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Home My WebLink About20201699.tiff a . ,...# COLORADO Department of Public Health&Environment RECEIVED Weld County - Clerk to the Board MAY 0 5 2020 1150O St PO Box 758 WELD COUNTY Greeley, CO 80632 COMMISSIONERS April 22, 2020 Dear Sir or Madam: On April 23, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Mallard Exploration, LLC - Green Teal Fed Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I ,7 No-iv Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director Point :O c Rev;er,J «:mem) no-K)pw(5ri/ER/CH/cw), 2020-1699 6/1O2-0 o6(1M) 6/03/2O MCM�M Air Pollution Control Division • 4' -'6*----:,---44° Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Mallard Exploration, LLC - Green Teal Fed Pad - Weld County Notice Period Begins: April 23, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Mallard Exploration, LLC Facility: Green Teal Fed Pad Well Production Facility SESW of Section 34, Township 8N, Range 60W Weld County The proposed project or activity is as follows: Mallard Exploration, LLC is requesting permit coverage for four (4) crude oil storage vessels, two (2) produced water storage vessels and hydrocarbon liquid loadout at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE1060, 19WE1061 and 19WE1062 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 I I ateiCOLORADO Department of Public Fioalt%b Envir*nment Denver, Colorado 80246-1530 Department of Public 2 I Health B Environment D Ph E Crude Oil Storage Tank(s) APEN " ' Form APCD-210CO Air Pollutant Emission Notice(APEN)and 5 9 Application for Construction Permit P1 All sections of this APEN and application must be completed for both new and existing facilities,including APEN updates.An application with missing information may be determined incomplete and may be returned or result in longer application processing times.You may be charged an additional APEN fee if the APEN Is filled out incorrectly or is missing Information and requires re-submittal. This APEN is to be used for tanks that store 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.Rov/Dacific/cdDhe/air-Dermits. 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, il.C.for revised APEN requirements. AIRS ID q Permit Number: / l l e f o w Number. I / %l en, [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 Administrative Information Company Hamel: Mallard Exploration, LLC Site Name: Green Teal Fed Pad Site Lacatbn: Site Location SESW 34 8N60W County: Weld 40.612876,-104.081402 NAicS or SIC Code: 211111 Mailing Address: 1400 St. Suite 300 (Include Zip Code) Denver, CO 80202 Contact Person: Erin Matthews Phone Number: 720-543-7959 E-Mail Address2: ematthews@mallards 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.My changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APED via e-mail to the address provided. 416149 law C$€ORA0Q Form APCD-21O Crude Oil Storage Tank(s)APEN Revision 712018 1 I AV Permit Number: 1a E woo AIRS ID Number: IAMAI t [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 2 Requested Action ❑i NEW permit OR newly-reported emission source Q Request coverage under traditional construction permit ❑ Request coverage under General Permit GPO8 If General Permit coverage is recµsested,the General Permit registration fee of S312 50 must be submitted along with the APEN filing fee. ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit O Transfer of ownerships O Other(describe below) -OR- [] APEN submittal for update only(Note blank APENs will not be accepted) -ADornorw,Pairr Arnows- ❑ 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: Crude Oil Storage Tanks Company equipment Identification No.(optional): Crude Oil Tanks 1-4 For existing sources,operation began on: NA For new or reconstructed sources,the projected start-up date is: 7/10/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at O Exploration&Production(E&P)site ❑ Midstream or E&P)site Will this equipment be operated in any NAAQS nonattainment area? es 4 -- No Are Flash Emissions anticipated from these storage tanks? O Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes a 805 series rules?If so,submit Form APCD-105. No Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual Yes ❑ No emissions a 6 ton/yr(per storage tank)? j 1. c ?V , tic u. • HD3 OS I (70t4) COtO11ADO Form APCD-210 Crude Oil Storage Tank(s)APEN-Revision 7/2018 2 I Permit Number: 9 i C AIRS ID Number: ti /404.4/ OU% [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 4-Storage Tank(s)information Actual Annual Amount Requested Annual Permit Limits (bbllyear) Obi/year) L.Clude Oil Throughput `S3't3, 'i Project( From what year is the actual annual amount? Average API gravity of sales oil: 36.87 degrees RVP of sates oil: 5.27 Tank design: Q Fixed roof O Internal floating roof ❑External floating roof Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Storage ax of Stowe Tank Recent Storage Vessel in Production t Tank ID Vessels in Storage Tank (bbl) Storage Tank(month/year) (monthlyear) 101;e4.01;51 1-4 4-Crude Oil Tank ,2og> 500— May 2019 July 2019 ?pi 4.tx 5#0 14i pea Wells Serviced by this Storage Tank or Tank Battery'(E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 -46181. GREEN TEAL FED 34-27-16HN 05 -123 -4617+ GREEN TEAL FED 34-27-15HN ® . S Requested values wilt become permit(imitations.Requested limit(s)should consider future growth. 6 The MP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 -Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.612876,-104.081402 Operator Stack Discharge Height Above r Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACM) (ftlsec) 1-3 25.25 800-2000 varies varies Indicate the direction of the stack outlet:(check one) Q Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size:(check one) Q Circular interior stack diameter(Inches): 48" []Square/rectangle Interior stack width(inches): Interior stack depth (inches): ❑Other(describe): Asirtok0#r.40 Form APCD-210 Crude Oil Storage Tank(s)ADEN• Revision 712018 3 ) ,tt%#'C rof tihAlx &kJ J is,A 0411 toL3 Permit Number: Vtkui. 090 AIRS ID Number: i7" / / cwt [Leave blank unless APCD has already assigned a permit#and MRS ID] Section 6-Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): % Pollutants Controlled: V0C, HAP Rating: 11.7 MMBtu/hr Type: ECD Make/Model:Cimarron 48" ECD Q Combustion Requested Control Efficiency: 95 S Device: Manufacturer Guaranteed Control Efficiency: 99 5 Minimum Temperature: 800 degF Waste Gas Heat Content Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: 0.017 MMBtu/hr Description of the closed loop system: O Closed Loop System Pollutants Controlled: ❑ Other. Description: Control Efficiency Requested: S Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? Varies psis Describe the separation process between the well and the storage tanks: 3-phase HLP separator 3-phase heater treater vAt._ treW14itat� . via 11.4)LO coaon�DO Form APCD-210 Crude Olt Storage Tanks)APEN-Revision 7/2018 4 ) V f' ""_ Permit Number: ( to iii AIRS ID Number: i'3 ,m44 (Leave blank unless APCD has already assigned a permit C and AIRS ID) 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 Methods) Efficiency (dr reduction in emissions) VOC ECD - 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor? Actual Annual Emissions Emission Limitts)s Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions° Emissions Emissions .etc.) (tons/year) (tons/year) (tons/year) (tans/year) VOC 3.20. Ib/bbi APCD l•i .t ,t„cr.0 'VA.° NOx 0.068• ib/MMBtu AP-42 t.c3 ;.0 t.e n.t CO 0.31 . Ib/MMBtu AP-42 q. is 4.c 4.S Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Servke(CAS) uncontrolledUnits (AP-42, Emissions Emissions8 Number Basis kik,etc.) (pounds/year) _ (pounds/year) Benzene 71432 0.046 ` Ib/bbi APCD tSi.55 `a Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.245 . lb/bbl APCD N.-4%So% 4,I4S 2,2,4- 540841 Trfmethylpentane S Requested values will become permit limitations.Requested limits)should consider future growth. 7 Attach crude oft laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. ?NceiXts4.4 ,,( r '(- tiCt `or .. RS oilisitoto mow COLORADO Form APCD-21O Crude Oi!Storage Tank(s)APEN- Revision 7/2018 5 I AffliTr Permit Number: AIRS ID Number: / / let.4-1F. rtt,'r • it** <X)( [Dave blank unless APCO has already assigned a permit#and AIRS ID] Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GPM, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. John Tonello Digitally 1s 829 0 20:10 Tondo 13/29/2019 Signature of Legally Authorized Person(not a vendor or consultant) Date Jon ToneIto CEO 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 httas://www.colorado.rtov/cdphe/apcd Alup COtaseoo Form APCD-210 Crude Oil Storage Tank(s)ADEN•Revision 7/2018 6 Produced Water Storage Tankif 't' AL CDPHE 10 APEN - Form APCD-207 rt e CO Air Pollutant Emission Notice(APEN)and N` ig Application for Construction Permit Ali sections of this APEN and application must be completed for both new and existing facilities,including APEN updates.An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks,condensate storage tanks,hydrocarbon liquid Loading,etc.). In addition,the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at:www.colorado.ocov/pacific/cdDhe/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. AIRS ID Permit Number: iq we Number: (1 /AMA/cc 2. [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name: Mallard Exploration, LLC Site Name: Green Teal Fed Pad Site Location Site Location: SESW 34 8N60W County: Weld 40.612876,-104.081402 NAICS or SIC Code: 211111 Mailing Address: 1400 16th. Suite 300 (Include Zip code) Denver, CO 80202 Contact Person: Erin Mathews Phone Number: 720-543-7959 E-Mail Address2: emathews@matianiexpkuation.com 'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 4161`!7 Mir cotoe.,00 Form APCD-2O7 Produced Water Storage Tank(s)APEN Revision 7/2018 1 { :7,1-7-1—t-, Permit Number: tsi AIRS iD Number: t / 0, (leave blank unless APED has already asstgned a permit g and MRS tO) Section 2-Requested Action Q NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP05 O GPM If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFIICATiON to existing permit(check each box below that applies) ❑ Change in equipment O Change company names ❑ Change permit limit O Transfer of ownership' ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -Aoomorta PERMIT AMOK- • 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: Produced Water Storage Tank Company equipment Identification No. (optional): Produced Water Tanks 1-2 For existing sources,operation began on: NA For new or reconstructed sources,the projected start-up date is: 07/10/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: f Exploration&Production(E&P)site O Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQ5 nonattainment area? Q Yes O No Are Flash Emissions anticipated from these storage tanks? Q Yes O No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes 0 No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? O Yes 0 No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes O 805 series rules?If so,submit Form APCD•t05. No Are you requesting a 6 ton/yr V0C emissions(per storage tank),or are uncontrolled actual Yes �b emissions a 6 ton/yr(per storage tank)? If!""` �CQ Form APCD-207 Produced Water Storage Tank(s)APEN - Revision 7/2018 2 1 �" !.! v„,,jowc ?e4 oouc�aO Fiber Permit Number: tct u3t=- tokak MRS ID Number. EtA / / t [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 4-Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbllyecr) tbblfyear) Produced Water Throughput: 1541-1`j -Loo: From what year is the actual annual amount? Project Tank design: ©Fixed roof O Internal floating roof O External floating roof Storage g 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 ly'/I (bbl) Storage Tank(month/year) (month/year) j,ac, PW1&2 2 X 500 BBL Produced Water ito —500"" May 2019 July 2019 j Q Wells Serviced by this Storage Tank or Tank Battery'(E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 -46177 GREEN TEAL FED 34-27-15HN ❑� 05 -123 -46182 GREEN TEAL FED 34-27-16HN ✓❑ - - 0 5 Requested values will become permit limitations.Requested limits)should consider future growth. 'The EDP Storage Tads APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5-Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.612876/-104.081402 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) NA NA NA NA NA Indicate the direction of the stack outlet:(check one) p upward ['Downward 0 Upward with obstructing raincap ❑Horizontal ['Other'(describe): Indicate the stack opening and size:(check one) A Circular Interior stack diameter(Inches): 48" [�Square/rectangle Interior stack width(Inches): Interior stack depth(Inches): O Other(describe): -ka,1",L5 Pc-1 OVA-1441A 9b1,`c \DA - AIORADO Form APCO-2O7 Produced Water Storage Tank(s)APEN-Revision 7/2018 3 I i1 '.- Permit Number: ta1tC t1 AIRS ID Number: ( /ADAA/ar .�.. (Leave blank unless APCD has already assigned a permit z and AIRS ID) Section 6-Control Device Information O 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: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC, HAP Rating: 11.7 MMBtu/hr Type: HVECD Make/Model:Ci ma rron 48" combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 99 Minimum Temperature: 500-1200 Waste Gas Heat Content: Near, Stu/scf Constant Pilot Light: Q Yes ❑ No Pilot Burner Rating: 0.017 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other. Description: Control Efficiency Requested: % 3"‘"4- Kre 'Pb NDS azy Leto Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? Varies psig Describe the separation process between the well and the storage tanks: 3-phase HLP Separator and 3-phase heater treater Form APCD-2O7 Produced Water Storage Tank(s)APEN-Revision 7/2018 4 1 APP 2 M, Permit Number: (etmx IMP AIRS ID Number: i /Aam/ not, (Leave blank unless APCD has already assigned a permit#and AIRS 101 Section 8 -Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(X reduction): Overall Requested Control Pollutant Description of Control Alethod(s) Efficiency (%redaction In emissions) VOC t co I►s NOx CO HAPs EGO as Other: From what year is the following reported actual annul(emission data? Projected Criteria Pollutant Emissions inventory Requested Annual Permit Emission Factor7 Actual Annual Emissions Emission Lhslit(s)3 Pollutant Uncontrolled units Uncontrolled Controlled Uncontrolled Controlled units (AP-42, Emissions Emissions Emissions Emissions Bash Mfg.,etc.) (tons/yeor) (tons/year) (tons/year) (tons/year) VOC 0.262• lbs/BEIL State Factor L'S>ki 1.t9 tu,.i 1=s1 NOx ()etas Aj's-Kt O.Vs o.t'a s 1s"t +cs.11. — CO is ii r+,a*+sks7 K7, 151 1.51 vOr IAA Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor7 Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissionsa Number Basis Mfg-,etc.) (pounds/year) (Ponds/Year) Benzene 71432 0.007 Ibs/BB! State Factor tt + ,} Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.022, ibs/BBL State Factor Vti -S teK.H 2,2,4- 540841 Trimethylpentane 5 Requested values wilt become permit Limitations.Requested limits)should consider future growth. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. a Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. 4,1toto Caro*AR0 Form APCD-207 Produced Water Storage Tank(s)APEN-Revision 7/2018 5 I `" '� Permit Number: tCl l4)%ok AIRS iD Number: its / / cot_ - (leave blank unless APCD has already assigned a permit#and AIRS ID) Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GPOS or GPO8, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. John TonesnJ 0�201s08.2908:200:4 John 7neBo -06'00' 8/29/2019 Signature of Legally Authorized Person(not a vendor or consultant) Date John Tonel[o CEO Name(print) Title Check the appropriate box to request a copy of the: 0 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, N.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$312.50,if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692.3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment httns://www.colorado.stov/cdphe/apcd wow COLORADO Form APCD-207 Produced Water Storage Tank(s)APEN-Revision 7/2018 6 I C D P N E Hydrocarbon Liquid Loading APEN Form APCD-208 v CO Air Pollutant Emission Notice(APEN)and Application for Construction Permit •5111$ AU sections of this APEN and application must be completed for both new and existing facilities,includ' EN updates.An application with missing information may be determined incomplete and may be retu It in longer application processing times. You may be charged an additional APEN fee if the APEN is filled ou incorrectly or is missing information and requires re-submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g.amine sweetening unit,glycol dehydration unit, condensate storage tanks,etc.).In addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of ail available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.colorado.elov/cdohe/aacd. 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: /' WE 10 Z AIRS ID Number: f7 /444/ 3 [Leave blank unless APCD has already assigned a permit#and AIRS 1D[ Section 1 -Administrative Information Cry Nam': Mallard Exploration, LLC Site Name: Green Teal Fed Pad Site Location: Site Location SESW 34 8N60W County: Weld 40.612876,-104.081402 NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 1400 16th St. Suite 300 Denver, Co 80202 Contact Person: Erin Mathews Phone Number: 720-543-7959 E-Mail Address2: .mathewsemauardexporamn.com • 1 Use the fuU,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invokes will be issued by the APCD via e-mail to the address provided. 416148 coLaaaao Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 7/2018 1 ► A Permit Number: 1t I- MRS ID Number: ( 91"4/tiOE (Leave blank unless APCD has already assigned a permit#and AIRS IDi Section 2 -Requested Action p NEW permit OR newly-reported emission source Q Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested,the General Permit registration fee of 5312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(cheek each box below that applies) ❑ Change fuel or equipment O Change company name3 ❑ Change permit limit O Transfer of ownership's ❑ Other(describe below) ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDMONAL Pamir AtnoNis- ❑ Limit Hazardous Air Pollutants(RAPS)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: Please Permit with Individual permit for potential load out. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3-General Information General description of equipment and purpose: Crude truck load out Company equipment Identification No. (optional): NA For existing sources,operation began on: NA For new or reconstructed sources,the projected start-up date is: 7/10/2019 Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes O No is this equipment located at a stationary source that is considered a Major Source of(HAP) O Yes 0 emissions? No Does this source load gasoline into transport vehicles? O Yes El No is this source located at an oil and gas exploration and production site? 0 Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual Yes „, average? 14 110.4 Does this source splash fill less than 6750 bbl of condensate per year? a Yet:Wio Does this source submerge fill less than 16308 bbl of condensate per year? O Yes Q No cotoRAuo Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 7/2018 2 I Ell ""° tit ACS c io Cok "i OA'. N 135 "3``(Jwtt? Permit Number: tG1 uDe i+ Z. AIRS ID Number: I7.s 1 / a 3 (Leave blank unless APC0 has already assigned a permit#and AIRS ID) Section 4-Process Equipment information Product Loaded: O Condensate [] Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: sg4tiw� ( bbl/year Actual Volume Loaded: I - jot ! 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 .F Saturation Factor: bulk liquid loading: Molecular weight of lb/lb-mot True Vapor Pressure: Psia�' *F displaced vapors• If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: NA bbl/year Actual Volume Loaded: NA bbl/year Product Density: NA lb/ft3 Load Line Volume: NA ft3/truckload Vapor Recovery Line Volume: NA ft3/truckload 5 Requested values will become permit limitations.Requested limits)should consider future process growth. Gr tic4 1s iLcl ti0 L 3 p cotoRsao Form APCD-2O8 Hydrocarbon Liquid Loading APEN Revision 7/2018 3 I Permit Number: t t ,L AIRS ID Number: n tt rA044 r [Leave blank unless APCD has already assigned a permit#and AIRS IDJ Section 5 -Stack Information / Geographical Coordinates i a1 r',�! f (Latitude/Longitude or UTM) red eG e*'f LAI% Nae)75% NA Lo4,1G' -tom t rosz. Discharge Height Above Operator Temp. Flow Rate Velocity Ground Level Stack ID No. r (ACFM) (ft/sec) met) NIA 25.2 5 — aps,cs Indicate the direction of the stack outlet:(check one) ®Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size:(check one) Circular Interior stack diameter(inches): 4%'I ❑Other(describe): Section 6-Control Device Information ,9_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: Used for control of: vC t Rating: 11.1- MMBtu/hr Combustion Type: C�,«.*�t�,�>< Make/Model: Lk?: FC.-b Device: Requested Control Efficiency: 't5 % Manufacturer Guaranteed Control Efficiency: 91 Minimum Temperature: j 'F Waste Gas Heat Content: 2,'$s Btu/scf Constant Pilot Light: p. Yes O No Pilot Burner Rating: mot-4. MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: H‘) O-1 tkcitvZ t Oi DC aDO Form APED-2O8 Hydrocarbon Liquid Loading APEN Revision 7/2018 4 I ® Permit Number: tctt.,to€t apt AIRS ID Number: iZ i ! /t szt [Leave blank unless APCD has already assigned a permit#and MRS iDi 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(3 reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in*missions) PM SOx NOx CO VOC °l5 HAPs EC r-4 41 Other. ❑� Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane El Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL El Crude e 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported=tool armuol emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions6 Emissions Emissions Basis MJ .,etc.) (tons/year) (tans/year) (tons/year) (tars/year) PM SOX NOx C> + A?' ts.fl 'y n CO v. 4V-N"i— O.tg. €?.IS OAS 0.45" VOC 0.104 - lb/ElBl. State Factor y .,5q o.ts t€c, ca.4n Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical NameAbstract Source Uncontrolled Controlled UncontrolledUnits Emissions Emissions° service aasfs (AP-42, (pounds/year) (pounds/year) Benzene 71432 0.00018 ` Ibibbl State Factor q �, Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.0016. lb/BBL State Factor gyt.l _ 1:4.t 2,2,4 540841 Trimethylpentane Other: 5 Requested values will become permit limitations.Requested limits)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. Ayr Cotox ADe Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 7/2018 5 I •t Dos Permit Number: iatt,vE 10427,- AIRS ID Number: i121/ / [Leave blank unless APCD has already assigned a permit#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.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. John Tonei.o Digitally te 2019008.2908:19:01 X00' 8/29/2019 Signature of Legally Authorized Person(not a vendor or consultant) Date John Tonelio CEO • Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Q 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.Rov/cdphe/aped cottriADo Form APED-208 Hydrocarbon Liquid Loading ADEN Revision 7/2018 6 I AT" C �.;-L. COLORADO 4' Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE 1060 Issuance: 1 Date issued: Issued to: Mallard Exploration, LLC Facility Name: Green Teal Fed Pad Plant AIRS ID: 123/A0AA Physical Location: SESW SEC 34 T8N R60W County: Weld County Description: Well Production Facility Equipment or activity,subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment'Description Description ID Four (4) 500 barrel fixed roof crude oil Crude Oil Enclosed 001 storage vessels connected via liquid Tanks 1-4 manifold. Combustor(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 10 .... COLORADO COLORADO I A:4---46.. Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued,by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION!LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits; Facility AIRS Tons per Year Emission Equipment ID Point pM2.5 NOX VOC CO Type Crude Oil 001 --- 1.0 28.0 4.5 Point Tanks 1-4 -Note:See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 10 �Anik �.Vt. COLORADO 1p A., Air Pollution Control Division �i Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Crude Oil 001 Enclosed Combustor(s) VOC and HAP Tanks 1-4 PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits }r a. Facility AIRS Equipment a Process Process Parameter Annual Limit ID Point Crude Oil 01 350,000 barrels Crude Oil 001 Throughput Tanks 1-4 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 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and Page 3 of 10 aCOLORADO Air Pollution Control Division CDPHE Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020,The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the..Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation, 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator -of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING & MAINTENANCE REQUIREMENTS 17. 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 18. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator must complete site specific sampling including a compositional analysis of the pre-flash Page 4 of 10 COLORADO • Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado pressurized crude oil routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. The pre-flash pressurized crude oil sample must be obtained from the outlet of the heater treater. Testing must be in accordance with the guidance contained in PS Memo 14-03. Results of testing must be used to determine site-specific emissions factors (in units of lb/bbl crude oil throughput) for VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane using Division approved methods. Results of site-specific sampling and analysis must be submitted to the Division as part of the self-certification. The operator must submit to the Division, within 60 days of completion of site-specific sampling or a timeframe as agreed to by the Division, a request for permit modification to use the site-specific emission factors developed through this analysis to estimate emissions and demonstrate ongoing compliance. Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number, 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. Page 5 of 10 ry. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B). 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 administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. Page 6 of 10 a44;.i.; - COLORADO -'.-4-41 V Air Pollution Control Division CD E Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description =Issuance 1 This Issuance Issued to Mallard Exploration,LLC Permit for four (4) 500 barrel crude oil storage vessels ata new synthetic minor oil and gas well production facility. Page 7 of 10 COLORADO 4-41 Air Pollution Control Division .. COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exc.eedance 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:// w.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. Uncontrolled Controlled AIRS Pollutant CAS # Emissions Emissions Point - (lb/yr) (lb/yr)° Benzene 71432 16,100 805 001 n-Hexane 110543 85,750 4,288 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 OO1: Process O1: Crude Oil Throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 5.53x10-3 5.53x103 AP-42 Chapter CO 2.52x10-2 2.52x10-2 13.5 VOC 3.2 1.6x1O' CDPHE PS Memo 71432 Benzene 4.6x10-2 2.3x10-3 14-03 110543 n-Hexane 2.45x10-1 1.225x102 Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-03 for crude oil storage vessels. The NOx and CO emission factors in the table Page 8 of 10 �r�.�/_ COLORADO .,,,, i.4 t Air Pollution Control Division 7iL Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 3535 Btu/scf and GOR of 23 scf/bbl. Actual emissions are 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 Factors Emission Factors Source lb/MMscf lb/MMscf NOx 100.19 100.19 AP-42 Chapter CO 456.75 456.75 13.5 Note: The NOx and CO emission factors in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat content of 1473.4 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot gas. Pilot light gas fuel flow is based on a constant rate of 11.538 scf/hr per enclosed combustor. There are total of three enclosed combustors used to control emissions. As a result, the total pilot light gas fuel flow is 34.614 scf/hr Total actual emissions are obtained from the sum of,emissions resulting from the storage vessels and the combustion of waste gas from the storage vessels (Process 01) and the combustion of pilot light gas (Process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most-recent annual fee invoice to determine the APEN expiration date forteach 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 arid;associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a -Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, °2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971/oil-and- natural-gas-sector-emission-standards-for-new-reconstructed-and-modified-sources 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane Et Total HAP PSD Synthetic Minor Source of: VOC Page 9 of 10 grCOLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MALT 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 Air Pollution Control Division CDPHE Department of Public Health 8 Environment • Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE 1061 Issuance: 1 Date issued: Issued to: Mallard Exploration, LLC Facility Name: Green Teal Fed Pad Plant AIRS ID: 123/A0AA Physical Location: SESW SEC 34 T8N R60W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment a Equipment Description ID Point Description Produced Two (2) 500 barrel fixed roof produced Enclosed Water 002 water storage vessels connected via liquid Combustor(s) Tanks 1-2 manifold. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 9 M,M- COLORADO ill '� Air Pollution Control Division I COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type Produced Water Tanks 002 --- 0.4 1.4 1.7 Point 1-2 Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 9 %.,...., COLORADO COLORADO • -'IJ Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Produced Water Tanks 002 Enclosed Combustor(s) VOC and HAP 1-2 PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment, Process Parameter Annual Limit ID Point Produced Produced Water Water Tanks 002 . 200,000 barrels 1-2 Throughput The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other Page 3 of 9 elp y COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas 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 17. 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 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements Page 4 of 9 CNvMs COLORADO 4 Air Pollution Control Division COPHE Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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. 21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). 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 Page 5 of 9 a _v.:, COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 operators 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 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 Page 6 of 9 COLORADO 41":6-!---411. Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Issuance Date Description Issuance 1 This Issuance Issued to Mallard Exploration, LLC Permit for two (2) 500 barrel produced water storage vessels at a new synthetic minor oil and gas well production facility. Page 7 of 9 - COLORADO • Y-.s{� Air Pollution Control Division CDPHE Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exc.eedance 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 1,400 70 002 n-Hexane 110543 4,400 220 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 3.66x10-3 3.66x10-3 AP-42 Chapter CO 1.67x10 2 1.67x10 2 13.5 VOC 2.62x10-1 1.31x10-2 CDPHE PS Memo 71432 Benzene 7.0x10-3 3.5x10-4 14-03 110543 n-Hexane 2.2x10-2 1.1x10-3 Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-03 for produced water storage vessels. The NOx and CO emission factors in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1496 Btu/scf and GOR of 36 Page 8 of 9 ,,M COLORADO Air Pollution Control Division CCOPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado scf/bbl. Actual emissions are calculated by multiplying the emission factors in the table above by the total produced water throughput. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane a Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Cs.•- COLORADO -.tl Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE 1062 Issuance: 1 Date issued: Issued to: Mallard Exploration, LLC Facility Name: Green Teal Fed Pad Plant AIRS ID: 123/AOAA Physical Location: SESW SEC 34 T8N R60W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control I[) Point Equipment Description Description Hydrocarbon Hydrocarbon loadout from storage Loadout 003 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. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 11 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I. F.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 i,air pollutants must not exceed the following ti Part B, Section II.A.4) Annual Limits mitations. (Regulation. Number 3, Equipment ID AIRS Point Tons per, Year Emission Type PM2.5 NO X VOC CO Hydrocarbon Loadout 003 - - 0.1 1.0 0.2 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission 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 Page 2 of 11 a COLORADO Air Pollution Control Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado (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 ID AIRS Point Control Device Pollutants Controlled Hydrocarbon Loadout 003 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly recor`ds'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/Consul ption Limits Equipment ID AIRS Point process Parameter Annual Limit Hydrocarbon Loadout 003 Hydrocarbon Loadout 350,000 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) Page 3 of 11 »a COLORADO 4440 Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 12. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 13. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or, vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, 14. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control methods) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. Page 4 of 11 COLORADO W Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 15. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 16. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 17. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 18. 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 your OaM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 5 of 11 COLORADO Air Pollution Control Division CDPHE Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or for volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non-criteria reportable pollutant: If the emissions increase by 50%or five(5)tons per year,whichever is less, above the level reported on the last APEN.submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). GENERAL TERMS AND CONDITIONS 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not Page 6 of 11 Ilia" COLORADO • lia" Air Pollution Control Division EDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 26. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 27. Each and every condition of this permit is is material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Page 7 of 11 a .�u,. COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issued to Mallard Exploration, LLC Issuance 1 This Issuance Permit for hydrocarbon loadout at a new synthetic minor oil and gas well production facility. Page 8 of 11 z COLORADO C• Air Pollution Control Division Department of Public Health fy Envirorment 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 63 4 003 n-Hexane 110543 560 28 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl NOx 1.89x10-4 1.89x10-4 AP-42 Chapter CO 8.64x10-4 8.64x104 13.5 VOC 1.04x1O1 5.2x10-3 Page 9 of 11 a . . . COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl CDPHE PS n-Hexane 110543 1.6x10-3 8.0x10-5 Memo 14- 02 Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-02 for crude oil loadout. The NOx and CO emission factors in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 3535 Btu/scf and GOR of 0.788 scf/bbl. Actual emissions are calculated by multiplying the emission factors in the table above by the total hydrocarbon throughput. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane and Total HAP PSD Synthetic Minor Source of: V0C NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD Page 10 of 11 4.6"1:-.1-----461. � COLORADO - Mr Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package B: 416151 Received Date: 9/5/2019 Review Start Date: 3/19/2020 Section 01 - Facility Information Company Name: Mallard Exploration, LLC Quadrant Section Township Range County AIRS ID: 123 SESW 34 8N 60 Plant AIRS ID: AOAA Facility Name: Green Teal Fed Pad Physical Address/Location: SESW quadrant of Section 34, Township 8N, Range 60W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segmentiOil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutart? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRs Point B Permit B (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned assigned ) Permit Initial 001 Crude Oil Tank Crude Oil Tanks 1-4 Yes 19WE10E0 1 Yes Issuance Section 03 - Description of Project Mallard Exploration, LLC is requesting permit coverage for sources at a new synthetic minor oil and gas well production facility located in the ozone non- attainment area. With this application, the operator is requesting permit coverage for crude oil storage vessels, produced water storage vessels and hydrocarbon liquid loadout. This analysis only evaluates the crude oil storage vessels. An APEN is required for this source because uncontrolled requested VOC emissions are greater than 1 tpv (CO AQCC Regulation 3, Part A, Section II. B.3.a .). Further, a permit is required for this source because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 2 tpy (CO AQCC Regulation 3, Part B, Section II .D.2.a.). Public comment is required for this source because new synthetic minor limits are being established with this application. Additionally, the change n VOC emissions as a result of this project are greater than 25 tpy. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ LI ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ O ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ LI Is this stationary source a major source? No If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ 0 ❑ Title V Operating Permits COP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) 0 0 Crude Oil Storage Tank(s) Emissions Inventory (Section 01 - Administrative Information (Facility AIRS ID: 123 A0AA 001 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Four (4) 500 barrel fixed roof crude oil storage vessels connected via liquid manifold. Description: Emission Control Device Enclosed Combustor(s) Description: Requested Overall VOC & HAP Control Efficiency %: 95.0 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = 338208.0 Barrels (bbl) per year Requested Permit Limit Throughput = 350000.0 Barrels (bbl) per year Requested Monthly Throughput = 29726.0 Barrels (bbl) per month Potential to Emit (PTE) Throughput = 350000.0 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 3535.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 23.0 scf/bbl Actual heat content of waste gas routed to combustion device = 27,498.0 MMBTU per year Requested heat content of waste gas routed to combustion device = 28,456.8 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 28,456.8 MMBTU per year Control Device - Number of combustors: 3 Pilot Fuel Use Rate: 11.538 scfh 0.3032 MMscf/yr Pilot Fuel Gas Heating Value: 1473.39 Btu/scf 446.7593 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes Emission Factors Crude Oil Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Crude Oil (Crude Oil Throughput) Throughput) VOC 3.2000 1.60E-01 Crude Oil State E.F. (includes flash) Benzene 4.60E-02 2.30E-03 Crude Oil State E.F. (includes flash) Toluene 0.00E+00 Ethylbenzene 0.00E+00 Xylene Q.00E+00 n-Hexane 2.45E-01 1.23E-02 Crude Oil State E.F. (includes flash) 224 TMP 0.00E+00 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Waste Heat (Crude Oil Combusted) Throughput) PM10 0.0075 6.06E-04 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 6.06E-04 AP-42 Table 1.4-2 (PM10/PM.2.5) NOx 0.0680 5.53E-03 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 2.52E-02 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) PM10 0.0075 10.9782 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 10.9782 AP-42 Table 1.4-2 (PM10/PM.2.5) NOx 0.0680 100.1905 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 456.7509 AP-42 Chapter 13.5 Industrial Flares (CO) Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) I (tons/year) (tons/year) (lbs/month) VOC 560.0000 541.1323 27.0566 560.0000 28.0000 4756.2 PM10 0.1077 0.1041 0.1041 0.1077 0.1077 18.3 PM2.5 0.1077 0.1041 0.1041 0.1077 0.1077 18.3 NOx 0.9827 0.9501 0,9501 0.9827 0.9827 166.9 CO 4.4800 4.3314 4.3314 4.4800 4.4800 761.0 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 16100.00 15557.57 777.88 16100.00 805.00 Toluene 0.00 0.00 0.00 0.00 0.00 Ethylbenzene 0.00 0.00 0.00 0.00 0.00 Xylene 0.00 0.00 0.00 0.00 0.00 n-Hexane 85750.00 82860.96 4143.05 85750.00 4287.50 224 TMP 0.00 0.00 0.00 0.00 0.00 2 of 4 C:\Users\hslaught\Desktop\123A0AA\19WE1060.CP1 Crude Oil Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage tank is subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? Yes If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? Yes If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? No. If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? N/A - operator used state default EF to calculate emissions. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? No If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device basec on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 1. The operator calculated VOC and HAP emissions in this application using the state default emissions factors. This methodology is acceptable; however, the uncontrolled requested VOC emissions are greater than 20 tpy. As a result, the permit will contain an initial compliance test that requires the operator to develop site specific emission factors for this source. The operator must also modify the permit to use the site specific emission factors, developed through initial testing, for emission calculations and ongoing compliance demonstrations. This is required because PS Memo 14-03 states the following: "Site-specific emission factors must be developed and used as the basis to estimate emissions in the following circumstances or locations: Uncontrolled VOC emissions from a storage tank are greater than or equal to 20 tpy when calculated using state emission factors." 2. According to the application, two wells produce to this facility. The well names and API numbers are as follows: (i) Name: Green Teal Fei 34-27-16HN, API Number: 05-123-46182; (ii) Name: Green Teal Fed 34- 27-15HN, API Number: 05-123-46177. According to COGCC data, the API gravity of the wells is less than 40. As a result, the operator's classification of the storage vessels as crude oil storage is appropriate. The COGCC data further indicates the wells were fractured in April 2019 and began production in May 2019. Both wells produce from the Niobrara formation. 3. On February 14, 2020, Regulation 7, Part D, Section I was updated to include requirements for crude oil storage vessels. Since uncontrolled requested emission from this source are greater than 2 tpy (state only) and 4 tpy (SIP), this source is subject to the requirements of Regulation 7, Part D, Section I. The compliance deadline for the crude oil storage vessels is May 1, 2020 since they were constructed before March 1, 2020. This evaluation is discussed here because the current regulatory analysis in this workbook does not contain an evaluation of Regulation 7, Part D, Section I. It should be noted that the enclosed combustors used to control emissions from this source meet the requirements of Regulation 7, Part D, Section I. 4. Even though NOx emissions from this source specifically are below APEN reporting thresholds, the total NOx emissions from all sources controlled by the three (3) enclosed combustors (produced water storage vessels, crude oil storage vessels and hydrocarbon loadout) are greater than APEN thresholds. As a result, the permit for each source controlled by the common control device will include limits of NOx emissions. CO emissions from this source are above APEN reporting thresholds without the evaluation of other sources controlled by the common control device. The NOx and CO limits include emissions associated with the combustion of pilot fuel. As a result, the permit will also contain a limit on the volume of pilot fuel combusted. The permit is structured in this manner because the throughput tracking and emissi Dn calculation methods for the pilot light combustion are different than those used to estimate emissions associated with the crude oil throughput. 5. It should be noted that VOC emissions associated with the combustion of pilot light gas are not calculated in this analysis, and an emission factor for VOC associated with pilot light combustion s not incorporated into the permit. This is due to the fact that the pilot light only results in a negligible contribution of VOC (0.0012 tpy). This minimal amount of emissions does not impact the total VOC limit for this source and therefore can be ignored. 6. The produced water storage vessels, hydrocarbon loadout, and crude oil storage vessels are controlled by the same enclosed combustors at this facility. Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device. In this case, the highest emitting source is the crude oil storage vessels. As a result, the pilot light combustion emissions are included in this analysis. 7. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units t 01 4-04-003-12 Fixed Roof Tank, Crude Olt, working+breathing+flashing losse PM10 1.01 0 lb/1,000 gallons crude oil throughput PM2.5 0.01 0 lb/1,000 gallons crude oil throughput NOx 0.13 0 lb/1,000 gallons crude oil throughput VOC 76.2 95 Ib/1,000 gallons crude oil throughput CO 0.61 0 lb/1,000 gallons crude oil throughput Benzene 1.10 95 lb/1,000 gallons crude oil throughput Toluene 0.00 95 lb/1,000 gallons crude oil throughput Ethylbenzene 0.00 95 lb/1,000 gallons crude oil throughput Xylene 0.00 95 lb/1,000 gallons crude oil throughput n-Hexane 5.33 95 lb/1,000 gallons crude oil throughput 224 TMP 0.00 95 lb/1,000 gallons crude oil throughput 3 of 4 C:\Users\hslaught\Desktop\123A0AA\19WE1060.CP1 • Crude 011 storage rank xegulatory Halms WorkSheet The regulatory heeregulatory requiremen65below are determined based an requested emissions. • seeumrstrue c.",=rmnmuea atom'"."° woeaattu^ ma sgmmnn p nmm TMlnegwagon3,reran,swuenll.oa.a1] . - ahpaerdto%3<ke64 nanotmpminee e�ma4u/ullswars raemoua3meater ddmnalwaanwmennamuereappnwbuMlr v.ii�m at i�,nmeaneeneemage,ampaw=Mleawangomeea:nrIOX•] 3.Y.rmdraagNmmnmlYagoraM„lon=vaare.aansrr:,xoavaat.rman t0.]r;.reowaulmavae°rdw,ntomvlX.e.larrm,3.rart6.:e.,la,l1.0,1] • . . xah.6.cY,mgg`r�:n' t m ar.mYta tw..I.Aro uncontrolled ,p.IXwdeaen3,pahA.smunnatal, VO4.tr .antame„enq„etXm • 2.la 6ecenstrualon°date a�a];a°a•aand'„a a a 1414,5uPsue,°S ara.atlmranlewmnaa.en,anmerappe°emvn mro.w�wn naoogoruws;n,wn w:::�°�zrsp }•rta�yl a awomr°, '"""u..rt,a.wn3wxrto.xam.aa..,p.a�eau veaa.Ulan.o,..ma,wrd,3.Pan e.SeaW„II.o31r vaet4*Requxm.eemIt nvrwmnryvaeenmMi unxgattwmmarssbeee mac wnanaprmuameperaann..dlpmtlawnradio',na leas prmmavaer,.awalgaspm am.gamr nntamer,maeae,ehaMtwee namrmlmemmmarvthaet X.Art one tons 0.r arVota .>" seurceh rcawtpat con p n subject osawdarm 3,zememxxl.aaeeetauarcnqumon ts s.boat wsa n.nN'sdbonm"ggdtlsl ltm,the'diming aaemew prwwensappN. • ISwrce Isvblea to all prwlams at liegulallon,SettlonAIII,56settons toed z �u.rmw.eexempmnm.111.bgmntaa mhraT33w1] 6tm.ganneYrctwaanx�m. a.Oars thentartl d.20.*elesatlIan or equal to ; ms Iw.epo earl mm is pw=leen'a condensate...,,pears..°amtea War m mtoM gamer•»defined n 60.3avb] Wastnisanclensm¢storsge cant au dffeeaeadwotoon60.x1 akertuN23.15ur ..,rc adevgdalgvtl'swannnmin6oavvbr . 4,[-2.7 Wl awe uetmuternl.slew to.arnmphe..11..0i3.1Alr:m 6.1fietlealgn.eadry,smote,than or equal to ISIol•lyao net]mas aanporawnba maamom true wpm prenure•lea uan3shra f6esaenrynr:er IlledaagnopadtvIs3reaterth.or equal to 75 a'rmeetl burtessman ss3m'i-9soeet/anettnnaallgmamlua maemum wewpnrpresor:Net 0.1.5.0 Fra16o.3tgdblP ].ooel.sIorageta.meet a.ItedealpwdmV control xh,,. b.The o75rue,l>6eetl but lets thanssvm'sso 30Ll antiguns ugmawu a maamum weuaperpessuregeyser mart or equal letsapwbotlesswnv].6tn]2.'Was thb auk oixtorageftsfel tee.pMYeen.aanwanenawwyaprmnmmaepmoctween Aaswo®ws®mmrmm:coaleammmtwonaream ease3mmtawl„eet:rv] m,metee-wal„whrma:X9,20 -Gotoe,yma,ewaew 3mnmarueclee. nM,seeeaanNens.rm.w3,heaam Aym gm15ita�°m6°ae,3our ., � mtwgettrtmzg000-nom Cercaqunwmmntmueeammwrwnorxsrsaooxapgr+6rvn 3.Wm.Ws emle maragere.o.constructed,retonaructer4 or modified m vaendsaw 6emeet..111Nt.o6egnap',Tsurt6an wrneltostmapersea gYmarl yet:2*b co mxe ram gmb-on 304 o to the 6.nuo may< on nnea uwbintu m controlled Inuawaance wrhrequlremen�asswaees.nset.N.empart w subpart.a..Cfn wet 63sobparcxxr 65eunehwgenunsrs000m• I3mh®a„evre:acres rare rmwc. §6os3asolel�xmmaeonuwweane paoawapngeenuremenu v6al.lraumane cumavmtswee aenludn3 nmwmmrnu Nola:xan..ap.wa11•Maacoeumanee to be wblee m nn eoeo/omoae,m m a...n...6 tons w•w•wc on the a o-xtraeter.unauw eau,ltmwa rmtaln aubl.am env ooeapooeaper 6.3.1.21/60.53634eN31 evenxpere..t toeeadalnn dreg below 6 tans pmwad bent n gas p,Wwbs hazy wtmaomwaMelmwaym.. Erns Icm.6ue-me haw,n4licaueltilesauere eategoviantlx,ngaezmmarvsn.v • a.A Nano dotmomssaa,upeaees or stem bWmoreon lkodm'16xr601.0N:on natural gas paeta the lantawmtmmal sus men u0.natural gasrmmXnm ane.mngesweremtaaYIx XhllwreetoalluleMusn 163.rw1a1(sll] sm#e'm rage rwM hint wgeeraacr XX 3Mrearem MARHXrtq remerurmmnWataeaswrm 4. ehetteilnalonor,Drageveisel.thepolentlarler Cash 5 naahn4sudw] anm6ohpah gbm mi.r rMc] t] • NA dnhle3 963.ain.rae,;tmneenod s°nmrm 5..773 PALIEIrdew Olactemer fac warp deem..Ip not▪rulearray....abcoIns amryxYP Wno as partkaars,dat.ease eupan rm rinusammnmiances Pu's documert desro charge at a o. or en• ,�enmgremenomasMe 4a pueuM' roCmynct1..,.tw banw°se�uwsn between arnWWYn me y., o.-imaruuew Ia..,of rre Ownm.te..a Ire ce.naoacndird rmruycontm integrenbns eend ra u.0.r...mo....9,551 Yp5INeMmng ewu]a55uuecare Ward.ro a mg reau'nrents weer M t�tt COLORADO DEPARTMENT OF PUBLIC IlEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Mallard Exploration, LLC County AIRS ID 123 History File Edit Date 4/16/2020 Plant AIRS ID AOAA Ozone Status Non-Attainment Facility Name Green Teal Fed Pad EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0 0 i 0.0 New Fa:ility - No Previous Total 001 19WE1060 Four (4) 500 bbl fixed roof crude oil 1; 1 0.1 1 0 560.0 4.5 50 9 0. 1 0.1 I .i 28.0 4.5 2.5 New source - state EF used - SSEF must be storage vessels develop ed and used. 002 19WE 1061 Two (2) 500 bbl fixed roof produced Oil 0.0 0 4 26 2 1 ? 2 9 0.0 0.0 0.4 1.4 1.7 0 1 New Source - state EF used wter storage vessels 003 19WE1062 Hydrocarbon Liquid Loadout 0.0 0.0 0 1 18.2 0.2 0 3 0.0 0.0 0. 1 1 .0 0.2 0.0 New Source - state EF used 004 GP02.CN SI RICE Caterpillar G3306B NA. 0.0 0.0' Cancellation received 12/12/2019. Source no longer 4SRB, 145 HP (site rated), SN: exists at the facility. R6S03584 XA Fugitives 0 1, 0 0 0.1 0.0 Insignificant Source 0.0 0.0 0.0 0.0 0.0 0 0 00 00 0.0 0.0 0.0 0.0 0.0 0 0 FACILITY TOTAL 0.2 0.2 0.0 0.0 1.5 604.4 0.1 6.4 54.1 0.2 0.2 0.0 0.0 1.5 30.4 0.1 6.4 2.7 VOC: Syn Minor (PSD, NANSR and OP) NOx: True Minor (PSD, NANSR and OP) CO: True Minor (PSD and OP) HAPS: Syn Minor n-Hex & Total HH: Area source - no affected sources 7777: Not applicable - no engines Permitted Facility Total 0.2 0.2 0.0 0.0 1.5 604.4 0.0 6.4 54. 1 0.2 0.2 0.0 0.0 1.5 30.4 0.0 6.4 2.7 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.2 0.2 0.0 0 0 1.5 30.4 0.0 6 4 Modeling not required based on A change in emissions. Pubcom is required b/c new syn minor limits are being established and the change in VOC emissions is greater than 25 tpy. Total VOC Facility Emissions (point and fugitive) 30.5 Facility is eligible for GP02 because < 90 tpy (CO) and <45 tpy (NOx and VOC) (A) Change in Total Permitted VOC emissions (point and fugitive) 30.4 Project VOC emissions greater than 25 tpy "Next engineer - confirm site specific emission factors were developed for point 001 . The first issuance requires the operator to develop SSEF and modify the perm tin order to use the SSEF for emission calculations and ongoing compliance. This requirement is per PS Memo 14-03 which requires the operator to develop and use SSEF when "Uncontrolled VOC emissions from a storage tank are greater than or equal to 20 tpy when Note I calculated using state emission factors." Note 2 Page 1 of 2 Printed 4/20/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Mallard Exploration, LLC County AIRS ID 123 Plant AIRS ID AOAA Facility Name Green Teal Fed Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE1060 Four (4) 500 bbl fixed roof crude oil 16100 85750 50.9 storage vessels 002 19WE1061 Two (2) 500 bbl fixed roof produced 1400 4400 2.9 water storage vessels 003 19WE1062 Hydrocarbon Liquid Loadout 560 0.3 004 GP02.CN SI RICE Caterpillar G3306B NA, 4SRB, 0.0 145 HP (site rated), SN: R6S03584 XA Fugitives .. -' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 8.8 0.0 0.0 0.0 45.4 0.0 0.0 0.0 0.0 54.1 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE1060 Four (4) 500 bbl fixed roof crude oil 805 4288 2.5 storage vessels 002 19WE1061 Two (2) 500 bbl fixed roof produced 70 220 0. 1 water storage vessels , 003 19WE1062 Hydrocarbon Liquid Loadout 28 0.0 004 GP02.CN SI RICE Caterpillar G3306B NA, 4SRB, 0.0 145 HP (site rated), SN: R6S03584 XA Fugitives 4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.4 0.0 0.0 0.0 2.3 0.0 0.0 0.0 0.0 2.7 2 123AOAA 4/20/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package #: 416151 Received Date: 9/5/2019 Review Start Date: 3/19/2020 Section 01 - Facility Information Company Name: Mallard Exploration, LLC Quadrant Section Township Range County AIRS ID: 123 SESW 34 8N 60 Plant AIRS ID: AOAA Facility Name: Green Teal Fed Pad Physical Address/Location : SESW quadrant of Section 34, Township SN, Range 60W / County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment: Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRs Point # Permit # (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned) assigned) Produced Water Permit Initial 002 Produced Water Tank Tanks 1-2 Yes 19WE1061 1 Yes Issuance Section 03 - Description of Project Mallard Exploration, LLC is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area. With this application, the operator is requesting permit coverage for crude oil storage vessels, produced water storage vessels and hydrocarbon liquid loadout. This analysis only evaluates the produced water storage vessels. An APEN is required for this source because uncontrolled requested VOC emissions are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section II.B.3.a.). Further, a permit is required for this source because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 2 tpy (CO AQCC Regulation 3, Part B, Section II.D.2.a.). Public comment is required for this source because new synthetic minor limits are being established with this application. Additionally, the change in VOC emissions as a result of this project are greater than 25 tpy. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ 0 ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ U ❑ ❑ ❑ U Non-Attainment New Source Review (NANSR) ❑ 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 (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory Section 01 - Administrative Information (Facility AIRS ID: 123 AOAA 002 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Two (2) 500 barrel fixed roof produced water storage vessels connected via liquid manifold. Description: Emission Control Device Enclosed Combustor(s) Description: Requested Overall VOC & HAP Control Efficiency °r6: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 181,249 Barrels (bbl) per year Requested Permit Limit Throughput = 200,000 Barrels (bbl) per year Requested Monthly Throughput = 16986 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = 200,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 1496.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 36.0 scf/bbl Actual heat content of waste gas routed to combustion device = 9761.3 MMBTU per year Requested heat content of waste gas routed to combustion device = 10771.2 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 10771.2 MMBTU per year Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? YeS'°' Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) VOC 0.2620 1.31E-02 Produced Water State E.F. (includes flash) - Fron' Benzene 7.00E-03 3.50E-04 Produced Water State E.F. (includes flash) - Fron Toluene 0.00E+00 Ethylbenzene 0.00E+00 Xylene 0.00E+00 n-Hexane 2.20E-02 1.10E-03 Produced Water State E.F. (includes flash) - Froni 224 TMP 0.00E+00 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 0.00745 0.00040 AP-42 Table 1.4-2 (PM1O/PM.2.5) PM2.5 0.00745 0.00040 AP-42 Table 1.4-2 (PM10/PM.2.5) NOx 0.06800 0400366 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.31000 0.01670 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) PM10 0.0000 PM2.5 0.0000 NOx 0.0000 CO 0.0000 Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 26.200 23.744 1.18718 26.200 1.31 222.5 PM10 0.040 0.036 0.036 0.040 0.040 6.8 PM2.5 0.040 0.036 0.036 0.040 0.040 6.8 NOx 0.366 0.332 0.332 0.366 0.366 62.2 CO 1.670 1.513 1.513 1.670 1.670 283.6 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 1400.000 1268.743 63.437 1400.000 70.000 Toluene 0.000 0.000 0.000 0.000 0.000 Ethylbenzene 0.000 0.000 0.000 0.000 0.000 Xylene 0.000 0.000 0.000 0.000 0.000 n-Hexane 4400.000 3987.478 199.374 4400.000 220.000 224 TMP 0.000 0.000 0.000 0.000 0.000 2 of 4 C:\Users\hslaught\Desktop\123A0AA\19WE1061.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000. NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? No If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which a° generally means site-specific and collected within one year of the application received date. However, if the facility has not t- been modified (e.g., brought on-line), may appropriate site-specific p no new wells then it be a ro riate to use an older sample. ; N/A - the operator used the state default emission factors to estimate emissions. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? No If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 1. According to the application, two wells produce to this facility. The well names and API numbers are as follows: (i) Name: Green Teal Fed 34-27-16HN, API Number: 05-123-46182; (ii) Name: Green Teal Fed 34-27-15HN, API Number: 05-123-46177. According to COGCC data the wells were fractured in April 2019 and began production in May 2019. Both wells produce from the Niobrara formation. 2. On February 14, 2020, Regulation 7, Part 0, Section I was updated to include requirements for produced water storage vessels. Since uncontrolled requested emission from this source are greater than 2 tpy (state only) and 4 tpy (SIP), this source is subject to the requirements of Regulation 7, Part D, Section I. The compliance deadline for the produced water storage vessels is May 1, 2020 since they were constructed before March 1, 2020. This evaluation is discussed here because the current regulatory analysis in this workbook does not contain an evaluation of Regulation 7, Part D, Section I. It should be noted that the enclosed combustors used to control emissions from this source meet the requirements of Regulation 7, Part D, Section I. 3. The produced water storage vessels, hydrocarbon loadout and crude oil storage vessels are controlled by the same three enclosed combustors at this facility. As a result, the pilot light emissions ar! not calculated in this workbook because the are evaluated with the crude oil storage vessels (19WF 1060). Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device. In this case, the highest emitting source is the crude oil storage vessels. 4. Even though NOx and CO emissions from this source specifically are below APEN reporting thresholds, the total NOx and CO emissions from all sources controlled by the three (3) enclosed combustors (produced water storage vessels, crude oil storage vessels and hydrocarbon loadout) are greater than APEN thresholds. As a result, the permit for each source controlled by the common control device will include limits on NOx and CO emissions. 5. The operator was provided with a draft permit, APEN redline and O&M plan redline to review prior to public comment. The operator reviewed all the documents and expressed they had no comments. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process tt SCC Code Pollutant Factor Control % Units 002 01 4-04-003-15 Fixed Roof Tank. Produced Water, working+breathing+flashing losses PM10 0.0096 0.0 lb/1,000 gallons liquid throughput PM2.5 0.0096 0.0 lb/1,000 gallons liquid throughput NOx 0.0872 0.0 Ib/1,000 gallons liquid throughput VOC 6.2381 95.0 lb/1,000 gallons liquid throughput CO 0.3975 0.0 Ib/1,000 gallons liquid throughput Benzene 0.1667 95.0 lb/1,000 gallons liquid throughput Toluene 0.0000 95.0 lb/1,000 gallons liquid throughput Ethylbenzene 0.0000 95.0 lb/1,000 gallons liquid throughput Xylene 0.0000 95.0 lb/1,000 gallons liquid throughput n-Hexane 0.5238 95.0 lb/1,000 gallons liquid throughput 224 TMP 0.0000 95.0 Ib/1,000 gallons liquid throughput 3 of 4 C:\Users\hslaught\Desktop\123A0AA\19WE1061.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet The regulatory requirements below ore determined based on requested emissions. Colorado Regulation 3 Parts A and B_ADEN and Permit Requirements Source is is the ^ion-Aft:Iinrctnt At.ta 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 i.a)? 2. Is the operator claiming less than 1%crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B,Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section II.0.3)? Y31:have indented triot s•:•.e;e;s In the NX,-Atssnimcnt Ai ea NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A,Section II.D.1.a)? Yes Source Requires an APEN.Go to the next question 2. Is the operator claiming less than 1%crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3,Part B.Section II.D.1.M) No Go to next question 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3.Part 6,Section II.D.2)? Yes Source Requires a permit Sercct' requii.-,A pe:mrt Colorado Regulation 7�Section XVII 1. Is this tank located at a transmission/storage facility? N;- Continue - You have indicated the source category on the Project Summary sheet. 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility`,natural gas compressor station'or natural gas processing plant? Yr-. Continue -You have indicated the facilit} type on the Project Summary sheet. 3. Is this produced water storage tank a fixed roof storage tank? Yes Go to the next question 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? Yes (Source is subject to parts of Regulation 7. Sections XVILB&C. Go to the next question 'Storage tank is :object to Re-v'zcico 1. Section KVII, 8.C.1& C3 Section XVII.B-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 -Emissions Control and Monitoring Provisions Section XVII.C3- Recordkeeping Requirements 5. Does the produced water storage tank contain only"stabilized"liquids? If no,the following additional provisions apply. No Source is subject to all provisions of Regc lation 7,Section XVII,Subsections B& C 'Storage tnni is JObjer.t to Re qutaticn 7, Section XVil.C.2 Section XVII-C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60,Sulwart Kb Standards of Performance for Volatile Organic Ljquid Storage Vessels 1. Is the Individual storage vessel capacity greater than or equal to 75 cubic meters(m3) (-472 BBB)? Yes Go to the next question 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tank is not subject NSPS Kb. a. Does the vessel has a design capacity less than or equal to 1,589.874 m1(`10.000 BBL) used for petroleum' or condensate stored, processed,or treated prior to custody transfer'as defined in 60 11lb? 3. Was this condensate storage tank constructed, reconstructed,or modified (see definitions 40 CFR,60.2) after July 23, 1984? NA 4. Does the tank meet the definition of"storage vessel"'in 60.111b? NA 5. Does the storage vessel store a "volatile organic liquid(VOL)"sas defined in 60.11lb? NA 6. Does the storage vessel meet any one of the following additional exemptions: NA a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ("29.7 psi) and without emissions to the atmosphere(60.11ob(d)(2))?;or NA b. The design capacity is greater than or equal to 151 m ["950 BBL]and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa (60.110b(b))?; or NA c. The design capacity is greater than or equal to 75 M' (-472 BBL) but less than 151 m' ("950 BBL)and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110blb)l? NA 7. Does the storage tank meet either one of the following exemptions from control requirements: NA a. The design capacity is greater than or equal to 151 m' ["950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?;or NA b. The design capacity is greater than or equal to 75 M' (-472 BBL] but less than 151 m' (^950 BBL( and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? NA - 'Storage Tank is not subject to N5PS Kb 40 CFR. Part 60,Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment. natural gas processing segment or natural gas transmission and storage segment of the industry? Continue - You have indicated the source category on the Project Summary sheet. 2. Was this produced water storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2) between August 23, 2011 and September 18, 2015? No Storage Tank is not subject NSPS 0000-Go to the next question to continue determination of NSPS 0000a applicability. 3. Was this produced water storage vessel constructed, reconstructed,or modified(see definitions 40 CFR,60.2) after September 18,2015? Yes Go to the next question 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not subject NSPS 0000a 5. Does this produced water storage vessel meet the definition of"storage vessel"' per 60.5430/60,5430a? NA 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart NH) NA Herat;c Tank Is not subject to NSPS 0000., (Note: If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non•attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer Tins document assists operators with determining applicability of certain requirements of the Clean Air Act. its implementing regulations, and Air Qualify Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not appy 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 s not Jogaiy 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 wig control. The use of non-mandatory language such as 'recommend,"may,"-should.'and tan.'is intended to describe APCD interpretatons and recommendations Mandatory terminology such as 'must"and"required"are intended to describe controlling requirements under the terns of the Clean Air Act and Air Quality Control Commission regulators, but this document does not establish bgaly 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 #: 416151 Received Date: 9/5/2019 Review Start Date: 3/24/2020 Section 01 - Facility Information Company Name: Mallard Exploration, LLC Quadrant Section Township Range County AIRS ID: 123 SESW 34 8N 60 Plant AIRS ID: AOAA 1r�gV% Ix x 1111>A. xl 'x V%. ':ti'J%1 W%.%..1�((K' -Y.<f�� . +��+'%C:Xi.il%::n.:H[Gl'nl.%.(n 31 . Wit RYt�I u&'t'R'z:�Xv .i < �L..::cYl�•xzzwc.•��^'`^`tl• x:'x x Af,�x a %2' x-w: 4 ».. Ce :Wabe........x;i� R•Rx; \r— ,A, Facility Name: Green Teal Fed Pad y> g e � x� ` ' ..uu:xt'S£!:� ..&< Iz. :< .xN��x �..« ..if R R : � iR`.w1u s �Y�Rxx'��' ^e.a�R��S� Physical Address/Location: SESW quadrant of Section 34, Township 8N, Range 60W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment; Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRs Point 44 Permit 14 (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned assigned) Permit Initial 003 Liquid Loading Hydrocarbon Loadout Yes 19WE1062 1 Yes Issuance Section 03 - Description of Project Mallard Exploration, LLC is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area. With this application, the operator is requesting permit coverage for crude oil storage vessels, produced water storage vessels and hydrocarbon liquid loadout. This analysis only evaluates the hydrocarbon liquid loadout source. An APEN is required for this source because uncontrolled requested VOC emissions are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section II.B.3.a.). Further, a permit is required for this source because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 2 tpy (CO AQCC Regulation 3, Part B, Section ll.D.2.a.). Public comment is required for this source because new synthetic minor limits are being established with this application. Additionally, the change in VOC emissions as a result of this project are greater than 25 tpy. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ D ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ El ❑ ❑ Cl O Non-Attainment New Source Review (NANSR) ❑ El Is this stationary source a major source? No If yes, indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Hydrocarbon Loadout Emissions Inventory Section 01 - Administrative Information 123 A0AA 003 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Hydrocarbon liquid loadout from storage vessels to tank trucks using submerged fill. Description: Emission Control Device Enclosed Combustor(s) Description: Is this 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 = 338,208 Barrels (bbl) per year Requested Permit Limit Throughput = 350,000 Barrels (bbl) per year Requested Monthly Throughput = 29726 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 350,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 3535 Btu/scf Actual Volume of waste gas emitted per year = 266616 scf/year 0.78832 Requested Volume of waste gas emitted per year = 275912 scf/year Actual heat content of waste gas routed to combustion device = 942 MMBTU per year Requested heat content of waste gas routed to combustion device = 975 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 975 MMBTU per year Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? The state default emissions factors may be used to estimate emissions. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (Ib/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 1.04E-01 5.20E-03 Crude Oil Loadout State E.F. Benzene 1.80E-04 9.00E-06 Crude Oil Loadout State E.F. Toluene 0.00E+00 0.00E+0CC Ethylbenzene 0.00E+00 0.00E+00 Xylene 0.00E+00 0.00E+00 n-Hexane 1.60E-03 8.00E-05 Crude Oil Loadout State E.F. 224 IMP 0.00E+00 _ 0.00E+00 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.0075 2.08E-05 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 2.08E-05 AP-42 Table 1.4-2 (PM10/PM.2.5) SOx 0.0006 1.64E-06 AP-42 Table 1.4-2 (SOx) NOx 0.0680 1.89E-04 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 8.64E-04 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) P11/110 0.0000 PM2.5 0.0000 SOx 0.0000 NOx 0.0000 CO 0.0000 2 4 C:\Users\hslaught\Desktop\123A0AA\19WE1062.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.004 0.004 0.004 0.004 0.004 1 PM2.5 0.004 0.004 0.004 0.004 0.004 1 SOx 0.000 0.000 0.000 0.000 0.000 0 NOx 0.033 0.032 0.032 0.033 0.033 6 VOC 18.200 17.587 0.879 18.200 0.910 155 CO 0.151 0.146 0.146 0.151 0.151 26 A Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 63.00 60.88 3.04 63.00 3.15 Toluene 0.00 0.00 0.00 0.00 0.00 Ethylbenzene 0.00 0.00 0.00 0.00 0.00 Xylene 0.00 0.00 0.00 0.00 0.00 n-Hexane 560.00 541.13 27.06 560.00 28.00 224 TMP 0.00 0.00 0.00 0.00 0.00 _ Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7 Part D Section II.C.5. The hydrocarbon liquids loadout source is subject to Regulation 7 Part D Section Ii.C.5. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08 - Technical Analysis Notes :X 1. According to the application, two wells produce to this facility. The well names and API numbers are as follows: (i) Name: Green Teal Fed 34-27-16HN, API Number: 05-123-46182; (ii) Name: Green Teal Fed 34-27-15HN, API Number: 05-123-46177• : According to COGCC data, the API gravity of the wells is less than 40. As a result, the operator's classification of the storage vessels as crude oil storage is appropriate. The COGCC data further ind cates the wells were fractured in April 2019 and began .e -G< Production in May 2019. Both wells Produce from the Niobrara formation. .. ,._ ... _ ,.:, . . ... <:::. :•.. : . : . ... ....._ . . _...._ � , ...._ . _ . � , •.. .. _ G ,:., .F , � - 'A•w iil. t �\� pi.. ., :n[>Y .r.;:..,W. • GJ,::.•. : %..\•.r ,�.. ..N.. .t.n / t i.x..:. • /..:.. ..t ... .. .s. C.:% .c 'n'Y -->' Y ii .t Y %- [ f 1.11. 1.Ilt.n,.3 *am Y,> .,;,,- ,,5s„�.gx • .. 6.: •:SR Aix,.• • .,.. .. - < 2 u t % x [i it < )3t ){ 4' < k x ,x r �x. �`L2 � J%»f:. �^A ,: %' }. -,u > k.,wx 4.x zs Glii» '.::u�::.R,R r2>F :t�S:�aieN3Fz�> . �raros <)i�-j-7F;y.`w)xx r ♦ '.r .s 'u .-. z x e f< r't�33�i,iuxJ t)iF{f,R x%t�<ye z1x >,t a""t tii' %Ipe��kx,fjr�FaKxm`>�x.%x. .e% i}•r >? > • :. t .t ii xt rc x : F % $ x < 't>' 1: & %< 'R/.FS x Gt .,,,, .'n x •'.f?.: •xn x �u. .v ^ctkx a Y. v. } - i - 1 £ r Y Y 5 % C w r"', "' � '^X, ••��Ri]7t₹:xcrW-%+t%t. `�: x`-tc%% »::X- ti .Y>:1�>x;TJ't: permit i ( G ,::!> . . G't;txx G .x:...ii. s':£.'{x.! .a >ii;1v.. .-:tvt,�x:�a >srmits 'Eti:t•i1Gni Fitt.tl{...:{<: siaw � i•ii'�xiE ^ ifrz'.x' i�xx)''T3 2. Benzene emissions are below APEN reporting thresholds (i.e- 250 lb/year). As a result, an emission factor will not be included in the for this pollutant.�t i� ,.:xx % x t .t t s�< >; x ) � K.MIX:' ..x:«aw�jRx�%RR:.i :� ^ : . '.�xFx�`�R%:�:, •:Ri-�;Rotz RExc�xa .i u > > .G >: >• a } t :'x % ie x S.ii ex b x Y}'a t s�,�t iR^tt 21 gfiiiiii M %,� iEwR�y$�% c% .�,„ a—uxr..x.:vi:)G»:an: .. ., r ..., a ...�--.: ..: %.' ..: .t, o._ t 'u xi s:u: x ♦:.,Lt,L ,i [l t,G .t4+a ltl 9'iIXn tMn ttk rL! n-1..1 n.ce M+RC'}))C:%SK:.%::c'>r>:X. 3. The hydrocarbon loadout source, produced water storage vessels and crude oil storage vessels are controlled by the same three enclosed combustors at this facility. As a result, the pilot light emissions are not calculated in this workbook because the are evaluated with the crude oil storage vessels (19WE1060). Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device. In this case, the highest s . ._ _ .. . . . . _. : .: emittin source is the crude oil storage vessels. :.t..%.G../.:. :x.rq:<.,\..% R ••,:--t •X' <..-., . :.,,�:t::t. ,.<.,t) : „ .., �._,_. . .,..., , .....4_ •:,...... .::24.}.:::.: .. . �.,... . ,.r..) . >:.;i ._.. 1!:7. .. _ v . _ F. . ::::7:::':!:'::::' ...c ,.... ., ..x. r Y:4.:>. < e .. -..v,.Jr. ... _-. : .> . .-.a:.. ..,., .-. ., ft..,•:_d,._....... a... + v,K..Y..0.. ..L a.u... Y�✓'� xi•b.ncs.a Yv:.%'^n-'>Y^IXiu•e�₹:{16,12LC2GRVtnSRX C.(:Lllk.^..'Lx ^Axx<.'W:..<t.x AC :Ai' 4. Even though NOx and CO emissions from this source specifically are below APEN reporting thresholds, the total NOx and CO emissions from all sources controlled by the three (3) enclosed combustors (produced water storage vessels, crude oil storage :_ , , lel vessels and hydrocarbon loadout) are greater than APEN thresholds. As.a result, the permit for each source controlled by the common control device will include limits on NOx and CO emissions. , , , 4:i,as• R ., .. .: .fo->t <_ [ <.: ;: ...,. ., .....G' •K , s;:i>:.,.a t k.. ..• .a- `....z.' ... . ._... . ....... .. .. ., ' ..'.. :,,- :,....:...:x. u..c...G:}...,... . G......e.:.....t............... �'J -C<R »x�..;.': .,{;- �. ail .ix.<y.a•s t.x..x.m.t t1 uRe:< xe o ..n. x.xx.<. .R.xtG. 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Colorado Regulation 3 Parts A and B -APEN and Permit Requirements Suurco is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3. Part A, Section II.D.1.a)? , `T 2. Is the loadout located at an exploration and production site (e.g.,well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? S. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? J1 z 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B. Section II.D.3)? • You have indicated that source is in the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Go to next question. 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? Yes Go to the next question 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No Go to next question 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next question 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next question 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? ves The loadout requires a permit Source requires a permit Colorado Regulation 7 Part D Section II.C.S. 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 II.C.5. The hydrocarbon liquids loadout source is subject to Regulation 7 Part 0 Section II.C.5. Section II.C.S.a.(i) - Compliance Schedule Section II.C.5.a.(ii) - Operation without Venting Section II.C.5.a.(iii) - Loadout Equipment Operation and Maintenance Section II.C.5.a.(iv) - Loadout observations and Operator Training Section II.C.5.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. Hello