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Home My WebLink About20201229.tiffCOLORADO Department of Public Health Et Environment Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 March 25, 2020 Dear Sir or Madam: RECEIVED APR 01 2020 WELD COUNTY COMMISSIONERS On March 26, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Verdad Resource LLC - Lost Creek03-62-08-2H Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Pub l c Rev,e.,J 5/4/20 Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director CC P L (TP), }{ L ILK) PfrA3?t/ER/cH /CK) O G (Sra) 4/27/20 2020-1229 TM Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Verdad Resource LLC - Lost Creek03-62-08-2H Production Facility - Weld County Notice Period Begins: March 26, 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: Verdad Resource LLC Facility: Lost Creek03-62-08-2H Production Facility Exploration Ft Production Well Pad NWNW S8 T3N R62W Weld County The proposed project or activity is as follows: Source is requesting permit for storage of condensate in tanks, storage of produced water in tanks and loadout of condensate by truck 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 18WE0235 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: Christian Lesniak Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health & Environment CDPHE Construction Permit rra Air Pollution Control Division Permit number: 18WEO235 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Lost Creek 3-62-8-2 Plant AIRS ID: 9FA3 Physical Location: NWNW quadrant of Section 8, Township 3N, Range 62W County: 123 General Description: Exploration a Production Well Pad Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID TL01 001 Loading of condensate into tanker trucks Enclosed Flare WTO1 002 One 400 BBL produced water tank Enclosed Flare TK01-03 003 Three (3)400 bbl condensate storage tanks Enclosed Flare 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 THOSE 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 (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall 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. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall 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 AIRS ID: Page 1 of 11 olora Depa - b Health and Environment Air Pollution Control Division such constructio or ivi ed ;d t6 comme a as set forth in the permit a application ass e - , wi i II it; Atztv.>, ntinu- Yonstruction 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO), VOC CO Emission Type TL01 001 - 0.5 - Point WTO1 002 - 0.3 - Point TK01-03 003 - 12.6 2.4 See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve- month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. The owner or operator must use the emission factors found in"Notes to Permit Holder"to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TL01 001 Enclosed Flare VOC, HAPs WTO1 002 Enclosed Flare VOC, HAPs AIRS ID: 123/9FA3 Page 2 of 11 olora Depa me f b Health and Environment Air Pollution Control Division TK01-03 3 • En use Flare VOC, HAPs PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID TL01 001 Condensate Throughput 90000 BBL WT01 002 Produced Water Throughput 40000 BBL TK01-03 003 Condensate Throughput 90000 BBL Compliance with the annual throughput limits shall 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 shall 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 AIRS ID point number(e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. Point 001: The following requirements for hydrocarbon liquid loadouts apply to this point: a. 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.) AIRS ID: 123/9FA3 Page 3 of 11 olorae, Depa me f b Health and Environment Air Pollution Control Division (i) F. °litie o ` r ed r magifie on or of . r May 1, 2020, must be in ce:b o - errAg erat, (ii) Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. (iii) 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. b. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): (i) 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. (ii) Include devices to prevent the release of vapor from vapor recovery hoses not in use. (iii) Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. (iv) Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. (v) 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, c. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): (i) 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, (ii) 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. (iii) The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used AIRS ID: 123/9FA3 Page 4 of 11 „,,,, „•_,,„, .,,,,,,,„„., I ,. ,„ ,, _. olora Depa e f b Health and Environment Air Pollution Control Division a - :•pri•rime a Ai ne -ssa ` operati procedures for that (iv) 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. d. 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. (i) Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. (ii) 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. (iii) Records of the infeasibility of observation of loadout. (iv) Records of the frequency of loadout. (v) Records of the annual training program, including the date and names of persons trained. e. 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)) 13. Points 002, 003: This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) • 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 AIRS ID: 123/9FA3 Page 5 of 11 II olora Depa me f b Health and Environment Air Pollution Control Division operatin• ropz y. is =area ust e e ipped w h an operational auto-igniter accordi • •,.,4O1 s f,1,•, ESP" '-gu *:,1 tuber rt D, Section II.6.2.d. • 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. • 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. • 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 14. Upon startup of these points, the owner or operator shall 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 O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING No sampling or testing is required ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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 AIRS ID: 123/9FA3 Page 6 of 11 olora Depa - b Health and Environment Air Pollution Control Division For volatil org- .'c •- nd- (VI - nitroge oxides sources(NO,) in ozone non attai = -re. - . g c .. -s +0 to 07.--1, 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 16. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 17. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 18. 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 No. 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. 19. 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. AIRS ID: 123/9FA3 Page 7 of 11 , _ , , „ , , ., iii, ii-„olora Depa me f b Health and Environment Air Pollution Control Division 20. Unless specifical . . o e7 - e g- eral nd spe c conditions contained in this permit have be- - i 733,,,q - ! -C cess assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 21. 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 shall constitute a rejection of the entire permit and upon such occurrence, this permit shall 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. 22. 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. 23. 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: / f Christian Lesniak Permit History Issuance Date Description Issuance This Issuance Issued to Verdad Resources LLC AIRS ID: 123/9FA3 Page 8 of 11 ofora Depa me f b Health and Environment Air Pollution Control Division Notes to Permit Holder at t - - f t p- . it i 'uan 1) The permit holder is to .,,rakez time is permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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 shall 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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) (Ib/yr) Benzene 71432 37 2 001 n-Hexane 110543 324 16 Benzene 71432 280 14 002 n-Hexane 110543 880 44 Benzene 71432 540 27 Toluene 108883 340 17 Ethylbenzene 100414 40 2 003 Xylenes 1330207 108 5 n-Hexane 110543 2673 134 2,2,4-Trimethylpentane 540841 336 17 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. AIRS ID: 123/9FA3 Page 9 of 11 RtAdofollowjemission loepa me f b Health and Environment Air Pollution Control Division 5) The emission levels c.• - -• factors: Point 001: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl VOC 2.36E-01 1.18E-02 Condensate Loadout State E.F. n-Hexane 110543 3.60E-03 1.80E-04 Condensate Loadout State E.F. The uncontrolled VOC emission factor was calculated using state emission factors for loadout of condensate Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Point 002: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Source lb/bbl Factors lb/bbl VOC 0.262 1.31E-02 Produced Water State E.F. 71432 Benzene 0.007 3.50E-04 Produced Water State E.F. 110543 n-Hexane 0.022 1.10E-03 Produced Water State E.F. Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 003: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors lb/bbl lb/bbl CO AP-42 Chapter 13.5 0.0529 0.0529 Industrial Flares (CO) VOC 5.61 2.81 E-01 Source 71432 Benzene 0.006 3.00E-04 Source 108883 Toluene 0.004 1.89E-04 Source 100414 Ethylbenzene 0.000 2.20E-05 Source 1330207 Xylene 0.001 6.00E-05 Source 110543 n-Hexane 0.030 1.49E-03 Source 540841 2,2,4-TMP 0.004 1.87E-04 Source Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with G.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 shall be submitted no later than 30 days before the five-year term expires. Please refer to the AIRS ID: 123/9FA3 Page 10 of 11 111 olorac Depa ' b Health and Environment Air Pollution Control Division most recent annual fe voic o •- era - - A''',1I - airation da = for each emissions point associated with this p- .r a •ue . • .eg. ecific - ' ation 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 PSD or NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK 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)OCXXXX 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9FA3 Page 11 of 11 PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Chrirbeo_dandy Package#: 575,23 ,1 Received Date: 3/7,CeO z Review Start Date: 6112/2015' 2015' Section 01-Facility Information Company Name: .,P.eao ee'0c Quadrant Section Township Range County AIRS ID: 123 Plant AIRS ID: 91A3 Facility Name: _ssrCreer'e2 g-2 Physical Address/Location: o , County: Weld County Type of Facility: Exploration&ha-caeca-en stedi oar: What industry segment? & otis Go Pi erree„srg Is this facility located in a NAAQS non-attainment area? :e5 If yes,for what pollutant? ❑ Carbon Monoxide(CO) ❑ Particulate Matter(PM) Q Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point# Emissions Source Type Equipment Name Permit if Issuance# Action Control? Required? Remarks Pemnit initial 001 Liu ii..c..ad:=.;v ices: Yes ,,z.-vc-3 Yu5 issuance Permit Irntlal 002 ProducedWater Tank area 01 Yes ,u_3 s Yes issuance Pet sr tlnitial 003 Condensate'trait these-herd" ''es _V be2O-5 1 .yes issuance Section 03-Description of Project Source re ca ._ih The separeyor verong ft'._,3 13325 I AA,to 1E5532332!'cn≥-aa,r_.-.i-220-A6-Er podos have been radverlect to aro ,permits,`353ce has agreed.e Section 04-Public Comment Requirements Is Public Comment Required? If yes,why? Requ s irg Syr drew _ Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification • Is this stationary source a true minor? No` Is this stationary source a synthetic minor? • If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑✓ ❑ DOD Non-Attainment New Source Review(NANSR) ❑ ❑� Is this stationary source a major source? No Hydrocarbon Loadout Emissions Inventory 001 Liquid Loading Facility Al Rs ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit t : € T., � . r '� } y .ti zweNifplirDescription: ,224 -k» .,,„ ,..h...z"*, -..,..+ ,"Srs`a§r`t .m Emission Control D ��"` �'an w3 � '.2 "F' " - Description: 5*r v$ x 4 "f 49k t ay '. L _ � rd•`'x„ Is this loadout controlled? Collection Efficiency: Control Efficiency: Requested Overall VOC&HAP Control Efficiency%: _-r,._ Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Leadout Actual Volume Loaded= r* S`°r, S ;Barrels(bbl)per year Actual Volume Loaded While Emissions Controls 0perating= "NOM Barrels(bbl)per year 'Requested Permit Limit Throughput= g ,B i Barrels(bbl)per year Requested MonthlyThroughput= 76o4 Barrels(bbl)per month Potential to Emit(PTE)Volume Loaded= l' .„„s�..�Barrels(bbl)per year Secondary Emissions-Combustion Device(s) - Heat content of waste gas= ?a4Btu/sef Volume of waste gas emitted per year= '.2384e sef/year Actual heat content of waste gas routed to combustion device= 1 MMBTU per year Requested heat content of waste gas routed to combustion device= 2:9 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= _-'9 MMBTU per year Section 04-Emissions Factors&Methodologies Does the company use the state default issions factors to estimate emissions? Does the hydrocarbon liquid loading p tion utilize submerged filly ,,. :, ''� ,A , nay ,,,litVgA .: t M ,- , H FACEilleifirCIATMEIZEGIUMIESAIlfaZialliMMVILMENESINIESERINEWAIVERMINSINMEMINIENFIM 49f WW2;A.10.44.w.v/e/01,,bg%4Aikag',Kilv:ar 1,1N,614r,e4de-42,0042 ,14,ANK4afirtAtir-Z;40.0rAdkAa' A0 4 .n Hydrocarbon Loadout Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Volume (Volume Loaded) Loaded) IMMIECE MMEZEEM; Spleen ? n-Hexane -- P ___. Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) )Ib/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) .11211 MM. MEMO tk.AteLigia..442, 44 �... 2 of 10 K:\PA\2018\18 W E0235.CP1.zlsm i+ydlocArbon L O3tde ar-r --a"Sion _nvent',-7 . 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 000 0.:.. C_50 9.90 0.09 3 PM2.5 1.30 _.— 2.10 0.00 0.103 3 SOx 3.73 c 3: b... 0.00 C NOx 3.31 0__0 `;30 3-C1 0.01 2 VOC 1v's.32 =._1 .;.21 10.62 1.91 , CO oe, 0.:`€0 ..,. 0,0v 3s Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) (Ibs/year) (lbs/year) (lbs/year) Benzene __. 10 1g a7 _ 0,3009 Teluene 9 0 C. 0 0 0.0070 J Ethylbenzene v 0 0 S 0 0.0030 Xylene s 5 .. 0 9 C=.Oly00 n-Hexane 525 151 I _,.r rao Ira .3,6901 224TMP 0 - P 0 _ 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts.A,B 4 -;unit RACT-Regulation 3,part B,Section lll.D.2.a The 49,000.5 5..se 30 z_v 3 i.i- €=4,zr- 0--.r..,ss satis0,,909.- (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? ,„_L.; If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion dEvice based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes Source submitted an APES addendum in September,2019,to increase requested throughput. Suety changes to Regulation 7,control of Ioadouts above 5003 bbl per year is now required,with a compliance date of May 1,2021,for all existing sites.Because of this,I have asked the source to install a control device as part of this permit modification before the compliance date hits.Source has agreed.Actual volume listed was not controlled,since it was actual for before the combustor was installed. i , ,. ,:yXtgst:*,,eesoftks-rjgf,AppiiRmf_Vtfgzigf_Sit;;vstiwpfgxit;., ,,vz c v. .-r- . r „ , .a� _ u Section 09-Inventory SCC Coring and Emissions Factors Uncontrolled Emissions AIRS Point# Process ft SCC Code Pollutant Factor Control%Units 001 01 a.01 00,de O-...Sub,ne.oed Loading Norma:.a.a :S09.00 PM10 .i.3C v lb/1,000 gallons transferred PM2.5 1.15 e lb/1,000 gallons transferred 500 0.00 C lb/1,000 gallons transferred NOx - 0,71 c lb/1,000 gallons transferred VOC 5.' 45 lb/1,000 gallons transferred CO 0,02 7 lb/1,000 gallons transferred Benzene 5.0'1 95 lb/1,000 gallons transferred 'Toluene 0.80 95 lb/1,000 gallons transferred Ethylbenzene 0.90 95 lb/1,000 gallons transferred Xylene 9.00 .,_ lb/1,000 gallons transferred n-Hexane 0,39 95 lb/1,000 gallons transferred - 224 TMP s..,.. Sc lb/1,000 gallons transferred 3 of 10 K:\PA\2018\18WE0235.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B-APEN and Permit Requirements [Source .tta, ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B,Section II.D._ 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)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3,Part B,Sectioi (Source,_ ;nit 7. RACT-Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy(Regulation 3,Part B,Section III.D.2.a)? (The Ioadout must be operated with submerged fill to satisfy RACT. Disclaimer 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 i(,Cul O(7 .,.\:;:,.. ST..)•.-.,. e- :3. c`1:: l'1a-€i'.,:y. 002 Produced Water Tank Facility Alfts ID: 123 3F# ' 002 County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit i" " �::az.,.;. ' Description: BBLurodoc 'eaatoito* ' Emission Control Device •'•: t ` ( tttnmbuxto€ . Description: Requested Overall VOC&HAP Control Efficiency%: .;. .``• M1' Section 03-Processing Rate[Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Produced Water Throughput= ` ,aO0 Barrels(bbl)per year Actual Produced Water Throughput While Emissions Controls Operating= 30,6041 Requested Permit Limit Throughput= liie#0O70 Barrels(bbl)per year Requested Monthly Throughput= 339: Barrels(bbl)per month Potential to Emit(PTE)Produced Water ""`!-"" ' Throughput= '0PS;f000 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 'll i'il.4446 Btu/scf Volume of waste gas emittedlper BBL of liquids produced= .. -BO scf/bbl Actual heat content of waste,gas routed to combustion device= i...:—MMBTU per year Requested heat content of waste gas routed to combustion device= _ ::MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 2 1,1 MMBTU per year Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? ",_o-,-p- Emission Factors Produced Water Tank - Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source Pollutant (Produced (Produced Water Water Throughput) Throughput) VOC :`r: "Oio_Z_ ,_ 1.31E-02 Benzene W04:Rp' ''., 35004 Toluene 0.00E+0u 7 Ethylbenzene i'aRv 0 00En30 - Xylene ti ,,. . 0 h3_W n-Hexane i 'y 1.1rJ 03 tld: _ `lash}--,ac 224 TMP .✓„ 0.00E,00 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (Produced (waste heat Water combusted) Throughput)PM10 -`' OO075,,' 0.£04 AP-42 Table 142 2 PM2.5 a a.g' ', 3 0.0504 AP-42 T bl 1.42 25) NOx n'({ 0.0037 AP-42 Chapter :Fla t (`0.} lln CO i' 0.0107 AP-42 Ch:pter 13 ,„):Fla_,(LO) 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 52 48 01 0.2 73 4y PM10 0.0 0.0 0.0 0.0 0 0 PM2.S 0.0 0.0 0.0 0.0 0.0 NOx (IL 0.1 0.1 0.1 0 L ' .._ CO 0.5 0,3 0 3 0.3 0 3 5. 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 280 256 13 230 15 Toluene 0 0 C 0 •0 Ethylbenzene 0 C 0 3 Xylene 0 • 0 0 0 n-Hexane 880 803 40 880 44 224TMP 0 3 0 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,0 bourse fegvirrs 3 ye,mit Regulation 7,Section XVII.B,C.1,C.3 Storage tank is s:bier'ta Regulation 7,Section SS;:B C 1&•:i Regulation 7,Section XVII.C.2 Storage tank is subject to tehuiati4v 7,Section Mil:3.3 Regulation 6,Part A,NSPS Subpart 0000 Swage rani,is ant sab,?rt to`aS='5 O00 (See regulatory applicability worksheet for detailed analysis) 5 of 10 K:\PA\2018\18WE0235.CP1.xlsm Produced Water Storage Tank(s)Emissions inventory Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis?This sample should be considered representative which generally means site-specific and collected within one year of the application received date However,if the facility has not been modried e. no new wells brought on-line),then it may be a ( g, g ) Y appropriate to ¢y, � use an older site-specific sample. 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? If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes Source requested cancellation of GP08 in APEN addendum sent Sept 2019,to be replaced with individual permit. References within permit have been updated to reflect new Reg 7 references.STEM plan now applies forthis PW tank Section 09-Inventory 5CC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process R SCC Code Pollutant Factor Control%Units 002 01 4-04-003-15 Fixed Roof Tank,Produced Water,workings-breathings-flashing losses PM10 0.01 0 lb/1,000 gallons liquid throughput PM2.5 0.01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n-Hexane 0,52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput • 6 of 10 K:\PA\2018\18WE0235.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might he might he applicable for certain tanks at water management and injection facilities.If the tanks you are reviewing are at one of these facilities,please review NSPS Kb. Colorado Re:lotion 3 Parts A and B-APEN and Permit Requirements ATTAINMENT - 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? 2. Is the operatorclaiming less than 1%crude oil and is the tank located at a non-commercial facilityfor processing oil and gas wastewater?(Regulation 3,Part 0,Section ll.D.1.M) ;* 3. Are total facility uncontrolled VOC emissions greater th n 5 TPY,Novgreater than 10 TPY or CO emissions greater than SO TPY(Regulation3,Part B,Section 11.0.3)7 lYnF. Indicated nd categ S Vint. t k 3'_r., nt ran NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation3,Part A,Section l l.D.1.a)? X4 +''t"N''.f • 2. Is the operator claiming less than 1%crude oil and is the tank bated at a non-commercial facility-for processing ail and gas wastewater?(Regulation 3,Part B,Section ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2TPY,NOx greater than 5 TPY or CO emissions greater than 5 TPY(Regulation 3,Part 8,Section 11.0.2)? ISou-se.e_t r_ap.-3_t Colorado Regulation 7.Section XVII 1. Is this tank located at a transmission/storage fadlity? ..v 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? 3. Is this produced water storage tank a fixed roof storage tank? MOM 4. Are uncontrolled actual emissions°f th t ag tank equal to o greater than 6tons per year VOC? $.'t'�.,p�A IQ k5 sukir,t <Ts.05n7,S i {rl1,B.CAP.,3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVILC3-Emissions Control and Monitoring Provisions Section XVII.C3-Recardkeeping Requirements 5. Does the prodoced water storage tank contain only"stabilized"liquids?Ono,the following additional provisions apply. rti,.'"�5) IS=,, .cgu1uc10 7Set,tion XV!=C2 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CPR,Part 60,Subpart 0000,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?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? 7 t 3. Are potential VOC emissions'from the Individual storage vessel greater than or equal to 6 tons per year? j s".g 4. Does this produced water storageIra et the definition of"storage vessel'per 60.54307 '^£na3.4v ISt.c.Tage. to MPS DE3G0 Subpart A,General Provisions per§60.5425 Table 3 060.5395-Emissions Control Standards for VOC §60.5413-Testing and Procedures 460.5395(g)-Notification,Reporting and Recardkeeping Requirements 560.5416(c)-Cover and Closed Vent System Monitoring Requirements §60.5417-Control Device Monitoring Requirements •[Nate:Ifa storage vessel is previously determined to he subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tans per year] RACT Review RAC?review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area.tabs tank meets both criteria,then review RAC?requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation,or any otherlegally binding requirement andis 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(he 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 Nr Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. • Condensate S o'o ? rank(s)Emissions inventory 003 Condensate Tank 'Facility AfRs ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit `2,i,W41.40fir Descnpuon: Emission Control Device � 9sv Description z,,"�-. €,..,�;".^„pp�'ss-a�` `''ra,.,. -a ;t o-X'Yo✓ Requested Overall VOC&HAP Control vv; Efficiency% Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Condensate Throughput= ' 930-Barrels(bbl)per year Actual Condensate Throughput While Emissions Controls Operating= ,,... ;Barrels(bbl)per year Requested Permit Limit Throughput= ` vts'i Barrels(bbl)per year Requested Monthly Throughput= 2444 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= 108,0011 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= Btu/scf Volume of waste gas emitted per BBL of liquids produced= 22s.scf/bbl Actual heat content of waste gas routed to mmbustion device= ;.633 MMBTU per year Requested heat content of waste gas routed to combustion device= .5.191 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= _._< ?MMBTU per year Section 04-Emissions Factors&Methodologies • 41,4111161 , Will this storage tank emit flash emissions? Uncontrolled Controlled Pollutant (lb/bbl) (m/bbl) Emission Factor Source , (Condensate (Condensate Throughput) Throughput) ®' m re: ae' .. 10& 41C . r Iii f(A�.t-r* =EMI entainialaZiftinfitgi*%# =MOM ti;;;.AtintatIMEVEMPFilt, Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source waste heat (Condensate combusted) Throughput) MEMO PW47,74,TORZISEaraarriA: NOx _ 3100. �' 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 302.9 326.2 6.3 202.5 LAC 2-_44 PM10 G,"_ 0,0 0.0 0 1 0.3 10 PM2.5 "J:1 0.0 30 0.1 ,.1 10 NOx 0.0 0.a` 0.3 0.5 L 5 89 CO 2,3 1.Z 1 2 2,5 2.4 405 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 632 2"0 14 _.: 2? Toluene 400 _ ,.C 9 3.9 .. Ethylbenzene' 's8 1 48 _. Xylene 130 sa 3 132 n-Hexane 32'10 .:337 67 2673 -.1 224TMP 433 168 5 335 17 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requtre5 a permit Regulation 7,Section XII.C,D,E,F '.scrag taak is s_tziec;Ec 3PgtelatiOri 7,sec€:an xh,c,.F Regulation 7,Section Xll.G,C Storage Tank:v v3 53j&ct to Regulation 7,Sectlo.XI;11 Regulation 7,Section XVILB,C.1,C.3 sreragv'e..9is-33jecc`toneaulat'e.7,5ec1€cn R19,S,G.'&C.3 Regulation 7,Section XVII.C.2 Storage tank a:311 3319.:to Re- abort 7,Ser1ton X''.1,3.2 Regulation 6,Part A,NSPS Subpart Kb Stomp Ta=k is not s46jeci'3 15f'§KS Regulation 6,Part A,NSPS Subpart 0000 Storage Tank is rvt =ti€(=ct 13 aib`5 3000 Regulation 8,Part E,MACT Subpart HH Swags Tank=5 nor subiact t h H (See regulatory applicability worksheet fordetailed analysis) 8 of 10 K:\PA\2018\18WE0235.CP1.xlsm Condensate St.o ge--,nk=_j Emissions nve.7,ory, Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? _ If yes,are the uncontrolled acteal or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? ;figs. If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted?This sample should be considered representative which generally means site-specific and collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample. Nits, -. If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95%for a flare or combustion device? No - • If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes Source submitted an APEN addendum to reduce requested throughput Emission factors were developed from a site-specific sample References w,th,n permit have been updatee ro reflect nem Reg 7 references. e Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point 0 Process 8 SCC Code Pollutant Factor Control%Units 003 01 PM10 0.03 0 lb/1,000 gallons condensate throughput PM2.5 0.03 0 lb/1,000 gallons condensate throughput NOx 0.28 0 lb/1,000 gallons condensate throughput VOC 133.6 95 lb/1,000 gallons condensate throughput CO 1.26 0 lb/1,000 gallons condensate throughput Benzene 0.14 95 lb/1,000 gallons condensate throughput Toluene 0.09 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput 'Xylene 0.03 95 lb/1,000 gallons condensate throughput n-Hexane 0.71 -95 lb/1,000 gallons condensate throughput 224 TMP 0.09 95 lb/1,000 gallons condensate throughput 9 of 10 K:\PA\2018\18WE0235.CP1.xlsm • Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 PartsAand a-ADEN and Permit Re u ".:re s..__... ATTAINMEM 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan uTPY(Regulation 3,Part A,section 11.0.1.x)? 2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Aretotal facility uncontrolled VOC emissions greaterthan 5 TPY,N0x greater than in TPY or CO emissions greaterthan nO Try(Regulation 3,Part B,Section 11.0.3)? NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than(TPy(Regulation 3,Part A,Section 11.0.1.a)? ,PtSource Req 2. Is the construction date(service date)pi-Darla 12/30/2002 and notmodified after 12/31/2002(See PS Memo 0501 Definitions 1.12 nd1.14 and Secen 2for additional guidance on grandfather applicability)? =do � 'Go to next 3. Aretotal facility uncontrolled VOC emissions greater than 2 TRY,NOx greaterthan STPV or CO emissions greater than 1OTPY(Regulation 3,Part B,Section 11.0.2)? .".Source Req Colorado Regulation],Secd0n 1II.C-F� 1. Isthis storage tank located In the 8-hr as.control area or any ozone non-attainment area or attainment/maintenance area? Continue-' 2. Is this storage tank located at an oil and gasexploratlon and production operation",natural gas compressor station or natural gas drip station? • Continue-` 3. Is this storage tank located upstream of a natural gas processing plant? zy„'.::_'Source is Sc Section%11.0.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section t0.C.2—Emission Estimation Procedures Section 111.0—Emissions Control Requirements section 111.6—Monitoring Section%II.F—Recordkeeping and Reporting Colorado Regulation 7.Section 011.0 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? •., Continue- 2. Is this storage tank looted ate natural gas processing plant? Storage Tar 3. Doesthis storage tank exhbit`Flash(eft. g hli dlquids)emissions and have umantrolled actual emissions greater than or equal to 2 tons per year VOC? `!C4 .'$Source is se Section 011.0.2-Emissions ContraloequirementsL Section I11.e.1-General Requirements for Air Pollution Control Equipment-Prevention of Leakage Section 0110.2-Emission Estimation Procedures Colorado Regulation 7,Section 1VI1 1. Is this tank located at atransmission/storagefacilty? .. Continue- 2. Is this condensate storage tank`Messed at an oil and gas exploration and production operation,well production facility',natural gas compressor station'or natural gas processing plant? m Go to the n 3. Is the condensate storage tank a fixed rant storagetank'" kd, -Go to then 4. Are uncontrolled actual emosani of this storage tank equal to or greater than 6 tons per year MX? Yom- Source's.. Section 10/11.B—General Pravisiansfor Air Pollution Control Equipment and Prevention of Emission Section 10011.0.1-Emissions Contrd and Monitoring Provisions Section 1MI.C3-Recordkeeping Requirements 5. Doss the condensate storagetenk contain aniy'sta bl ed(quids? hd.J f Source is sc Section 1/11.0.2-Capture and Monitoring for StorageTanksfitted with Air Pollution Control Equipment 40 CFR,Part 60,Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vesel capacity greaterthan or equal to 75 cubic meters life)('472 B01s)? ph I Storage Tar 2. Does the storage vessel meet the-following exempten in na.111b(d)(4)? r. a.Does the vessel has a design capacity less than or equal to 1,589.874 m'(-10,000013L]usedtor petroleum'or condensate stored,processed,ortreated priorio custody transfer'as defined in 60.1116? 3. Was this candenzatesiorage tank nonstructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984? 4. Doesthetankmeet the definition of"storag II 60.111b? 5. Does the storage vessel stare a"vddatilearganic liquid 10001"s as defined in 60.1116? 6. Doesthe storage vessel meet any one ofthefollowing additional exemptions: a.Is the storage vessel a prsssure vsssel designed to operate in excess 0204.9 kra('39.7 psi]and without emissionsto the atmosphere l60.11ob(d)(2))?;or b.The design capacity is greaterthan or equal to 151 m'('950 BBL]and atones a liquid with a maximum true vapor pres e'lessthan 35 hot(60.11oblb))?;or c.The design capacity is greaterthan or equal to 75 Ste(-472 BBL]but less than 151 m'("950 Intl sod onurcas liquid with a maximum true vapor pressure°less than 15.0 kPa(60.11ob(b))? Subpart A,General Provisions • 460.1126-Emissions Control Standards for VOC 460.1136-Testing and Procedures 460.115b-Reporting and Recordkeeping Requirements §60.116b-Monitoring of Operations 40 CFR;Part 60,Subpart 0000,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution I. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processingsegment natural gas transmission and storagesegment of the Industry? Continue-' 2. Was this condensate storage vessel constructed,reconstructed,or modified(see definitions 40LFR,60.2)between August 23,2011 and September 10,2015? tfggr"uiim,_Storage Tar 3. Are potential VOC emssions'from the individual storage vessel greater than or equal to 6 tons per year? Y e, 4. ages this condensate storage vessel meet the definition of"storage vessel'per 60.5430? • �. 5. Is the storage vessel subject to andcontralled In accordance with requirements forstorage vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart FM? , ,,.. Subpart P.General Provisions eel-460.5425 Table 3 460.5395-Emissions Control Standards for VOC 460.5413-Testing and Procedures 460.5995(g)-Notification,Reporting and Recordkeeping Requirements 460,5416(c]-Cover and Closed Vent System Monitoring Requirements §50.5417-Control Device Monitoring Requirements (Note:If a storage vessel Is previously determined to be subjectte NSPS 0000 duets emissions above 6 tons per year VOC an the applicability determination date,it should remain subjectne NSPS 0000 per 60.5363(e)(2)even if potential VOC emissions drop below 6 tons per year] 40 CFR,Part 63,Subpart MACE 04,Oil and Gas Production Facilities 3. Is thestoagetank located at an ail and natural gas production facility that meets either of thefollowing criteria: I (Continue-' a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.76B(a)(2));OR b.A facility that processes,upgrades or stores natural gas prier to the point at which natural gas enters the natural gastransmission and storage source category or is delivered to a final end user'(63.760(a)(3)1? 2. Is thetank located at a facility that is major'for Hull? tdfi;"':t:,Storage Tar 3. Does thetank meet the definition of"storage vessel'^in 63.]61? 4. Does thetank meet the definition of"storage vessel with the potential for flash emissions"s per 63.761? 5. Isthetank subjectto control requirements under 40 CFR Part 60,Subpart Kb or Subpart 0000? Subpart A,General provisions per 463.764(a)Tablet 463.]66-Emissions Control Standards §63.773-Monitoring 463.774-Recordkeeping 463.]]5-Reporting RACT Review RACT review Is required if Regulation]does not apply AND if the tank is in the non-attainment area.lithe tank meets both criteria,then review BAR requirements. - Disclaimer This document assists operators with determining-applicability of certain regoirements of the Clean Air Act,,ds implementing regulafions,.and Air Quality Control Commission regulations.This document is not a rule ornegulation,and the analysis it contains may not apply to a particularsituation 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 thewvent of any conflict between the language of this document and the language of the Clean Air Act„its implementing regulations, and Air Ovally Control Commission regulations,the language of the statute er 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. f\QN i\cle,1e/Jcovx 1O/il Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: v ieo)5 AIRS ID Number: 123 /9FA3 / 001 [Leave blank unless APCD has already assigned a permit It and AIRS ID] Company equipment Identification: TL01 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Lost Creek 03-62-08-2H Production Facility Site Location: NWNW Sec 8 T3N R62W 40.24691/-104.352548 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 E -Mail Address2: bganong@verdadoil.com Site Location County: Weld NAICS or sic Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 '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 APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 1 I kCOLORADO RAV f=7:,r4ro Permit Number: AIRS ID Number: 123 i9FA3 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action El NEW permit OR newly -reported emission source ❑r Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name ❑ Change permit limit O Transfer of ownership3 ❑✓ Other (describe below) OR - APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - :I Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Currently permitted as GP07. Cancel GP07 with issuance of Construction Permit. 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: Hydrocarbon Truck Loadout For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 10/ 01 /2017 / / Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? if yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 O Yes ❑ No ❑ Yes ❑✓ No ❑ Yes El No El Yes O No ❑ Yes O No ❑ Yes O No ❑ Yes O No l V cowaaoo Permit Number: AIRS ID Number: 123 /9FA3/ 001 [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 0 Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth 90,000 Bbl/yr Actual Volume Loaded: 45,000 Bbl/yr This product is loaded from tanks at this facility into: trucks (eg, "rail tank cars" or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: 'F True Vapor Pressure Psia ®60 °F Molecular weight of displaced vapors Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: Bbl/yr Actual Volume Loaded: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 3 I partimatalblOle COLORADO eeaivaas„tnn a ❑ Upward ❑ Horizontal Permit Number: AIRS ID Number: 123 /9FA3/ 001 (Leave blank unless APCD has already assigned a permit " and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM)' 40.24691/-104.352548 6lperator Stack ID No. Discharge Height ' p Abtswe Level (Feet) Temp. f•F) Flow Rate (A£FM) veto ter," Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system: Requested Control Efficiency (t/ Combustion Device: Pollutants Controlled: Rating: Type: f_eck Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr c\c.) Waste Gas Heat Content Constant Pilot Light: g Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 41 R A DO Permit Number: AIRS ID Number: 123 /9FA3/ 001 [Leave blank unless APCD has already assigned a permit n and AIRS ID) Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes [✓ No I equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NOx CO VOC thc.loc to( Fiore 15 HAPsn�}6€c l lgf t 15% Other: Using State Emission Factors (Required for GP07) VOC ❑✓ Condensate 0.236 Lbs/BBL ❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 18/19 Use the following table to report the criteria pollutant emissions from source: Pollutant = Uncontrolled Emission Factor Emission Factor Units ,. Emission Factor Source (AP -42, Mfg. etc) `� , Actual Annual Emissions Requested Annual Emi art Permit Uncontrolled (Tons/year) Controlled5 (Tons/year) ' Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NOx VOC 0.236 lb/bbl CDPHE 5.31 5.31 10.62 0 .5 3 CO Benzene 0.00041 lb/bbl CDPHE 0.0092 0.0092 0.018 Toluene Ethylbenzene Xylenes n -Hexane 0.0036 lb/bbl CDPHE 0.081 0.081 0.16 ti.c °81 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 5j N«ate Y,tih5pgnHsrirtTs+?� Permit Number: AIRS ID Number: 123 /9FA3/ 001 [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 the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: Ei Draft permit prior to issuance ID 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 $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 6 I 07COLORADO " oL (Ze c . 0/1 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.cotorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 1% \ e O 2 AIRS ID Number: 123 /9N-3/002 (Leave blank unless APCD has already assigned a permit /t and AIRS ID] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Lost Creek 03-62-08-2H Production Facility Site Location: NWNW Sec 8 T3N R62W 40.24691/-104.352548 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Brad Ganong 720-845-6918 bganong@verdadoil.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 couoRAoo 1 I Alr , „1: -. YYYYYY mumarnYm v Permit Number: AIRS ID Number: 123 / 9AF3 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source Q Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP05 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. - OR ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) - OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: GP08 Permit Cancellation included in package. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage PW01 10/01/2017 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 ❑✓ Exploration & Production (EEtP) site weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? p Yes • No Are Flash Emissions anticipated from these storage tanks? p Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • ,./ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ✓ Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual• emissions ≥ 6 ton/yr (per storage tank)? Yes No p Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 Aw COLORADO 2 I ako`w �:a Permit Number: AIRS ID Number: 123 / 9AF3 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bb l year) 29,000 Requested Annual Permit Limits (bbl/year) 43,500 From what year is the actual annual amount? Tank design: Ej Fixed roof 2018/2019 ❑ Internal floating roof O External floating roof Storage torn ID # ofLiquid Manifold Storage : Yessets in Storage Tank `- Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) �. PW01 1 400 5/2017 10/2017 Wells Serviced by this Storage Tank or Tank Bette (E&P Sites,0in y :Number • ame of Well Newly Reported Well 05 -123 -44648 Lost Creek 03-62-08-2H (05-123-44648) s Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information eographical ;Coordinates`, Latitude/Longitude or U.TM) 40.24691/-104.352548 Operator Stack ID No " Discharge"""Height Above Ground Level (feet)- Temp. (°F) , Flow Rate (ACFM) Velocity: (ft/sec) EC01 20 1200 100 0.033 Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal ❑ Downward 0 Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 96 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO 3 I `k H.!nmb49+arrmri Permit Number: MRS ID Number: 123 / 9AF3 / 002 [Leave blank unless APCD has already assigned a permit fi 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑✓ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 12 Type: Enclosed Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: n/a MMBtu /hr Make /Model: 95 % 98 GCO Beast 3200 Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes O No Pilot Burner Rating: 1496 0.043 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EaP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —131 psig psig Describe the separation process between the well and the storage tanks: 1 x 3 -phase separator to heater treater to storage tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 '.'! 4.luilh hYfia1COLORADO 4 I Benzene 71432 VOC Permit Number: AIRS ID Number: 123 / 9AF3 / 002 [Leave blank unless APCD has already assigned a permit # 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): escription of Control Methods Overall Requested Contra Efficiency reduction in emissions) Enclosed Combustor 95 NOx CO HAPs Other: Enclosed Combustor 95 From what year is the following reported actual annual emissions data? 1 8/1 9 Criteria Pollutant Emissions Inventory ctual Annual Etnissjon. controlled asis z.: r e_quested Annua Emission Limits lb/bbl CDPHE Default 3.80 0.19 5.70 0.28 VOC 0.262 NOx 0.068 Ib/MMBtu AP -42 0.053 0.053 0.080 0.080 CO 0.31 Ib/MMBtu AP -42 0.24 0.24 0.36 0.36 ion -Criteria Reportable Pollutant. Emissions;invento mission Factor ncontrolled Basis Units CDPHE Default &dual Annual, Emissions ncontrolle missions ., (pounds/year) ontro(led misstonsg ounds%yeas) 0.0070 Ib/bbl 203.00 10.15 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 Ib/bbl CDPHE Default 638.00 31.90 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) 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. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 5 I o.r..mku(Aouk HWfAbthusratma o Permit Number: AIRS ID Number: 123 / 9AF3 / 002 [Leave blank unless APCD has aheady assigned a permit ii 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 GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO 6 I A‘1;4,�k %.;t3 Notat. 4,4- re c. L. I /1-i- pcf Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Qov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 / 9FA3 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Verdad Resources LLC Site Name: Lost Creek 03-62-08-2H Production Facility Site Location: NWNW Sec 8 T3N R62W 40.24691/-104.352548 Mailing Address: (include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Brad Ganong Phone Number: 720-845-6918 E -Mail Address2: bganong@verdadoil.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. COO DO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 1 I Permit Number: AIRS ID Number: 123 / 9FA3 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit El Request coverage under a General Permit 0 GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit. (check each box below that applies) O Change in equipment ❑ Change company name3 O Change permit limit ❑ Transfer of ownership4 ❑✓ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Currently permitted as GP01. Cancel GP01 with issuance of Construction Permit. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate Storage Tanks TK01-03 10/01/2017 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: El Exploration & Production (E&P) site weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? Yes No © ■ Are Flash Emissions anticipated from these storage tanks? Yes No p ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No ■ GI If "yes", identify the stock tank gas -to -oil ratio: 0.014 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No 12 Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualSI emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 2 I ACOLORADO ,:.: Permit Number: AIRS ID Number: 123 I 9FA3 / 003 (Leave blank unless APCD has already assigned a permit ii and AIRS ID] Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbl/year) 45,000 From what year is the actual annual amount? 2018-2019 Average API gravity of sales oil: --39 degrees O Internal floating roof Tank design: ❑✓ Fixed roof Requested Annual.Permit Limits (bbl /year) 90,000 RVP of sales oil: -8 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage'; Vessels in Storage.Tank , ; Total Volume of ^ - Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date ,of First Production (month/year) TK01-03 3 1200 05/2017 10/2017 API Number ells Serviced.by this Storage Tank or Tank Battery6;(E&P-Sites Only) lame of Well Newly Reported Well 05 - 123 - 44648 Lost Creek 03-62-08-2H (05-123-44648) O O O 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The El'&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or 40.24691/-104.352548 Operator -Stack" ID No Discharge Height Above Ground Level (feet) ,; Temp ' (°F) ; Flow Rate (ACFM) ` , Velocity {ft/sec) EC01 20 1200 100 0.033 Indicate the direction of the stack outlet: (check one) ❑� Upward O Downward 0 Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular O Square/rectangle 0 Other (describe): O Upward with obstructing raincap Interior stack diameter (inches): 96 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 1°71;72°L,, 3 I _ NwmRx Permit Number: AIRS ID Number: 123 / 9FA3 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 12 MMBtu/hr Type: Enclosed Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: n/a GCO Beast 3200 Waste Gas Heat Content: Constant Pilot Light: ❑Q Yes ❑ No Pilot Burner Rating: 2145 0.042 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —131 psig psig Describe the separation process between the well and the storage tanks: 1 x 3 -phase separator to heater treater to storage tanks Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 AV,..'COLORADO 4 Ia r Benzene VOC Permit Number: AIRS ID Number: 123 / 9FA3 / 003 [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 8 - Emissions Inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): escription of Control Methods) Overall Requested Control Efficiency" (% reduction in emissions) Enclosed Combustor 95 NOx CO HAPs Other: Enclosed Combustor 95 From what year is the following reported actual annual emissions data? 2018-2019 Criteria Pollutant Emissions inventory source (AP -42, Mfg•, etc.) Uncontrolled Emissions (tons/year) 6.31 Requested, Annual Fermi Emission Limit(s) nc"ontrotled Emisnssio 'tons/year). 12.62 VOC 5.61 Ib/bbl Site -Specific 126.23 252.46 NOx 0.068 Ib/MMBtu AP -42 0.28 0.28 0.54 0.54 CO 0.31 Ib/MMBtu AP -42 1.21 1.21 2.40 2.40 on -Criteria Reportable Pollutant Emissions Inventory emical Abstract . Service (CAS) Number_. Emission Factor ctuai Annual" Emission Uncontrolled Basis Units Source (AP -42_ Mfg., etc - 270.00 13.50 71432 0.0060 Ib/bbl Site -Specific Toluene 108883 0.0038 Ib/bbl Site -Specific 170.00 8.50 Ethylbenzene 100414 0.00044 Ib/bbl Site -Specific 20.00 1.00 Xylene 1330207 0.0012 Ib/bbl Site -Specific 54.00 2.70 n -Hexane 110543 0.030 Ib/bbl Site -Specific 1,336.00 66.80 2,2,4- Trimethylpentane 540841 0.0037 Ib/bbl Site -Specific 168.00 8.40 5 Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 5 I Cagatmeatiftatie COLORADO nn4mtrItruneaim.s Permit Number: AIRS ID Number: 123 / 9FA3 / 003 [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 GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager 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, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.Qov/cdphe/aped Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 3/2019 6 I AVcowswtro �t�x Hello