.to nr....PLO kote,alolinu andalayrerminaevy+uch as'must'oPrep.,rvarommmrodnsvibeconbonirgremareraammaraa me toms olihe mmnarAdam,v AA.AIVeanImlcnmmlasimhuhA,n tad s docummenr dines roteatablbh lovely bindlrO reAnvcmenn In and a',toel/ COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Enerplus Resources(USA)Corporation County AIRS ID 123 History File Edit Date Plant AIRS ID 9FD9 Ozone Status Non-Attainment Facility Name Irish Well Pad I EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) AIRS lid PERMIT I Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS 1 VOC HAPs VOC HAPs Previous FACILITY TOTAL 1.1 1.1 0.0 0.0 157.4 1,666.0 1.4 239.6 33.5 1.1 1.1 0.0 0.0 18.1 86.9 1.4 53.0 3.0 Previous Permitted Facility total 1.1 1.1 0.0 0.0 157.4 1,666.0 1.4 239.6 33.5 1.1 1.1 0.0 0.0 18.1 86.9 1.4 53.0 3.0 SI RICE Doosan 0081NA,4SRB,106 HP Cancellation received 0523/2020.Source no longer 001 GP02.CN 0.0 0 Q SN EEPOF-301446: exists 8tkhe faclhty `r 002 GP02 SI RICE Caterpillar G3306TA,4SRB,203 HP, 0.2 0.2 32.5 1.4 32.5 q.6 0.2 0.2 2.0 1.4 4.0 0.3 No Change SN:16X07142 003 GP02 SI RICE Caterpillar G3306TA,4SRB,203 HP, 0.2 0.2 32.5 1.4 32.5 0.6 0.2 0.2 2.0 1.4 4.0 0.3 No Change SN:07Y06333 004 18WE1125 Two(2)400 bbl fixed roof produced water 0.58 34.3 2.6 3.8 0.6 1.3 2.6 0.1 No Change storage vessels 16)400 btat rued roof crude oti storage _ _ _ s C7)frwm 104718 tab tyr to 125,00e bbllyr. ?{inPdt`112T asezts !iodate SSE(.Update cotatxtal scenario.lamiucit. font:oil ptto1 Iieglit '2Y las ;vY1 r1 �f <r',e daraar.^rlYrpii 4>,arra 1'Td,dSrY 007 18WE1128:CN Fugitives from NGL skid 0.0 0.0 Cancellation received 12/10/2019.Source no longer exists at the facility. 008 18WE1129 NGL skid 0.0 0.0 Cancellation received 12/10/2019.Source no longer exists at the facility. ` - 7 vaLl separators 2t(Z Rf9fb P:,.Sc 11.'1 -:-.i y fb.i> separators scenario /tgipf UVe even Rate.include emit on 'fitb a 111,fa Si RICE Doosan O219L 4SRB 550 HP,SN) Cancellation received 12/1'0/201'9.Source no , ,010 GP02.CN EZYOFS02668 longer exists at the facility. 011 GP02 SI RICE Doosan D081 NA,4SRB,106 HP, 0.1 0.1 12.9 0.7 21.6 0.2 0.1 0.1 1.0 0.7 2.0 0.2 No Change SN:EEPOG402285 XA Heaters 0.3 0.2 0.0 0.3 0.2 0.0 Insignificant Source XA Fugitives 0.2 0.0 0.2 0.0 Insignificant Source VOC: Syn Minor(PSD,NANSR and OP) NOx:Syn Minor(NANSR and OP) CO: True Minor(PSD and OP) FACILITY TOTAL 0.6 0.6 0.0 0.0 79.8 432.7 0.2 94.4 11.0 0.6 0.6 0.0 0.0 7.0 24.7 0.2 17.8 1.3 HAPS: True Minor HH: Area source-no affected sources 7777: Area source Permitted Facility Total 0.6 0.6 0.0 0.0 79.5 432.7 0.0 94.2 11.0 0.6 0.6 0.0 0.0 6.7 24.7 0.0 17.6 1.3 Excludes units exempt from permits/APENs Modeling not required based on 4 change in (A)Change in Permitted Emissions -0.5 -0.5 0.0 0.0 -11.4 -62.2 -1.4 -35.4 -1.7 emissions.Pubcom is required because new syn minor limits are being established with this modification. Total VOC Facility Emissions(point and fugitive) 24.9 Facility is eligible for GP02 because<90 tpy(CO) and<45 tpy(NOx&VOC) (A)Change in Total Permitted VOC emissions(point and fugitive) -63.6 Project emissions less than 25 tpy(VOC&NOx) and less than 50 tpy(CO) Note 1 Page I of 2 Printed 7/16/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Enerplus Resources(USA)Corporation County AIRS ID 123 Plant AIRS ID 9FD9 Facility Name Irish Well Pad Emissions-uncontrolled(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL(tpy) — 001 GP 2 CN SI RICEDOOsag DO81NA 4SR9 106 00 HP SW EEPOF-301446 002 GP02 SI RICE Caterpillar G3306TA,4SRB, 980 84,1, 4'L L5.2 48.H 0.6 203 HP,SN:G6X07142 SI RICE Caterpillar G3306TA,4SRB, 003 GP02 203 HP,SN:07706333 980 445 42 252 42.9 0.6 004 18W61125 Two(2)400 bbl fixed roof produced 1835 5766 3.8 water storage vessels 005 18WE1126 Six(6)400 bbl fixed roof crude oil 556 88 0 0 3619 2.1 storage vessels 006 18WE1127 Hydrocarbon Loadout 16 3 0 0 100 0.1 007 18WE1128ENx Fugitives from NGL skid . 0.0 008 18WE1129 ` NGL skid ' 0.0 Natural gas flaring from two(2)two- 009 18WE1129 phase separators and two(2)three- 1107 737 96 203 5061 157 3.7 phase separators SI RICE Doosan D219L,4SRB,550 010 GP02 CN HP,SN:EZY0F802668 0.0 011 GP02 SI RICE Doosan D081NA,4SRB,106 239 t,� HP,SN:EEPOG402286 31 1835 0.2 XA Heaters 0.0 XA Fugitives 0.0 TOTAL(tpy) 1.1 0.1 0.1 1.8 0.4 0.0 0.1 7.3 0.1 0.1 11.0 Emissions with controls(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL(tpy) SI RICE Doosan D081 NA,.4SRB,106 001 GP02 CN 00.- HP,-SN:EEPOF-301446 002 GP02 SI RICE Caterpillar G3306TA,4SRB, 490 '14.8 42 25 2 r{f9.11 0.3 203 HP,SN:G6X07142 003 GP02 SI RICE Caterpillar G3306TA,4SRB, 490 44,1 42 25.2 48.9 0.3 203 HP,SN:07706333 004 18WE1125 Two(2)400 bbl fixed roof produced 69 216 0.1 water storage vessels 005 18WE1126 Six(6)400 bbl fixed roof crude oil 28 5 7 1' 181 0.1 storage vessels 006 18WE1127 Hydrocarbon Loadout "I 1 0 O 5 0.0 007 18WE1128.CN': Fugitives'from NGL skid ( 0.0 008 18WE1129 NGLskid'. _ 00 r-- Natural gas flaring from two(2)two- 009 18WE1129 phase separators and two(2)three- 50 37 F 11 253 8 0.2 phase separators 010 GP02 CN SI RICE Doosan.D219L,4SRB,550 0.0 HP,SN:EZYOF802668 011 GP02 SI RICE Doosan D081NA,4SRB,106 239 3'2 3'i I8 3(i 0.2 HP,SN:EEPOG402285 XA Heaters 0.0 XA Fugitives 0.0 TOTAL(tpy) 0.6 0.1 0.1 0.1 0.0 0.0 0.0 0.3 0.1 0.0 1.3 2 1239FD9 7/16/202(1 Corrado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 6: 422892 Received Date: 12/10/2019 Review Start Date: 6/16/2020 Section 01-Facility Information Company Name: Enerplus Resources(USA)Corporation Quadrant Section Township Range County AIRS ID: 123 SWSE 26 8N ,. 67 Plant AIRS ID: 9FD9 Facility Name: Irish Well Pad Physical Address/Location: County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment O;f&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? 0zone(NOn&VOC).. Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned) assigned) Permit 006 Liquid Loading L0AD1 Yes 18WE1127 2 No Modification Section 03-Description of Project Enerplus submitted a permit application to modify sources at an existing major well production facility.With this application,the operator is requesting to modify the crude oil storage vessels,hydrocarbon loadout and separator venting sources.This analysis only evaluates the hydrocarbon loadout. With this application,the operator is requesting to decrease the permitted throughput from 171,197 barrels/year to 120,000 barrels/year.The permit was also updated to include current regulatory requirements and citations. Public comment will be required for this permit modification because new synthetic minor limits are being established.In other words,the facility emissions are now below the serious non-attainment threshold of 50 tpy. Self-certification for the first issuance of this permit was received on 07/07/2020 and approved on 07/08/2020.The modifications as a result of this project do not warrant sending the permit back through the self-certification process.As a result,the permit will be issued as final approval. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration IPSO) ❑ ❑ ❑ O ❑ ❑ Title V Operating Permits(OP) ❑ O ❑ O ❑ ❑ ❑ O Non-Attainment New Source Review(NANSR) O 0 Is this stationary source a major source? No.: If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSO) ❑ ❑ ❑ ❑ ❑ El Title V Operating Permits(OP) ❑- ❑ ❑ ❑ ❑ EIDE Non-Attainment New Source Review(NANSR) ❑ ❑ Se ction 01-Administrative Information IFacilit0AIRs ID: 123 6300 06 County Plant Pmnt Section 02-Equipment Description Detats petaled Emssons Un Hydroc'a.bont clout from storage sets to 6.,nY. ! gzu56,0630 fill Description: Emission Control Device Vapor balance end Enclosed_ombustor{s) Descriffideffi bthis loadout controlled, yes Requested Overall VOC&HAP Control Efficiency%: 95 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= ,r.Barrels(bbl)per year Requested Perrot Limit Throughput= .068,,001Barre 600)per year Requested Monthly Throughput= Barrels(bbl)per month ) Potential to Emit(PTE)Volume loaded= 120,00:Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= .2265.25 /of Actual Volume of waste gas emitted per year= scf/year Requested Volume of waste gas emitted per year= scf/year 0:763415266 Actual heat content of waste gas routed to combustion device= 'MM3TU per year Requested heat content of waste gasrouted to combustion device= .t MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 3.MMBTU per year Control Device I I I Pilot Fuel Use Rates ^"S 'sefh -0 MMsdt/yr Pilot Fuel Gas Heating Value: .n 6:. dL'S3tu/sd 03 MMBTU/yr Section U4-Emissions Factors&.Methodologies Does the company use the state default emissions factors.estimate emissions? $£331i4F. Aretheemssons factors based on a scabhzed hydrocarbon quid sample drawn atthe facilitybeing permrtiedt _ 5...,..,,,,,„,,,,,,..,,,,,_,,,,..:,,, ..__ ,. .. ,.. . .e .,ac..o.,„ ..., s.__s Loading Loss Equation L=12.46"SeP"M/T Factor Meaning Value Units Source Molecular Weight 42.25 Saturation Factor 03 (111///3%. cr, AP42{fap£er52T,51052-15nbmergedt55d1ng Dedicated NorrrialSeivireiffir0EM P True Vapor Pressure i3.4„-ich Psi, ::AP-42 Chapter 3 Table 7.3 3...eminent Crude Oil)See Note ha Section. Mann. mass fraction u male% MW M M Molecular Weight of Vapors n50,33/ay lb/Ib-mol AP-12 Chapter Table7.1-2(Mid0,01,ont Crude 001 Helium 000. 3026 .u: T Liquid Temperature -3,3331,330.33/.33 0100162 086 6 ator Specified Value CO2 r 1.02 44.01 L-WE'.:1 L loading Lesvos •.15..316 s lb/1000 gallons N2 0.00 28.013 istl-- ,CE,O3.C6 o 33.3 ..:;5 Iii/bbl methane 14.95 16.041 4.eXii 3=OE_2 ethane 21.80 :30.063 8c Co mponent Mass Fraction Emission Factor Units Source Propane 45.64 4.092 ,, Benzene lb/bb - s0buhne 303 :458,138 Toluene -.E.Ib/bb n-butane 9.62 58:118 Ethylbenzene lb/bb 114 630060 'Ib/bh Total Waste:Gas C0mpo51t0n(E3P Tank) sepentnffienta,0 1.68 15:114 _. 6-Hexane Ib/hb psuedo1 0.05 123.42 224 TMP .lb/bb .. .Hexane 0.29 56:18 - r owedo2 ON 20218 other hexane. ..L 60ps _. Ensson Factors Hydrocarbon 10000 t psuedo3 00 219.75 Uncontrolled Controlled methylcyclohexane 00 48,55 .. Pollutant Emission Factor Source (Iii/bbl( lib/5bll 224-TMP 0.00 :,Lq.23 (Volume Loaded) (Volume Loaded) Benzene 0.05 -4$:12 VOC - _ -rig.,_ Toluene s 0.01 3,9.19 Benzene _ ®- Ethylbenzene 00 3.106,11 Toluene ® Xylen. 0.0 10337 ........0 Ethylbenzene - - CH+Heavies 00 s 116 %y1°°° e...3,4,,,Aw.,,, Total Mole% VOC mass fraction _ n-Hexane . VOC mole% 224 TMP . , § ,•,. Control Device Uncontrolled Uncontrolled Pollutant Emissi nFactm5 urra Rb/MMBtuI (Ib/bbl) (waste heat comhusted) (Volume Loaded) PM10 ,000]5 ¢ PM2.5 0.0025 sax 60008 NOx 0.0680 +. 141 CO :0310 CA r essy'i• wee Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (15/MN:Mu) (Ib/MMscf) Emission Fact r5 ur• {PilotGas (Waste Heat Combusted) Throughput) PM10 PM2.5 I VOC co 2 of 4 C:\Users\hzlaught\Desktop\1239F0\18W E112T.CP2 Hydrocarbon Loaad.L1 Emissions Inventory Section OS-Emisskno Imestary • Potentiaato Emit Actual Emissions Requested Permh limits Requested Monthly Umbs Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled Icons/earl Bons/year! (tans/year) pons/year) ...Mead • (lbs/month) PM10 PM2.5 .00 - SOxp Os NOx VOC Potentialto Emit Actual Emissions Requested Permh Umhz Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled pbs/yearl (bs/year) p./year) pbs/years pbs/year) Benzene Toluene Ethylbenzene %ylen II-Hexane 224 IMP .. _ Section Ofi- euletorn sum ry ma analysis Regulation 3R Parts A,B Regulation 7 Part 0 Section 11.0-5. (See regulatory applicability worksheet for deluged analysts) Section 07-Initial and Periodic Semolina eniTestine Requirements Does the company request a control deuce efficiency greater than 95%for a flare or combustion device? Na _ Hy.,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20.02 Section OS-Technical Analysis Notes I.Accordingta the APEN,two wells prod:metotho facility.The well names and API numbers are as follows.(i)Name Pot OrGold s-67-35-2e,API:05-123-44919 and hi)Name:Sligo 9-57-26-23C,API:05-12344921 80th wells were fractured and began production in July 2018.COGCCdaa Indidates the APIgautyfor each well Is less than 40.Asa r It the classification as crude of is appropriate.Each of the wells produces from the Codell formation. 2.HAP emissions are below ADEN reporting thresholds(I.e.a 250 ib/year).As result emission factors will not be included in the permit for HAM 3.Thevude oil storage easseb,produced water storage vessels and Ioadout operanom are controlled by the same three encosed combustors Asa result engineering guidance Indicates that combustion ern:Mons(ie.%Os and CO)from all the sources are summed together In order to determine APEN applicability.In this case,total NOxand CO emissions from all the sources are above APEN reportingehreshelds.Asa result,the permit for each source should contain emission limbs and emission factors for NOx and CO. 4.According to engineer guidance,pilot kilt emissions eregrouped with the highestemitong source that is controlled by common control device.In this case the crude oil storage vessels are the highest emdting source controlled by the enclosed combustors at thisfacility. Asa result,pilot light emissions are evaluated with the analysis for the crudeall storage vessels only(18W E1126.CP2). 5.The heat Input rote of loadout waste gas routed to the ECOs was calculated using the fallowing equation:MMBfu/Y [Uncontrolled VOC(ton/year)]"I2000 Ib/tonuIMoleculer Welghtlib/lbmol)I'(379 si#/IMmO1s[Heat Contentlelu(scf)I\I1;OWOW etu/MMBbi).The heat content used In this equation a based one weighted average of the value in the POP Tank simulation for the flash gas stream and the working and breathing scream.The value Is listed above In Secbon 03 of this analysis.The molecular weight used In this equation reflects the molecular weight for dconanent crude oil listed in AP-42 Chapter 7 Table 7,1-2(5D Ib/ibmol( 6.In March 2020,AP-42 Chapter 7 was,updated.One of dm updates pertains to the wkuletion of true vapor pressure for liquid specified asmdsenenent crude oil.Based on the updates,the true moor pressure for mdcontlnent crude oil s calculated using Equation 1-25(AP- 1.42 Chapter 2)and Figure 7.1-1&Using an average RVPaf 5.051(see stable.samples in application)-maximum dailyaverage ambient temperature of 523.178,minimum daily average ambienttempeature of 497.57R,average solar absoptance 0f 0.49(tan in average condition),and average total Ineelalfon factor of 1491 Btu/ft^2day in conlunction wish she equations listed above,thetrue vapor pressure was calculated at 3.022 psi.Using this value,a bulk liquid temperature of 55.67%and molecular weight of 5016/I6mol,the VOC fission factor was calculated at OCB21b/bbl.The operator's aiculatlons resulted in an VOC emission factor of 0.1007l/bbi Mnce the operator's tabulations are conservative,they were accepted and used for permitting purposes. 7.The mole 96 values from ttnetoal waste gas stream in the ESP Tank simulation weremnverted to weight 96 The ratio of the calculated HAP weight%to the VOC weight%was multiplied by the VOC emissions from this scarce to detetminethe HAP emissions.These conversions and calculations areavailablefor reference in Section 04 above. B.An updated APEN was submitted in March 2020.This APENindlates that a portion of emissions are captured using a vapor recovery unit lVRU).However,the operator has indicated they are not taking credit for any emissions routed to the VRU.While some of'Me emissions associated with the requested throughput may he routed to the VRU,tire operator has assumed the more throughput is routed to and controlled by the enclosed combustors. 9.The open as prodded wish a draft.Permit and APEN redline review to public comment The operator renewed both.documents and prodded comments The operators comments and Division response are available n the malls brat have been operator to cede review upfpa¢ed to Records Manager. Section 09-scc coding and Emissions Factors(Far Inventory Use Only) Uncontrolled • Emissions AIRS Point if PromssP SCC Code Pollutant Factor Control% Units 006 01 .I, -'6 PM20 _'9'Ca 0/1010 gallons transferred PM2.5 : 6/1,000 gallons transferred SOx - - 0/1000 gallons transferred NOx .3.33 0 6/1,000 gallons transferred VOC 2.:'.9i b/1,000 gallons transferred CO12='-0:. - b/1000 gallons transferred Benzene 2 3,303 6/1,000 gallons transferred Toluene 6/1,000 gallons transferred Ethytbenzene :- b/1001 gallons transferred Xylem 0 b/1000 gallons transferred e.eeeane 6/1,000 gallons transferred b/1000 gallons transferred 3 of C:\Users\hslaught\wesktop\1239F09\10WE1127.CP2 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements S,.urs e is in the Noe-o0 uvrr'irr,r Ai ea 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 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? S. Is the loadout operation loading less than 16,508 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 11.0.3)? V,D,f nave rt.3lcatert that swat:F:is„t the Nov A:teai,,,,a n:i.:,:.e NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan 1 TPY(Regulation 3,Part A,Section II.D.1.a)? Yes Go to next question. 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)? Yes s Go to the next question 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? No ,yfy-Go to next question 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? Nor.:,» ;Go to next question 5. Is the loadout operation loading less than.16,308 bbls per year of condensate via submerged fill procedure? Na a +' %:Go to next question 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greaterthan S TPY or CO emissions greaterthan 10 TPY(Regulation 3,Part B,Section ILD.2)? Yeg;y.y4,.,,ii The loadout requires a permit °s<.actr re_sluu,v.a P,,ntit Colorado Regulation 7 Part 0 Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility,natural gas compressor station or natural gas processing plant? Yes'.°"..,: Go to next question. 2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? Source is subject to Regulation 7 Part D Section ll.G5. Section II.C.S.a.(i)-Compliance Schedule Section II.C.5.a.(ii)-Operation without Venting Section II.C.S.a.(iii)-Loadout Equipment Operation and Maintenance Section II.C.5.a.(iv)-Loadout observations and Operator Training Section II.C.S.a.(v)-Records Section II.C.5.a.(vi)-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may," "should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 8: 422892 Received Date: 12/10/2019 Review Start Date: 6/16/2020 Section 01-Facility Information Company Name: Enerplus Resources(USA)Corporation,, -��` Quadrant Section Township Range County AIRS ID: 123 Swot> 26 8N 67 '. Plant AIRS ID: 9FD9 Facility Name: Irish Well Pad Physical �. Address/Location: County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment",Oil&Natural Gas.Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# - Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already # Required? Action Remarks assigned) assigned) 008 Other(Explain) NGL Yes 18WE1129 2 No Cancellation NGL Skid Permit 009 Separator Venting Separator Yes 18WE1129 2 Yes Modification Section 03-Description of Project Enerplus submitted a permit application to modify sources at an existing major well production facility.With this application,the operator is requesting to modify the crude oil storage vessels,hydrocarbon loadout and separator venting sources.This analysis only evaluates the separator venting source. With this application,the operator is requesting to decrease the permitted throughput of gas routed to and controlled by a flare from 75.4 MMscf/year to 11.7 MMscf/year.Additionally,the NGL skid has been removed from the facility.Thus,point 008 will be removed from the permit.As a result of the removal of the NGL skid,the entirety of the waste gas vented from the separators is routed to and controlled by an open flare during pipeline downtime.The permit will be updated to reflect this control scenario. Public comment will be required for this permit modification because new synthetic minor limits are being established.In other words,the facility emissions are now below the serious non-attainment threshold of 50 tpy. Self-certification for the first issuance of this permit was submitted on 07/07/2020 and approved on 07/08/2020.As discussed in this analysis,initial testing is still required,therefore the permit will be issued again as initial approval. Sections 04,OS&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑' 0 ❑ Title V Operating Permits(OP) 0000 0 0 0 0 Non-Attainment New Source Review(NANSR) ❑' ❑� Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration IPSO) 0 0 0 0 0 ❑ Title V Operating Permits(OP) 0 000 ❑ ODD Non-Attainment New Source Review(NANSR) ❑ ❑ • S2parecix'erring Emissions fnn•;fur;; SeNon 01-Administrative Information 'Facility Allis ID: 123 9pF09 009 County lant P SeMon 02-Equipment Description Details ', Detailed Emissions UntOescr Description. Natural gas venting from two andtwo(2)h Phase separators 1,2 M�'5,��"Agy'0";r Emission Control Oevice Description: Emissions from the two-phase separators and three-phase separators are routed to an open flare during pipeline dammoth. Requested Overall VOL&HAP Control Efficiency%: 95 haired Process Parameter - Gas meter i 5 ..,-.9.' Section 03-Processing Rate Information for Emisslom Estimates Primary Emissions-Separabr Actual Throughput= Mscf per year Requested Permit Umit Throughput= 11.7 MMscf per year Requested Monthly Throughput= MMscf per month Potential to Emit(PTO)Throughput= 1.1 MMscf per year Secondary Emiulom-Combustion DevIce(s)for Air Polka.Control Separator Gas Heating Value: 1485.8 Btu/scf Volume of waste gas emitted per 334.of it k liquids throughput scf/hbI Control Device Pilot Fuel Use Rate: 31 scth .'_MMscf/yr Pilot Fuel Gas Heating Value: 1485.75 etu/scf Section 04.Emtssiom Factors&Methodologies DescdPBon The two(2)wells atthe lnshWei!Pad produce to two(2)Mkt two-pbase separators.Biked liquid from the two-phase separators 1 routed to two(2)threephase separate.for further separation:The gas from the two-phase separators and three-phase separators tz commingled and routed to the openflare to be controlled during gas pipeline downtime.Skeepedfk pressurized two-phase separator gas samples were obtained from the Sligo 857-26-230 and Pat 0 Gold 857-35.20 wells on 09/07/201&The temperature and pressureof the sample are 105°F and 89 este respectively for the Sligo well and 106.8°F and 88 prig respectively for the Pot 0Gold we,The operator converted the mole %elo,es from the samples to weight%These wkulatiom are shown below.The most conmrva five totaIlLAIXweight%individual weight fraction to total HAP weight frzctloe ratio and molecular wei47 from each sample along with the displacement equation(shown below)wore used to estimaeemluimrs from this source. Pot O Gold BST-35-20 Sample Sligo 8.6726.23C Sample IMW I r'.:i1113/1b-cool Displacement Equation IMW I _-I Ib/Ib-mol Oisplacement Equation Ex=Ce,W"Xx/C Exa Or MW'Xx/C _ Mole% MW Ib/Ibmol Weight% Mole% MW Ih/Ibmal Weight% Helium - 0.0000 4.00 Helium 0.0000 4.00 CO2 1.7187 44.01 - CO2 1.7015 44.01 -. N2 0.7395 28.02 -' N2 0.7650 28.02 methane 61.9427 16.04 methane 62.2988 16.04 ethane 14.7700 30.07 - ethane 14.6039 30.07 Propane 12.4915 44.09 - propane 12.5559 44.03 isobuMne 1.3285 5012 -. isolatane 1.3035 58.12 n.butane 4.2436 58.12 n-butane 4.1211 58.12 isopentane 0.8325 .72.15 isopentane 0.7897 72.15 mpentane 0.9451 72.15 + .pentane 0.8676 72.15 cyclopentane 10565 70.13 cyclopentane 0.0509 70.23 n-Hexane 0.1302 86.18 ...n-Hexane 0:1669 86:18 cyclohexane 0.0730 44.16 cyclohexane 0.0668 - &1.16 Other hexanee 0.2756 0500 Other hexanes 0.2489 85.00 heptanes 0.2106 10020 heptanes 0.2022 :100.20 methyicyclohemne 0.0338 98.18 methylryclohexane 0.0365 98.18 224-TMP 0.0008 11422 224TMP 0.0041-- 114.22 Benzene 0.0459 70.11 - e 00417 ;7111 Toluene 0.0188 92.14 Toluene 01239 .92.. Ethyibenzene 0.0024 106.17 Ethylbemene 0.0027 .106.17 xylenes 0.0053 106.17 Xylenes 0.0057 106.17 C8+Heavies 10570 120.00 040 Heavies ...0.0627 120.00 Total Total .. Total Total VOC Mole 99 WICWt% VOC Mole% VOC wt% HAP Wt% HAP Wt% Emission Factors Separator Venting Uncontrolled Controlled Emission Factor 5eurw Pollutant (IL/MMscf) (Ib/MMzh) (Gas Throughpud (Gas Throughput) VOC ty s Benzene - a atulys5 Toluene , TWdelfirwelysls Ethylbenzene ., o'er...edges anairsts xylene 1 ' - Exteodd gas analysis .-Hexane f.r.m4044 n01)01 224TM0 gas analysh Primary Central Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 - 0.0075 APi'2 1944.2.5) PM2.5 0.0075 - AP 10/PM.2.t) sox 10000 (SO.) NOx 0.0680 AP$2 61 Flares(NOM CO 0.3100 _ AP-02 al Flares(CO) Pilot tight Emis5i0m Uncontrolled Uncontrolled Pollutant (Ib/MM9tu) Ib/MMscf Emssion Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 - 0.0075 '42)PM10/PM.2.5) PM2.5 0.0075 thm " M10/PM.2.5) Sox 0.0006 2-Z(S0,0 NO0 0.0080 NF,,,-. 'prof Flares(NOM) VOC 0.0054 7i,= 114.2-iVOCJ CO 03100 31.0%.-tui Flares(00) Section 05-Emissions Inventory Potential to Em0 Actual Emissions Requested Permit Omits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) )tom/year) (tons/year) (tons/year) (tons/year) )Ibs/month) PM10 0.07 -. .. , PM2.5 00/ 0.. 000 50v 'La 0.09 NOx 0r. r uu VOC . Potential to Emit Actual Emissions Requested Permit limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) f./year) 1150/year) (Ms/pearl I b/year) Besse e .-' -' '..19 Toluene =_ -. Ethylbeneene 1 0 _ xylene nelexane 224 TMP .. 2 of 4 C:\Users\hslaught\0esktop\1239F09\18WE1129.CP2 • Section 06-Regulatory Summary Analysis Regulation 3,Parts Ai B hogs-them o Regulation 7,Part D,Section ll.B,F Ittfittstm gets do.'t,i 5 Regulation 7,Part O,Section ll.B.Le (See regulatory applicability worksheet far detailed analysis) Section 0T-',Atha]and Periodic Samplinttand Testing Requirements Using Gas Throughputto Monitor Compliance Does the company use site specific emission factors based on a gmszmple to estimate emissions? This sample should represenithe gas outlet of the equipment covered under this AIRS ID,and should have been collected within one year of the application received date.However,lithe facility has • not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facilitt-wide permthed emissions of VOCgreater thanr equal to 4ot0ns per year m the ozone nonattainment area R r emissions g or greater than equal to 90 ton per year In the ozone attainment area, If yesethe permit will contain: -An"Initial Testing Requirement"to collecta site-sp ecificgas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission actors are less than or equal to the emissions factors established with this application. -A"Periodic Testing Requirement"to collecta site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application an an annual basis: Will the operator have a meter installer)and operational upon startup°MI.point?' If no,the pemth will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180 days). This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. �s Does the company request a control device effc ency greater than 95%for a Mare or combust on device? �._ G 3'hn ssWM Yves,the permit will contain initial and periodic compliance testing in accordance with P5 Memo 2002 .frielilifieRsfirttAffiy•lfsfeftiliq410,0:5,40,4144,5550151S4,50,:rtgrtr:11155,145A50951515.5MEM5155554155*;5•055550540151 4' Section 08-Technical Analysis Notes d " ..... be a production-od o eallulylltwo OGCC daducemth s hel y g 4130 names and A l nombers0 gas resultfollows:he Name:Poi O'Gold 8-de 6 3120,API:051234491g,.Eac one(iii Name Sligome,tfla Correll2 o,m05-1.The ex1 Bothwells 0,were fractured and oeganrdaltralhey beg COm4000a and no new,Ils have hi aaded.ishesthan 60.nce result Bass began l tA,,gust I,014,of the gal,,Aegoffth m pareto,aiaob(e to The exist 01 lion 7, b rlionILF4 ix or rh,theoetedslncepseybeganprodtob and nonewwels,eds been theacility.6nce tiled,(10 wellsban 4124etionalter August I,2014(0)open flare. This ofltnoLipl2tors is subfgRmCOAQCC Regulation OLifl St Sectionbull f.As hovedosntrol devices re required t be enclosed or approved as analtern alternative emission control equipment The controldevicef then p airs s one(I)open flare: control options a new request AO this appbeaboo The flare will be approved salt nxt'eetsededmntrol agreement in thlsssuance of the permit for the following reasons.. ()The operiflare isnot ntendedlo be used as the primary control deg.for the separators at this facility.According.the application;the gas produced by the separators will primarily be routed.a gas pipeline Only whenthe gas ppelnes unsomilabl&wfl(thes p ratorgasbe rootedm the°pen flare (i)The open flare ha a minim m control efficiency 00955S-for hydrocarbon emission and has a manufacturers design guarantee of 98%destrutton efficiency for hydrocarbons. (ill)The open flarewlloperaie with no visible emissions,Is equipped with an autognter and will be able to comply vdth the requirements ofRegulation 7,Patti),Sectionll.B. (iv)The open flare will not bessedmcoatml emissions from the crude oil orproduced water storage vessels at the facilty. Appropriate conditions willbe added to the permit in order nsu etheserequirements are meton an ongpngbays. 2.PSMemo15-03 was updated on January 31,2019,With this pdate,alternativeemission controlcant qupment must be 011201 a backup emission control on a temporary basis,natio exceed 1 month in a calendar year As a resul,the permit will contain a new ondt that requires operator.track the hours ofoperation of the open Rare and these hours do not exceed 744 hours(31 day month)ins calendar year.The operator has indicated they are capable of complying with require onto tr this new requirement. 3 According to the application,aflows-net, nstalleo and operational at the facility.This flow meter s s the total two-phaseseparator and three-phase separator gas that,s routed to and controlled by the flare 4.According to the operator,the samples presided In the application and used to calculate emiss are only representative of two.phaseseparator gas f tent°the flare These samples were obtained framthe two wells at this facility on 09/0]/2018.. The ap a indicated that the two.phate separator gas will bethe marority of the gas routed to the flare However,thtt permit covers both.o-phaseandthree-phase separator gas that is routed to the Rare As a result,the operator oil be required to obtain itial 5 pfethats represetatrve of commingled two phase and thee-phase separator gas in order to confirm the emission factors developedthroughths analysis eelher accuam of conservative.ltshauld be noted that the sample the.:: operator submitted as part of the self-ter-Ace-don for this pants sill only representative of two-phase separator gas:This further supports ttieneed to k phenitial testnggrementn the permit 5 There are novae r recovery thos(VRUs)on location for separator gas As a result the opera[ has idicated the produced gas from the separators iseith uteri to a gas gatherng pipeline orto the open flare dunngppel'ne downtime.Thegas routed to the pipeline is considered to have a 100%control efficiency and is not required to be metered As discussed above,a flow.meter)used to measure only the total volume ofzepararor gas that is routed to the open Aare. 6.With this application,p mitted emissions are now less than 40 toy.Asa result,perod.[wing will be removed from the permit as it is no longer warranted accordingtostandard engineering guidance. 7.CO emissions from this source are above PPM reporting thresholds.As.aresult,the permit will contain a limit on this pollutant This lmtnldes emissions associated with pilot light combustion B.A throughput limit.included in the permitfor plot light combustion.11,1 n010111s and calculthon methods for p,lothght combustion emissions are also included in the notes to permit holder.This informthons included inthe permit because plotlightemoa,a comb et the overall emissions fromths source.Addiuonaiiyit ismportat to include the information;because throughput tracksog and emission calculation methods are different than those used to tternate emissions based on the combustion ofs pars sue gas This clarity Is:(moo [.for amurately 069118ying..ual m at the faulty.It should be noted that the VOC I on factor associated with piletbght combustion is not included in perm because the roc waste ssi°ns emissans are 11141,ble(0.0004 thy)and do not impact the permitted lets. 9.Periodic apathy obsery ions are addressed by the O&M pin As a result,the permit does not contain periodcopacty testing It should be noted that Mensal opacity resting requiredin the firth issuance'of the permit was completed wrth the to certification that was submitted on 07/07/2020 and approved on 02)08/20200.5a result the.,Alba)opacity testing h sheen removed from the permit 10.The operator ndisated the openfiare used to control emissions from this source does not utl ny assst gas or supplemental fuel. 1i Traditionally,emission factors and errnsvons for separation equipment are determined using the weght%values and molecular weight information directly from the gas samples provided in the application.In this cases the operator chose to convert the molep values from the samplesntheapplotlon to ght%and use the total HAP we ght96,ndLvdeal weight fraction to total HAP weight fraction rb and molecular wightvaivasto calculate emissions.Using the most conservative weight%values directly from the tempter pr ded,the traditional method of oleo) on resulted nth'following emission factors:.Ii)VOA 21,746.5915/MMscf,(?i Benzene:94:7316/MMscf,(Iii)Toluene:5&0e lb/MMscf,(v)Ethyibenzene. 7.5716/MMscf,(v)Xylene:15.9116/MMscf,(2)'001111.:432.4416/MMscf and(Hi)224 IMP:12.2416/MMscf.The opeatorsealculations resulted in emission factors that are either conservative or negligibly differenithan the values calculated using standard methods.As a result,the ope rs estimations were accepted and tised for permitting purposes. 'ample 1111011tohfon the toluene emsson factor as follows:(0.8744'%Total IIAP(/(100)"(0.08438%toluene/0.81247%Total HAP)1(21.2581t0bmoi(1(379 scf/Ibm4I)'(IA00,000 act/MMfl asc 6292Ib/MMscf. 14 Eth?benzene,xyleneend 2,2,4-IMP emissions are below UPON reporting thresholds ti.e.12501b/year).As a result,emission factors for hese pollutants 0011 wt be included in the permit 13 Tradiaonatiy,the ideal gross heating throe listed on the gas sample(3499.78 Btufscf)would be fed for emission calculators In this se,the operator chose to use the govs real(wet bass)heat content(1425.758tu/sof)to cal Ite emissions.The operator prott ed the f llovnng reasoning for thingtheththan heat value I respectfully request use the Heating value we havede ated in the applithtion,approved by p and has beenuz df r the past two years for this facility.The value IS based on an accepted GPA method and is a vwfd calculation for heat content The"ideals heat.content istheorehcal for ideal gas and not"real",therefore:the teal wet basis calculated heat content has been used.This a how all of g rplusedth term lowest grand f h sake of constr.-try,rember,heyn80ot 00,eant tothe ve one term rower eat gvaas lue,see compliance tracking age.Theheathe cst nt Other equipment at used Mesh that-th eengiingmodlfred Busing tNtvalueaswell appropriate gro up set the ore Iowent.10,p"for ve long asn,eby the Iortheynowu content Yoenatu)gas shall seen ar en thaloter healing wine e(LE)oftt[hoe. e,00t gas useattcontentvseenaiion shall beverfied and maes aft leap opriaie Division upon Methods Reg,dloti,00ed in tsme 001.the5omtia.inlet oat doatif nldethelatethet of he tedpnth00twaheatn the combustion n0200toReich io melea of the tni like to besfiap0nshall.T vaporedand&waterde s not totge on upon request Regardless,rtLs the salue..H et bass mean you don't include the latent heat vaporeation of wasee nine wmbuetion products,wliicht0 meseemslikeifie hest approach.The ponzaton ofw is notgoing to ntrbutetothe production of NOx or CO and therefore should not be included inthosecalcuiations Based on the opfor sra soning and the indistinguishable difference in total emssons when using either value,he calculations provided by the. opera-tore/ere accepted for nem-Ming purposes. to The nonce A startup tor WAsource was submitted'on 1/17/202°As a result..requirement will be rernowd from this issuance of the permit 15.The operator was providedxnth a draft permit and APEN red.e 10,00000440114 permit issuance he operaor renewed both documents and provided comment.lhe orators comments and Division responses are awilathe inthe email record uploaded to Records Manager, section Os-scC Coding and Emissions Factors(For Inventory Use Only), AIRS Point) Process 1 SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 009 01 .. PM10 P M2.5 2 SO. NOx VOC CO Benzene tt Toluene hitts Ethylbenzene Xyiene n-Hexane 224 TMP :._. • 3 of C:\Users\hslaught\9esktop\1239FD9\18W E1129.CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements Id{bfi,-I V Im X'.Y'zt 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. 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)? l'i rea have saaadcated thlrtelraarcea IStr kl4eNaai-cl4 ilaaa,t&$icc 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, t?Source Requires an APEN.Go to the next question 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation3,Part B,Section 11.D.2)? Yes *..Source Requires a permit 1F:varrcc'iPlaB'Mros a(aeanat Colorado Regulation 7,Part 0,Section II 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? Yes "+=1Source is subject,go to next question S4aa'i.c 6 w I lzil ct E.0 kag,41$aO2..a'I,Pan il,"a2a$'oat m2.,(- Section 11.5.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Emissions Control(Optional Section) a. Is this separator controlled by a back-up or alternate combustion device.(i.e.,not the primary control device)that is not enclosed? IThe coaanz/ .1 via<;{sros eh'.s'Puxrnfars t,suiafcr 1 iea It ,.a$tvar I,V2O4 F5,Sa.a t, itB.,.r. Section II.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act,.,its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may," "should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. CDPHE Crude Oil Storage Tank(s) APEN Form APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store crude oil 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. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)website at:www.colorado.gov/pacific/cdphe/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: 1 8W 1126 AIRS ID Number: 123 / 9FD9 /005 [Leave blank unless APCD has already assigned a permi- and AIRS ID] Section 1 - Administrative Information Company Name': Enerplus Resources (USA) Corporation Site Name: Irish Well Pad Site Location Site Location: SWSE Sec. 26, T8N, R67W County: Weld NAICS or SIC Code: 1311 Malting Address: (Include Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 Contact Person: Kristin Van Hees Phone Number: 720-279-5515 E-Mail Address2: KVanHees@enerplus.com 1 Use the full,legal company name registered with the Colorado Secretary of State.Th h 'C•ffPany name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. �2 Th 89 Av COLORADO Form APCD-21O Crude Oil Storage Tank(s)APEN Revision 3/2019 1 Permit Number: 18WE 1126 AIRS ID Number: 123 /9FD9/005 [Leave biank unless APCD has already assigned a peer=it and AIRS ID Section 2 - Requested Action O NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under General Permit 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 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- • 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: Six, 400 bbl Crude Oil Tanks Company equipment Identification No. (optional): TANKS For existing sources, operation began on: 8/4/2018 For new or reconstructed sources, the projected start-up date is: 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 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes 0 No 805 series rules?If so, submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual 0 Yes ❑ No emissions≥6 ton/yr(per storage tank)? Av COLORADO Form APCD-21O Crude Oil Storage Tank(s)APEN - Revision 3;2019 2 Permit Number: 18WE1126 AIRS ID Number: 123 /9FD9/005 [Leave blank unless ARCD Las already a s i_i e permd and AIRS ID) Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Crude Oil Throughput: 120000 From what year is the actual annual amount? 2019 Average API gravity of sales oil: '-'37 degrees RVP of sales oil: -5 Tank design: J Fixed roof ❑Internal floating roof ❑ External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) TANKS 6 2400 7/2018 8/2018 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 -44918 Pot O'Gold 8-67-35-2C 0 05 • 123 -44921 Sligo 8-67-26-23C 0 0 0 5 Requested values will become permit limitations. Requested limit(s)should consider future growth, 6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Lotitude/Longitude or UTM) 40.626117/-104.858296 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet: (check one) ❑Upward O Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) Q Circular Interior stack diameter(inches): 48 Interior stack depth IDSquare/rectangle Interior stack width(inches): (inches): ❑Other(describe): Form APCD-21O Crude Oil Storage Tank(s)APEN - Revision 3/2019 3 I AV COLORADO COLORADO Permit Number: 1 8WE 1 1 26 MRS ID Number: 123 /9FD9/005 [Leave bunk imtess,a."C,D has already assignee;a hermit. C and A Ra l Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit (VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Type: Enclosed combustors Make/Model:Three Cimarron 48" ❑✓ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98+ Minimum Temperature: NA Waste Gas Heat Content: 2263.25 Btu/scf Constant Pilot Light: Q Yes ❑ No Pilot Burner Rating: 0.02 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: O Other: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —38 psig Describe the separation process between the well and the storage tanks: Gas and liquids from each well are sent to a 2-phase separator, gas goes to pipeline, liquids go to 3-phase heated separator, oil goes to oil tanks and water goes to water tanks. Redlines per updated application. (HDS 07/14/2020) T COLORADO Form APCD-210- Crude Oil Storage Tank(s) APEN - Revision 3/2019 4 I AS? K . Permit Number: 1 8WE 11 26 AIRS ID Number: 123 /9FD9/ 005 ;Leave blank unless APCD has aireacy assigned a permit a and AIRS iDI Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. 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 (%reduction in emissions) V0C Combustors 95% N0x CO HAPs Combustors 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor7 Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions Basis I Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 3.672 lb/bbl E&P Tanks 220.29 11.02 NOx 0.068 Ib/MMBtu AP-42 0.44 0.44 CO 0.31 Ib/MMBtu AP-42 1.99 1.99 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions8 Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 4.63E-3 lb/bbl E&P Tanks 555.2 27.8 Toluene 108883 7.26E-4 lb/bbl E&P Tanks 87.1 4.4 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 3.02E-2 lb/bbl E&P Tanks 3619 181 I 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 7 Attach crude oil 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. e Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Redlines per updated calculations. (HDS 07/14/2020) Aim COLORADO Form APCD-21O - Crude Oil Storage Tank(s) APEN - Revision 3/2019 5 I ,[i] .....7,7=.. Permit Number: 1 8V1/E 1 1 26 AIRS ID Number: 123 /9FD9/005 [leave".lank unless APCD has already assigned a permit h and A-SRS I'i'] 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 GP08, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP08. Lw, l2 ! (.9 /t Signature of Legally Authorized Person (not a vendor or consultant) Date Kristin Van Hees Sr. Environmental Specialist Name(print) Title Check the appropriate box to request a copy of the: ✓�Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 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 pp COLORADO Form APCD-210 Crude Oil Storage Tank(s) APEN - Revision 3/2019 6 I m ` M^`°"; ��, Hydrocarbon Liquid Loading APEN C Form APCD 208 Air Pollutant Emission Notice (APEN)and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks,etc.). In addition, the General APEN (Form APCD-2OO)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,gov/cdphetapcd. 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: 18WE1127 AIRS ID Number: 123 / 9FD9/ 006 [Leave blank unless APCD has already assigned a permit w and A:RS 1D Section 1 - Administrative information Company Name': Enerplus Resources(USA) Corporation Site Name: Irish Well Pad Site Location: Site Location SWSE Sec. 26, T8N, R67W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 Contact Person: Kristin Van Flees Phone Number: 720-279-5515 E-Mail Address2: KVanHees@enerplus.com ' Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.My changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 4,22 COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 3/2019 Permit Number: 18WE1127 AIRS ID Number: 123 /9FD9/006 [Leave blank unless APCD has already assigned a permit and A`QS ID] Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source ❑ Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ✓❑ Change permit limit ❑ Transfer of ownership' ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et 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: Truck Loadout of Crude Oil Company equipment Identification No. (optional): LOAD1 For existing sources, operation began on: 8/4/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? p Yes ❑ No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes 0 No emissions? Does this source load gasoline into transport vehicles? O Yes No Is this source located at an oil and gas exploration and production site? 0 Yes ❑ No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes Q No average? Does this source splash fill less than 6750 bbl of condensate per year? ❑ Yes O No Does this source submerge fill less than 16308 bbl of condensate per year? O Yes ❑ No Av��jj COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 2 L1 �„ Permit Number: 18WE1127 AIRS ID Number: 123 /9FD9/006 (Leave blank unless APCD has already assigned a Dermit=and AIRS ID; Section 4 - Process Equipment Information Product Loaded: ❑ Condensate Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 1 20000 bbl/year Actual Volume Loaded: 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 0 Saturation Factor: F 0.6 bulk liquid loading: 7 Molecular weight of True Vapor Pressure: 3.4 @7OF Psia @ 60 °F 50 lb/tb mol displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations.Requested timit(s)should consider future process growth. Ali AV COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 3 I m COLORADO Permit Number: 18WE1127 AIRS ID Number: 1 23 I 9FO9/006 [Leave blank unless APCD"_s already assigned a perrnit n and A.'�Ra iDi Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.626117/-104.858296 Discharge Height Above Operator Temp. Flow Rate Velocity Stack ID No. Ground level (SF) (ACFM) (ft/sec) (feet) r Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet: (check one) Q Upward ❑Downward ❑Upward with obstructing raincap ❑ Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter (inches): 48 ❑Other(describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. ❑� Loading occurs using a vapor balance system: Requested Control Efficiency: 100% Used for control of: VOC and HAPs Rating: MMBtu/hr Type: Fnr IncadCnmhuctnrs Make/Model:3 Cimarron 48" rn Combustion Device: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98+ % Minimum Temperature: NA F Waste Gas Heat Content: 2263.25 Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: 0.02 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: Redlines per updated application and email. (HDS 07/14/2020) pp CCOLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 4 I m permit Number: 18WE1127 AIRS ID Number: 123 / 9FD9/006 Ft eave blank unless APC0 has already assigned a permit 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 Method(s) Control Efficiency (%reduction in emissions) PM SO. NO. CO VOC Vapor Balance and Combustors 95% HAPs Vapor Balance and Combustors 95% Other: ❑ Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 • Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOX NOx 0.068 lb/MMBtu AP-42 0.01 0.01 CO 0.31 lb/MMBtu AP-42 0.03 0.03 VOC 2.4 lb/1000 gal AP-42 6.04 0.3 Non-Criteria Reportable Pollutant Emissions Inventory I Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Basis Number Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 Toluene 108883 Ethyl benzene 100414 Xylene 1330207 n-Hexane 110543 2,2,4- Trimethylpentane 540841 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. AV cotaAAoo Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019 5 I Redlines per updated application and email. (HDS 07/14/2020) Permit Number: 18WE1127 AIRS ID Number: 123 /9FD9/006 [Leave blank unless APCD nas already assigned a permit 4 and AIRS€0] 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 will be operated in full compliance with each condition of General Permit GP07. 12 i911`‘ Signature of Legally Authorized Person(not a vendor or consultant) Date Kristin Van Hees Sr. Environmental Specialist Name (print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 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/apcd pp COLORADO Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 3/2019 6 I L� COLORADO C°PHE Gas Venting APEN -- Form APCD-211 CO 40 Air Pollutant Emission Notice (APEN) and .f Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g.amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at: www.colorado.govlcdphe/aped. 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: 18WE1129 AIRS ID Number: 1213/9FD9 /009 [Leave blank unless APCD has already assigned a permit v and AIRS ID] Section 1 - Administrative Information Company Name': Enerplus Resources (USA) Corporation . Site Name: Irish Well Pad Site Location Site Location: SWSE Sec. 26, T8N, R67W Weld County: NAICS or SIC Code: 1311 Mailing Address: 950 17th Street, Suite 2200 (Include Zip Code) Denver, CO 80202 Contact Person: Kristin Van Flees Phone Number: 720-279-5515 E-Mail Address2: KVanHees@enerplus.com ' Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on alt documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. COLORADO Form APCD-211 Gas Venting APEN - Revision 3/2019 1 I COLORADO Permit Number: 18WE 1129 AIRS ID Number: 1213/9FD9/009 [Leave blank ucte=:,ARCD mas aiready assigned a permit a and AIRS`Dl Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source -OR- ❑✓ MODIFICATION to existing permit(check each box below that applies) Q Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit p Change permit limit ❑ 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 E 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: Flaring of Separator Gas when pipeline is unavailable Company equipment Identification No. (optional): Separator For existing sources, operation began on: 8/4/2018 For new, modified, or reconstructed sources, the projected start-up date is: D Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Witt this equipment be operated in any NAAQS Q Yes ❑ No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes 0 No considered a Major Source of(HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, 0 Yes ❑ No Section XVII.G? [� COLORADO Form APCD-211 Gas Venting APEN - Revision 3/2014 2 I A COLORADO Permit Number: 18WE1129 129 AIRS ID Number: 1213/9FD9/009 (Leave blank unless APCL na- already assigned a pe.rndt d and AYRS I0] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Q Yes ❑ No Vent Gas 1485.75 BTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: 11 .7 MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput 5 Requested : blUbyear Actual: bbl/year Process Parameters5: Molecular Weight: 26.26 VOC(Weight%) 41.58 Benzene(Weight%) 0.1365 Vented Gas Toluene(Weight%) 0.0908 Properties: Ethylbenzene(Weight%) 0.0118 Xylene(Weight%) 0.025 n-Hexane(Weight%) 0.6242 2,2,4-Trimethylpentane(Weight%) 0.0193 Additional Required Information: 2 Attach a representative gas analysis (including BTEX ft n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX a n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. COLORADO Form APCD-211 Gas Venting APFN - Revision 3/2019 3 OOL"""N..u!F b Suna•wr• Redline per application and email. (HDS 07/15/2020) Permit Number: 18WE1129 AIRS ID Number: 1213/9FD9/009 [Leave blank unless APCD has already assigned a permit#and MRS iD] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.626117/-104.858296 Discharge Height Operator Temp. Flow Rate Velocity Stack ID No. Above Ground Level (SF) (ACFM) (ft/sec) (Feet) Flare -10 1000 Variable Variable Indicate the direction of the stack outlet: (check one) ❑ Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other (describe): Indicate the stack opening and size: (check one) ,/❑Circular Interior stack diameter(inches): 4 ❑Other(describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Size: Make/Model: O VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Type: Open Flare Make/Model: Steffes rm Combustion LLiDevice: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98+ Minimum Temperature: NA Waste Gas Heat Content: 1485.75 Btu/scf Constant Pilot Light: p Yes ❑ No Pilot burner Rating: 0.02 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: AirCOIOR�DO Form APCD-211 Gas Venting APEN - Revision 3/2019 4 m Redline per email. (HDS 07/15/2020) Permit Number: 18WE1129 AIRS ID Number: 1213/9FD9/009 [Leave bank uniess A?CD has aiready assigned a permit r 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 Method(s) Control Efficiency (%reduction in emissions) PM sox NOx CO VOC Open Flare 95% HAPs Open Flare 95% Other: From what year is the following reported actual annual emissions data? 2020 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 Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOX NOx 0.068 lb/MMBtu AP-42 0.6 0.6 CO 0.31 Ib/MMBtu AP-42 2.72 2.72 VOC 28,805.22 lb/MMscf Mass Balance 168.51 8.43 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 Emissions6 Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 94.60 lb/MMscf Mass Balance 1,106.8 55.3 Toluene 108883 62.92 r lb/MMscf Mass Balance 736.2 36.8 Ethylbenzene 100414 8.19 lb/MMscf Mass Balance 95.8 4.8 Xylene 1330207 17.29 Ib/MMscf,Mass Balance 202.3 10.1 n-Hexane 110543 432.49 lb/MMscf Mass Balance 5,060.2 253 2,2,4- 540841 13.38 Ib/MMscf Mass Balance 156.6 7.8 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. COLORADO Form APCD-211 Gas Venting APEN - Revision 3/2019 5 1 A COLORADO wF.A D Redlines per email and updated calculations. (HDS 07/15/2020) I I Permit Number: 18WE1129 MRS ID Number: 12131 9FD9/009 (Leave blank unless APCD nas already assigned a permit C and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 1,,/\ „ ) 12- RP /I °! Signature of Legally Authorized Person (not a vendor or consultant) Date Kristin Van Flees Sr. Environmental Specialist Name(please print) Title Check the appropriate box to request a copy of the: ID Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to; For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd Form APCD-211 Gas Venting APEN - Revision 3/2019 6 I AV COLORADO E"`AD Hello