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Home My WebLink About20201596.tiff a -w:<� COLORADO ' 'V Department of Public CO"E Health b Environment RECEIVED MAY 0 4 2020 Weld County Clerk to the Board WELD COUNTY COMMISSIONERS 1150 O St PO Box 758 Greeley, CO 80632 April 29, 2020 Dear Sir or Madam: On April 30, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Verdad Resources LLC - Rohn 9-60-14A Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health £t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator � c OF CoLpf 4300 Cherry Creek Drive 5., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe (,m . i Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director I (* , x *. Pubic Rev; et,.) cc:p�(Tp),HL(iitlPt„1(sa./ER/ct-I/cK), 2020-1596 6/T/zo o&csiA) 5/29/2O MtMaM Air Pollution Control Division 4 ,• Via �Y Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Verdad Resources LLC - Rohn 9-60-14A Pad - Weld County Notice Period Begins: April 30, 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 Resources LLC Facility: Rohn 9-60-14A Pad Well Production Facility NWSE of Section 14, Township 9N, Range 60W Weld County The proposed project or activity is as follows: The operator is requesting permit coverage for crude oil storage vessels, produced water storage vessels, hydrocarbon liquid loadout, and natural gas venting from heater treaters at a new synthetic minor oil and gas well production facility located in the ozone attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0993, 19WE0994, 19WE0995 ft 19WE0996 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.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public1 Health Environment la p N E Crude Oil Storage Tank(s) APEN '7` Form APCD-210 04,, CO Air Pollutant Emission Notice(APEN)and Ian Application for Construction Permit $41 All sections of this APEN and application must be completed for both new and existing facilities,including updates.Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. condensate storage tanks,produced water storage tanks,hydrocarbon liquid loading,etc.). inn addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)website at www.colorado.eov/pacificicdphe/air-permits. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No.3,Part A, II.C.for revised APEN requirements. Permit Number. lei WE$fig 3 MRS ID Number: /2.3 /A#t /OO (Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 1 -Administrative Information Company Name': Verdad Resources LLC Site Name: Rohn 9-60-14A Pad Site Location Site Location* NWSE Sec 14 T9N R60W County: Weld 40.748536/-104.058703 NAICS or SIC Code: 1311 Mailing Address: pew,zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Contact ten: Brad Ganong Phone Number: 720-845-6918 E-Matt Address2: bganong@verdadoii.com • r Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes wilt require additional paperwork. 2 Permits,exemption fetters.and any processing invoices will be issued by the APCD via e-mail to the address provided. Ayr COtO,*DO Form APCD-210-Crude Oil Storage Tank(s)APEN- Revision 3/2019 1 ► cAllaV "i" Permit Number: et 0:t4IS MRS ID Number: 113 Oa1b /cot [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 2-Requested Action 0 NEW permit OR newly-reported emission source O Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested,the General Permit registration fee of 5312.50 must be submitted along with the APEN filing fee, -OR- • MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment ❑ Change company name3 O Change permit limit 0 Transfer of ownership4 0 Other(describe below) ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADomormt PEnMrr Across- ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info a Notes: Initial permit application. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 General Information General description of equipment and purpose: Crude oil atmospheric storage Company equipment Identification No. (optional): TK01-08 For existing sources,operation began on: For new or reconstructed sources,the projected start-up date is: 9/18/2019 Normal Hours of Source operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration ft Production(E&P)site O Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? O Yes 0 No Are Flash Emissions anticipated from these storage tanks? 0 Yes 0 No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes 0 Na 805 series rules?If so,submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual �� Y n No emissions a 6 ton/yr(per storage tank)? pp co.arraoa Form APCO.210-Crude Oil Storage Tank(s)APEN Revision 3/2019 2 1 >i31 Permit Number: MRS ID Number: 113 / j C [Leave blank unless APCD has already assigned a permit P and AIRS ID) Section 4-Storage Tank(s)information Actual Annual Amount Requested Annual Permit Limits (bb(lyegr).. . . (big/year) Crude Oil Throughput: 225,000 292,500 From what year is the actual annual amount? Prajected Average API gravity of sales oil: 35.5 degrees RVP of sates oft: 7.1 Tank design: ❑Fixed roof ❑Internal floating roof ❑External floating roof Storage I of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First t a Vessels In Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank;(monthlyear) ( h/yam) TK01-08 8 3,200 08/2019 09/2019 Wells Serviced by this Storage Tank or Tank Battery's(E&P Sites Only) API Number Name of Well: . .. N Newly Reported Well 05 -123 47781 Rohn 9-60#14A-23-1(05-123-47781) ❑ 05 - 123 -47780 Rohn 9-60#14A-23-3(05-123-47780) ❑ 0 0 5 Requested values wilt become permit limitations.Requested limit(s)should consider future growth. •The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5_Stack Information Geographical Coordinates (Latittd.lLongitude or UTM) 40.748536/-104.058703 Operator Stack Discharge Height Above Temp. now Rate Velocity ID No. Ground Level(feet) (aF) (ACFM) (ft/sec) EC01 20 1000 25 0.026 Indicate the diroc-lkn of the stack outlet(check one) El Upward 0 Downward ❑Upward with obstructing raincap [Horizontal ❑Other(describe): Indicate the stack opening and size:(check one) Q Circular Interior stack diameter(inches): 54 ❑Square/rectangle Interior stack width(inches): Interior stack depth (inches): ❑Other(describe): ocoeta0 Form APCD-210-Crude Oil Storage Tank(s)APEN-Revision 3/20143 Permit Number: tGivaU��l� AIRS ID Number: as /,os 1fl/ t [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6-Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Requested Control Efficiency: Unit(VRU): VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC/HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model:GCO ECD2000 OCombustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 99 Minimum Temperature: N/A Waste Gas Heat Content: 21,s.'N.i Btu/scf Constant Pilot Light: O Yes ❑ No Pilot Burner Rating: 0,050 MMBtu/hr Description of the closed loop system: O Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7-Gas/Liquids Separation Technology Information (ESP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —30 psig psig Describe the separation process between the well and the storage tanks: Produced fluids from the wells are directed to two 3-phase horizontal heated separators. From the separators,oil is directed to the two 3-phase vertical heater treaters for further separation and pressure reduction. From the heater treaters, oil is directed to the atmospheric storage tanks. 'aceKti t. rig a ce pl ctibOK . V 1' Itoto p COiO* DO Form APCD-21O Crude Oil Storage Tanks)APEN-Revision 3/2019 4 I �] __<» Permit Number: AIRS ID Number:// 1°iva 014i l23 Ai115 cot (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(1r reduction): Overall Requested Control Pollutant Description of Control A4t od(s) Efficiency VOC Endosed combustor 99 NOx CO NAPS Enclosed combustor 95 Other. From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions inventory Requested Annual Permit Emission Factor? Actual Annual Emissions Emission limit(s Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42. Emissions enissionsa Emissions Emissions 8as Mfg.,etc) (tons!year) (tans/year) (tons/Year) (tom/Yenr) VOC I.'stit lb/bbl site-specific rli.,:41 =S2 fyb< i 9;sL NOx o.arLit lb/tibl Calculated GAR cr.1;, 8:3&a : 848 0.4.1 4349 o.'it Co 0-011- ibbbl Calculated i 67 t,t} 4-11/1 2.16.4.14 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor' Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncoasis d Units (AP-42, Emissions Emissions Number Mfg.,etc.) (pounds/year) pounds/gear) Benzene 71432 3.511+K33 lblbbl site-specific tot.; Toluene 108883 3 rx•xto Ib/bbi site-specific A A ?*i.5 Ethylbenzene 100414 41- ta"1 Ibbbl site-specific lcrl-t- S+ Xylene 1330207 t.o s-7. lb/bbl site-specific uc n-Hexane 110543 Soi x i` Ibbbl site-specific v it t%,cam 3'f+•9 2'2'4 540841 41.,s e m s h/bbl site-specific t3:4 c 1 Trimethylpentane S Retested values will become permit limitations.Requested limit(s)should consider future growth. 7 Attach crude oil laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. $Annual emissions fees wilt be based on actual controlled emissions reported.If source has not yet started operating,leave blank "11411 fa Form APCD-210 Crude Oil Storage Tank(s)APEN Revision 3/2019 5 A • " *: Permit Number: AIRS ID Number. ( i !OCR% (Leave blank unless APC0 has already assigned a permit#and MRS IN Section 9 Applicant Certification I hereby certify that all information contained herein and information submitted with this application Is complete, true,and correct.If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be operated in full compli e with each condition of GeneralPermit GP08. if/if/61// Signature of Legally z erson(not a vendor or consultant) Date Michael Cugnetti Director of EHS and Regulatory Name(print) Title Check the appropriate box to request a copy of the: ❑Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No.3,Part A,II.C.for revised APEN requirements. Send this form along with 5191.13 and the General Permit For more information or assistance call: registration fee of S312.50,ff applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 0. • e Denver,CO 80246.1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.aov/cdphe/aped " Do Form APCD-210-Crude Oil Storage Tankis►APEN-Revision 3/2019 6 i AWAV to I is A CDPHE Produced Water Storage ornoy /� ► 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.An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal.. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations.If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g.. crude oil storage tanks,condensate storage tanks,hydrocarbon liquid loading,etc.).in addition,the General APEN (Form APCD 200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN farms and associated addendum forms can be found on the Air Pollution Control Division(APED) website at:www.colorado.eovioacifickdohe/air-oermits. 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 Numbers /g1,,c/E 03111 f. AIRS ID Number. r3 /Am p iod 2✓ (Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Verdad Resources LLC Site Name: Rohn 9-60-14A Pad Site Location Site Location: NWSE Sec 14 T9N R6OW County: Weld 40/48536/-104.058703 NAICS or SIC Code: 1311 Mailing Address`anode Zip Code} 1125 17th Street, Suite 550 Denver, Colorado 80202 Permit Contact: Brad Ganong Phone Number. 720-845-6918 E-Mail Address2: bganong@verdadoii.com Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by APCD via e-mail to the address provided. • OW? cocon•oe Form APCD-207 Produced Water Storage Tarnk(s)APEN Revision 07!2017 1 ( AV � . Permit Number: t9 MRS AIRS ID Number: (- ✓Anti rot (Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 2- Requested Action 0 NEW permit OR newly-reported emission source 0 Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP05 O GP0B If General Permit coverage is requested,the General Permit registration fee of 5250 must be submitted along with the APEN filing fee. -Oit- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name ❑ Change permit limit O Transfer of ownership.) O Other(describe below) -Olt- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -Aoornomm.Pow Acrloris- ❑ 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: Initial permit application. 3 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3-General Information General description of equipment and purpose: Produced Water Storage Tanks For existing sources,operation began on: For new or reconstructed sources,the projected start-up date is: 9/18/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration&Production(E&P)site O Midstream or Downstream(non E&P)site Wilt this equipment be operated in any NAAQ5 nonattainment area? O Yes 0 No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes 0 No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? 0 Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ 805 series rules?If so,submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual El Yes ❑ No emissions a 6 ton/yr(per storage tank)? _ CDI0 ADO Form APCD-2O7-Produced Water Storage Tank(s)APEN-Revision 07/2017 2 I r` ` "� Permit Number: 14t.k)ECfri`-1 AIRS ID Number: 123 /Ao. / [Leave blank unless APCD has already assigned a permit d and AIRS ID) Section 4 Storage Tank(s)Information Actual Annual Amount Requested Annual Permit Limit4 I Produced.Water Throughput: 150,000 22 ,oot3 From what year is the actual annual amount? Projected Tank design: QQ Fixed roof O Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in storage Tana Storage Tank Recent Storage Vessel in Production vessels (bbI) _ Storage Tank(month/year) (month/year) PW01-02 2x 400 bbl 800 08/2019 09/2019 Wells serviced by this Storage Tank or Tank Batter?(EDP Sites Only) API Number Name of Well Newly Reported Well 05 123 -47781 Rohn 9-60#14A-23-1 (05-123-47781) 0 05 - 123 -47780 Rohn 9.60#14A-23-3(05-123-47780) al - O O •Requested values will become permit limitations.Requested limit(s)should consider future growth. S The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5-Stack information Geographical Coordinates (Latitude/Longitude or UTM) 40.748536/-104.058703 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°) (ACFM) (ft/sec)_ EC01 20 1000 25 0.026 Indicate the direction of the stack outlet:(check one) 0 Upward O Downward O Upward with obstructing raincap Q Horizontal O Other(describe): indicate the stack opening and size:(check one) Q Circular Interior stack diameter(Inches): 54 ❑Square/rectangle interior stack width(Inches): Interior stack depth(inches): O Other(describe): AwsC 910RAD0 ltAW-> Form APCD-207-Produced Water Storage Tank(s)APEN - Revision 07/2017 3 O4 tt 010 Permit Number: i9u)C<OM AIRS ID Number: 1a / ij/ � (Leave blank unless APCD has already assigned a permit a and AIRS ID) Section 6 Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: % VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC/HAPs Rating: MMBtu/hr Type: Enclosed Comiwators make/M«de:GCO ECD2000 o Combustion Requested Control Efficiency: 9, Device Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: n/a Waste Gas Neat Content: 1496 Btu/scf Constant Pilot Light: Yes 0 No Pilot Burner Rating: 0.050 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: % Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —30 psig Describe the separation process between the well and the storage tanks: Produced fluids from the wells are directed to two 3-phase horizontal heated separators. From the separators,fluids are directed to two 3-phase vertical heater treaters for further separation and pressure reduction. Produced water at the horizontal separators and heater treaters is directed to the storage tanks. Viii , ic/E-. iuM,. b`J crIttc iotz cooli.Do Form APCD-2O7 Produced Water Storage Tank(s)APEN-Revision 07/2017 i Q�C' "" Permit Number: i°1 tOE t7°1 AIRS ID Number: 1't~'3 / Q/ cs✓L [leave blank unless APCD has already assigned a permit k and AIRS ID] Section 8- Emissions inventory Information Attach all emissions calculations and emission factor documentation to this APEN form'. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall (or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency VOC G enclosed camiw.ior as NOx CO HAPs wooedd Combustor 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factors Actual Annual Emissions Emission Limit(s)4 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled units (Ap-42, Emissions Emissions, Emissions Emissions Sash Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) yOC 0.262 - ib/bbl CDPHE 19.65• 0.98 21 H4 i NOx 0.0037. Ib/bbl Calculated 0.27. 0.27 • o,-l o,y1 Co 0.017• ibtbbi Calculated 1.25 • 1.25 1.4s • } �{ • Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor° Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions? Number 12411516 Mfg.etc) (Pounds/year) (Pounds/year) Benzene 71432 0.0070 - lb/bbl CDPHE 1,050.00 52.50• Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.022 • lbibbl CDPHE 3,300.00 • 165.00 • 2'2'4 540841 Trimethylpentane 4 Requested values will become permit limitations.Requested limit(s)should consider future growth. '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. r Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. [ 1' CL 11 ls •s- . H 0411 4' 2 ?'1., cOLORACO Form APCD-207-Produced Water Storage Tank(s)APEN-Revision 07/2017 5 AtV � Permit Number: jt MRS ID Number: as 7Ac ic>/ (X)L [Leave blank unless APCD has atready assigned a permit$and AIRS ID) • Section 9 -Applicant Certification I hereby certify that alt information contained herein and information submitted with this application is complete,true and correct.If this is a registration for coverage under General Permit GPO5 or GP08, !further certify that this source is and will be operat n full compliance with each condition of the applicable General Permit l fA/i7 Signature of Legally Person(not a vendor or consultant) Date Michael Cugnetti Director of EHS and Regulatory Name(print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No.3,Part A,11.C.for revised APEN requirements. Send this form along with$152.90 and the General Permit For more information or assistance call: registration fee of$250,if applicable,to: Colorado Department of Public Health and Small Business Assistance Program Environment - (303)692.3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver,CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303)692-3150 p color oo Form APCD-2O7 •Produced Water Storage Tankis)APEN Revision 07/2017 6 i Si -. '.. CD PH E Hydrocarbon Liquid Loading APEN - Form APCD-208 0C! Li Air Pollutant Emission Notice(APEN)and ,q alp CO ! Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities,including APEN updates.An application with missing information may be determined incomplete and may be returned or result in longer application processing times.You may be charged 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/cdohe/aped. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc).See Regulation No.3,Part A,iI.C.for revised APEN requirements. Permit Number: /9WE09(i5 AIRS ID Number. ,23 / f,/o 03 [Leave blank unless APCD has already assigned a permit#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: Rohn 9-60-14A Pad Site Location Site Location: NWSE Sec 14 T9N R6OW County: Weld 40.748536/-104.058703 NAICS or SIC Code: 1311 MailingdAddress: Zlp 112517th Street, Suite 550 (Include lip Cock) Denver, Colorado 80202 Permit Contact: Brad Ganong Phone Number: 720-845-6918 E-Mail Address2: bganong@verdadoil.com 'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.My changes will require additional paperwork. z Permits,exemption letters,and any processing invokes wilt be issued by APCD via e-mail to the address provided. caiorr•oo Form APCD 208 Hydrocarbon Liquid Loading APEN Rev 02/2017 1 I � »woe r xa.*maw) Permit Number: , , AIRS ID Number: 12.3 'Atoll/ i. [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2-Requested Action 0 NEW permit OR newly-reported emission source 0 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) • Change fuel or equipment O Change company name • Change permit limit O Transfer of ownership; O Other(describe below) -Oft- ❑ APEN submittal for update only(Blank APENs will not be accepted) -AnomoNAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info 8 Notes: Initial Application 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 09/ 18 /2Q19 start-up date is: Witt this equipment be operated in any NAAQS nonattainment area? O Yes No Is this equipment located at a stationary source that is considered a Major Source of(HAP) Yes ❑ emissions? No Does this source toad gasoline into transport vehicles? O Yes ❑ No Is this source located at an oil and gas exploration and production site? 0 Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual O Yes Elaverage? No Does this source splash fill less than 6750 BBL of condensate per year? O Yes O No Does this source submerge fill less than 16308 BBL of condensate per year? O Yes O No coiaht.00 Form APCD-208-Hydrocarbon Liquid Loading APEN-Rev 02/2017 2 i AV C01.0i: - Permit Number: FLUCe( ,S AIRS ID Number: 113 ! / co.s [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 Process Equipment Information Product Loaded: 0 Condensate ❑i Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Actual Volume Loaded': 292,500 sw/yr Loaded: 225,000 sbl/yr 4 Requested values will become permit limitations.Requested limit(s)should consider future process growth 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: Average temperature Saturation Factor: 'F of bulk liquid loading: True Vapor Molecular weight of Lb/lb-mot Pressure Psia®60'F displaced vapors If this APEN is being filed for vapors displaced from pressurized loading tines, complete the following: Requested Volume BbtJyr Actual Volume yr Loaded: Loaded: 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 Air !."D Permit Number: IQ v3E.cn9S AIRS ID Number: (Leave blank unless APCD has already assigned a permit 4 and AIRS ID) Section 5 - Geographical information Geographical Coordinates (Latitude/longitude or UTM 40.748536/-104.058703 Discharge Height Temp. Flow Rate Velocity Smock ID No. Above Ground Level CF) (ACFM) (ft/sec) EC01 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑Q Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): Other (describe): O Upward with obstructing raincap Section 6 Control Device information 0 Loading occurs using a vapor balance system: Requested Control Efficiency 100 [Li Device: Device: Pollutants Controlled: VOC, HAPS Rating: Type: Endosed Combustor Make/Model: GCO ECD2000 Requested Control Efficiency: MMBtu/hr 95 % Manufacturer Guaranteed Control Efficiency 98 % Minimum Temperature: nfa Waste Gas Heat Content 2:44.s.crA Btu/5d Constant Pilot Light: p Yes O No Pilot burner Rating 0.050 MMBturhr O Other: Pollutants Controlled: Description: Control Efficiency Requested Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 pA caaOR+aa m Permit Number: Ic1 o'iq AIRS ID Number. im f ^ID/ coo [Leave blank unless APCD has already assigned a permit X 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? Q Yes O No If yes, describe the control equipment AND state the overall control efficiency (% reduction): PM Overall Requested Control Efficiency (% reduction in omissions) SO. NO, CO VOC vapor balance /combustor 100/95 HAPs vapor balance / combustor 100/95 Other: Q Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0,236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL El Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Factor Source (AF42, Mfg. etc) Actual Annual Emissions Requested Annual Emission Perm* Limit(s) Controlled (Tonsf ) Uncontrolled (Tau/year) Controlled' (Taneyeer) Uncontrolled (Tant/ln ar) PM SOx NO, O.00015 . lb/bbl Ap-42/Calc 0.017 . 0.017 . 0.022 • 0.022 • V0C 0.104` Ib/bbi CDPHE 11.70 . 0.59 • 15.21 0.76 CO 0.0004o . Ib/bbl Ap-42/Calc 0.078 - 0.078 0.10 - 0.10 Benzene 0.00018 • lb/bbl CDPHE 0.020 0,0010 , 0.026 . 0.0013 -- Toluene Ethylbenzene Xylenes n -Hexane 0.0016 . lb/bbl CDPHE - 0.18 . 0.0090' 0.23 • - 0.012- 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees wilt be based on actual controlled emissions reported. if source has not yet started operating, leave blank. ickLAAt Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 AV eo►o,e.aa 5 I Kbb Permit Number: fito..1CO ' AIRS ID Number: ELs /Anti c> 'S, [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 wi each condition of the applicable General Permit. /07/qhf r^" Signature of Legally zed Person(not a vendor or consultant) Date Michael Cugnetti Director of EHS and Regulatory Name(print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance jai Draft permit prior to public notice (Checking any of these boxes may result in an increased fee andtor 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 For more information or assistance call: Permit registration fee of$250 as applicable to: Colorado Department of Public Health and Small Business Assistance Program Environment (303)692.3175 or(303)692.3148 Mr Pollution Control Division APCD-SS-B1 Or visit the APCD website at: 4300 Cherry Creek Drive South Denver,CO 80246-1530 https://www.colorado.gov/cdphe/apcd Make check payable to: Colorado Department of Public Health and Environment Telephone: (303)692-3150 ! caws&ea Form APCD-208-Hydrocarbon Liquid Loading APEN Rev 02/2017 6 ( ,ve ; CDPHE Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice(APEN)and co b- Application for Construction Permit RP-cp./vat, All sections of this APEN and application must be completed for both new and existing facilities,including updates.Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it ris 11?0a filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will requf cti payment for a new filing fee. ria , This APEN is to be used for gas venting only.Gas venting includes emissions from gas/liquid separators,well t casing,pneumatic pumps,blowdown events,among other events. If your emission unit does not fall into this category,there may be a more specific APEN for your source(e.g.amine sweetening unit,hydrocarbon liquid loading,condensate storage tanks,etc.). In addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.colorado.Rov/cdphe/aped. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No.3,Part A, II.C.for revised APEN requirements. Permit Number: I q W E AIRS ID Number: 1123 /op/o fl it [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Verdad Resources LLC Site Name: Rohn 9-60-14A Pad Site i ocatian: NWSE Sec 14 T9N R60W Site Location Weld 40.748536/-104.058703 NAICS or SIC Code: 1311 Mailing address: 1125 17th Street, Suite 550 (Include •zip Code) Denver, Colorado 80202 Contact Person: Brad Ganong Phone Number: 720-845-6918 E-Mail Address2: bganong@verdadoil.com 'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. • 420861 AT, CD OR ADO Form APCD-211 -Gas Venting APEN - Revision 3/2019 1 I x... Permit Number; 19 i�t?t"ort i to MRS ID Number: //4101W (leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2-Requested Action O NEW permit OR newly-reported emission source -OR- O MODIFICATION to existing permit(check each box below that applies) ▪ Change fuel or equipment O Change company name3 ❑ Add point to existing permit ❑ Change permit limit O Transfer of ownership'. O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -Aoornot4m.PERMIT ACnoNs- ▪ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info a Notes: Initial Permit Application 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: Heater Treater venting during VRU compressor downtime Company equipment identification No. (optional): HT-VENTO1 For existing sources,operation began on: For new,modified,or reconstructed sources,the projected start-up date is: 09/18/2019 ❑Check this box if operating hours are 8,760 hours per year;if fewer,fill out the fields below: Normal Hours of Source hourslday daystweek weeks/year Operation: variable variable variable Will this equipment be operated in any NAAQS ❑ Yes Q No nonattainment area? Is this equipment located at a stationary source that is Yes ❑ No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No.7, ❑ Yes ❑ No Section XVII.G? COLD4woO Form APCD-21l -Gas Venting APEN-Revision 3/201Q 2 I A Permit Number: tq we s to MRS ID Number: 1';.l/Aim!000,4 [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 4-Process Equipment Information • Gas/Liquid Separator ❑ Weil Head Casing O Pneumatic Pump Make: Model: Serial//: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/gist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event © Other Description: Heater Treater If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator,you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes 0 No Vent Gas BTll/SCF Gas Venting Heating Value: Process Parameters: Requested: MMSCF/year Actual: MMSCF/year -OR- Liquid Throughputs Requested: kk,- .OO O bbl/year Actual 9,000 bbl/year Process Parameter Molecular Weight: y3Wgz VOC(Weight%) ,11_ Benzene(Weight%) o-s Vented Gas Toluene(Weight%) 0.t'14( Properties: Ethytbenzene(Weight%) oosi�l Xytene(Weight%} 041.4 n-Hexane(Weight%) 2,2,4-Trimethylpentane(Weight%) acassi Additional Required information: ❑ Attach a representative gas analysis(including BTEX$n-Hexane,temperature,and pressure) El pressure) a representative pressurized extended liquids analysis(including BTEX Et n-Hexane,temperature,and pressure) S Requested values will become permit limitations.Requested limit(s)should consider future process growth. pq COIOIAQO Form APCD-211 -Gas Venting APEN Revision 3/2019 3 ( and "" "' Permit Number ttiti3eurt . AIRS ID Number. as /Am/ 00,4 (Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 5-Stack Information Geographical Coordinates 40/485361-104.058703 1Dpeaikor 1Feinp. Flow Rate Velocity Bta t iD No. iit1►a[ f) t 1 (JCIstr) ECO1 20 1000 25 0.026 indicate the direction of the stack outlet:(cherkone) 0 Upward O Downward ❑Upward with obstructing raincap O Horizontal O Other(describe): indicate the stack opening and size:(check one) 0 Circular interior stack diameter(inches): 54 ❑Other(describe): Section 6-Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Size: Make/Model: VRU: Requested Control Efficiency VRU Downtime or Bypassed: Pollutants Controlled: VOC/HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: GCO ECD 2000 LT-1 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: N/A Waste Gas Heat Content tti Btu/scf Constant Pilot Light 0 Yes O No Pilot burner Rating: 0.050 MMBtu/hr Pollutants Controlled: Other: Description: Requested Control Efficiency: % coLoa.ua Form APCD-211 Gas Venting APEN-Revision 3/2414 4 I �� z=" a a�pp�x Cite 1 Permit Number: 19tatp. l9ty AIRS ID Number: fa /, d 00,4 (Leave blank unless APED has already assigned a permit#and AIRS ID) Section 7-Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(x reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency PM Sl?x NO; CO VOC Enclosed Combustor 95 HAPs Encased Combustor 95 Other: From what year is the following reported actual annual emissions data? projected Criteria Pollutant Emissions inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Lbrnit(s)s Pollutant Source Unco nt oiled llpcoptrolied Controlled BasisUncontrolled •units ( 2. Emissions Emis;iorts6 Emissions Endssiori$ Mfg.,etc.) (tons/year) Rona/year) (tons/year) (tons/you) PM SOx NO, o.o,L. Ibibbl Cat/AP-42 Ma53 0.0s3 t3•04+$ q>Ct4Q CO x,053 Ib)bbl Cat/AP-42 am p.1% 0.31 VOC tt,-?ES lblbbl Site Specific Zei.Z$ t.MJ 'yo. 'k 1.14 Non-Criteria Reportable Pollutant Emissions Inventory chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Uncontrolled service{CAS) Units (AP-a2, Emissions Emissions Number Basis _ Mfg•.etc.) (pounds/year) (pounds/year) Benzene 71432 t WS�to tb/bbi Site Specific tb).i It Toluene 108883 2„%,y t©t' le/bbl Site Specific t.tut,5 io:1 Ethylbenzene 100414 MAuto-1 Ib/bbt Site Specific Xylem 1330207 1Ad4 io le/bb! Site Specific fb4 n-Hexane 110543 t l4 x tc t tb/bbl Site Specific iclo'1 ,%.t 2,2,4- Trimethyipentane 540641 5:tylvia"4 ib/bbi Site Specific Other: S Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emissions fees wilt be based on actual controlled emissions reported.If source has not yet started operating.leave blank. coLos*Do Form APCD-211 -Gas Venting APEN - Revision 3/201, 5 i A� xo t,t1 t1 co.ti dl. 44 CHIN 10 Permit Number: tciux 'lc(b AIRS ID Number: al, /A b/co,;k [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8-Applicant Certification I hereby certify that alt information contained herein and information submitted with this application is complete, true,and correct. jo/ic'7/i' Signature of(" ..:city zed Person(not a vendor or consultant) Date Michael Cugnetti Director of EHS and Regulatory Name(please print) Title Check the appropriate box to request a copy of the: 8 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 fire 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,B.C.for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment htcps://www.colorado.eov/cdphe/aped c*"),",-*-**Form APCD 211 Gas Venting APEN Revision 31201 w3 1 ;•MM COLORADO 161,14 Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0993 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Rohn 9-60-14A Pad Plant AIRS ID: 123/A09D Physical Location: NWSE SEC 14 T9N R60W County: Weld County Description: Well Production Facility Equipment or activity,subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Eight (8) 400 barrel fixed roof crude oil TK0"1-08 001 ` storage vessels connected via liquid Enclosed Combustor manifold. This permit is `granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 10 ar• M- COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section I I I.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The .operator must retain the permit final authorization letter issued by the Division,;.after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation,of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air;,pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type TK01-08 001 --- --- 9.6 1.8 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Page 2 of 10 M.TM,M COLORADO / Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado TK01-08 001 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Process Parameter Annual Limit ID Crude Oil 01 292,500 barrels TK0108 001 Throughput 02 Combustion of pilot 0.3 MMSCF light gas The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. • The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. 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 Page 3 of 10 COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 14. 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. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator,must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator must complete site specific sampling including a compositional analysis of the pre-flash pressurized `crude oil routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. The pre-flash pressurized crude oil sample must be obtained from the outlet of the heater treaters. Testing must be in accordance with the guidance contained in PS Memo 14-03. Results of the analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/bbl crude oil throughput) using Division approved methods. Results of the analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 10 COLORADO Air Pollution Control Division COP Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX 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 xc per year change emissions For sources emitting 1OO-tons �or more, a in actual emission of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase`by 50% or five (5) tons per year, whichever is less,'' above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- Page 5 of 10 a :„..,. COLORADO Air Pollution Control Division C6PHE Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each=and every condition of this permit is a material part hereof and is not severable. Any c len appeal rejectionpermit to or a eal of a condition hereof must constitute a re ectlon of the entire and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 6 of 10 aN�M,M COLORADO Air Pollution Control Division CDFHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit for eight (8) fixed roof crude oil storage vessels at a new synthetic minor oil and gas well production facility. Page 7 of 10 -N' z COLORADO Air Pollution Control Division CDPHE Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:!https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,047 53 Toluene 108883 896 45 Ethylbenzene 100414 140 7 001 Xylenes 1330207 293 15 n-Hexane 110543 9,034 452 2,2,4- 540841 18 1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Process 01: Crude Oil Throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 1.2x10-2 1.2x10-2 AP 42 Chapter 13.5 Page 8 of 10 v„..,.. COLORADO Y� ! Air Pollution Control Division CDPHE wDepartment of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 1.3014 6.507x10-2 ProMax 71432 Benzene 3.577x10-3 1.788x10-4 ProMax 108883 Toluene 3.062x10-3 1.531x10-4 ProMax 1330207 Xylene 1.0x10-3 5.0x10-5 ProMax 110543 n-Hexane 3.088x1O2 1.544x10-3 ProMax Note: The controlled emissions factors for this point are based on an enclosed combustor control efficiency of 95%.The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with ProMax. The pressurized liquid sample was obtained from the outlet of the three-phase heated separators on 10/04/2019. The sample temperature and pressure are 115°F and 84 psig respectively. The AP-42 Chapter 13.5 CO emission factor (0.31 lb/MMBtu) in the table above was converted to units of lb/bbl using a GOR of 14.02 scf/bbl and heat content of 2763.07 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total crude oil throughput. __- Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/MMSCF lb/MMSCF CO 137.28 137.28 AP 42 Chapter 1.4 Table 14-1 Note: The CO emission factor in the table above was calculated by multiplying the AP-42 Chapter 1.4 Table 1.4-1 CO emission factor(84tb/MMSCF)by a ratio of 1667 Btu/scf to 1020 Btu/scf.Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel combusted by the pilot_ light. Pilot light gas is based on a constant rate of 30 scf/hr. Total actual CO emissions are obtained from the sum emissions resulting from the combustion of storage vessel waste gas which is a function of crude oil throughput(process 01)and the combustion of pilot light gas (process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Page 9 of 10 aAir— . COLORADO Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC MALT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS,, Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories age 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 MALT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXX0'X Page 10 of 10 Ai4N=MM COLORADO 4.4_40r Pollution Control Division ,OFHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0994 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Rohn 9-60-14A Pad Plant AIRS ID: 123/A09D Physical Location: NWSE SEC 14 T9N R60W County Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Two (2) 400 barrel fixed roof produced PW01'-02 002 water storage vessels connected via liquid Enclosed Combustor manifold. This permit it- granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 8 . ,M- COLORADO Y'16- '1 Air Pollution Control Division DP Department Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section'II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type PWO'f-02 002 - - --- 1.5 1.9 Point Note~See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Page 2 of 8 C •M•M- COLORADO Y- Air Pollution Control Division CD HE Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado PW01-02 002 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Produced Water PW01-02 002 225 000 barrels Throughput ' The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 4 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. 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 Page 3 of 8 * r . COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. 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. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 16. U o startup of thispoint, the owner or operator must follow the mo st r p recent operating and maintenance (O8M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit :Revisions to the O8 M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section II III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or Page 4 of 8 M— COLORADO ,O Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Thereq`uirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established.after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D VI.B.4). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be ?reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. Page 5 of 8 ar . COLORADO m'44. Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. ;. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Permit for two (2) 400 barrel produced water storage vessels at a new synthetic minor oil and gas well production facility. Page 6 of 8 N~•M- COLORADO Air Pollution Control Division CDPHE Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the:Division addressing all of the criteria set forth in Part of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The.-following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as:indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,575 79 002 n-Hexane 110543 4,950 248 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 1.67x10-2 1.67x10-2 AP-42 Chapter 13.5 VOC 2.62x10-1 1.31x10-2 CDPHE PS Memo 71432 Benzene 7.0x10-3 3.5x10-4 14-03 110543 n-Hexane 2.2x10-2 1.1x10-3 Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-03 for produced water storage vessels. The CO emission factor in the table above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor (0.31 lb/MMBtu) by Page 7 of 8 a .r COLORADO __+M� Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado a heat value of 1496 Btu/scf and GOR of 36 scf/bbl. Actual emissions are calculated by multiplying the emission factors in the table above by the total produced water throughput. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable ,- Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr:gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A- Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 ar: ;: COLORADO Air Pollution Control Division CURE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0995 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Rohn 9-60-14A Pad Plant AIRS ID: 123/A09D Physical Location: NWSE SEC 14 T9N R60W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description tID Pointy Description Hydrocarbon loadout from storage TL01 003 vessels to trank trucks using , Vapor balance and submerged fill. enclosed combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 10 r� r- COLORADO ` Y Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Tons per Year Emission Point PM2.5 NOX VOC CO Type TL01 003 - --- 0.8 0.1 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants Controlled ID Point Page 2 of 10 hr. COLORADO ' Air Pollution Control Division CDPHE Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado TL01 003 Vapor Balance and Enclosed VOC and HAP Combustor PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit ID Point Hydrocarbon wtTL01 003 Loadout 292,500 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to Page 3 of 10 C -r• 1M- COLORADO ` Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 12. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 13. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or, vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 14. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as !loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 15. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. Page 4 of 10 r%, . COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 16. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 17. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) , OPERATING &t MAINTENANCE REQUIREMENTS 18. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (0&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. (Regulation ,Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 5 of 10 COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5)tons per year, whichever is less,above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation Page 6 of 10 1, - COLORADO Air Pollution Control Division 'OFH£ Department of Public Health @ Environment Dedicated to protecting and improving the health and environment of the people of Colorado of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 26. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 27. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in' the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet.any express term or condition of the permit. of the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaugter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Permit for hydrocarbon liquid loadout at a new Page 7 of 10 •;,M•M- COLORADO W Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado synthetic minor oil and gas well production facility. Page 8 of 10 .M.M COLORADO a ,._. Air Pollution Control Division CDPHE Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point_ Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 53 3 003 n-Hexane 110543 468 24 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl AP-42 CO 6.97x10-4 6.97x10-4 Chapter 13.5 VOC 1.04x10-1 5.20x10-3 CDPHE PS Memo 14- n-Hexane 110543 1.6x10-3 8.0x10-5 02 Page 9 of 10 HM COLORADO Y Air Pollution Control Division CDGHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-02 for crude oil loadout. The CO emission factor in the table above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor(0.31 lb/MMBtu)by a heat value of 2763.07 Btu/scf and GOR of 0.814 scf/bbl. Actual emissions are calculated by multiplying the emission factors in the table above by the total hydrocarbon throughput. 6) in accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable, Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: httri,//www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart X00000( Page 10 of 10 - -,M COLORADO - `Yj Air Pollution Control Division ® Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE0096 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Rohn 9-60-14A Pad Plant AIRS ID: 123/A09D Physical Location: NWSE Section 14 T9N R60W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point' Description Natural gas venting from two (2) three- Enclosed combustor HT-VENT01 004 phase heater treaters during vapor during vapor recovery recovery unit (VRU) downtime. unit (VRU) downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at Page 1 of 10 au :�-�M' COLORADO '141 j Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations.'(Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type X HT-VENT01 004 --- --- 1.9 0.4 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 10 Nsy,. COLORADO �Y-'� Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Pollutants ID Point Control Device Controlled Emissions from the two (2) heater treaters HT-VENT01 004 are routed to an enclosed combustor during VOC and HAP vapor recovery unit (VRU) downtime PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made.available to the Division for inspection.upon request. (Regulation Number 3, Part B, Section II.A.4.) ) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point Hydrocarbon liquid HT-VENT01 004 throughput during VRU 11,700 barrels downtime The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator must continuously monitor and record vapor recovery unit (VRU) downtime. VRU downtime shall be defined as times when natural gas vented from the three- phase heater treaters is routed to the enclosed combustor rather than the VRU. The total hours of VRU downtime, total hydrocarbon liquid throughput and total hydrocarbon liquid throughput during VRU downtime must be recorded on a monthly basis. The owner or operator must use monthly VRU downtime records, monthly hydrocarbon liquid throughput records and calculation methods established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 3 of 10 r,M_ COLORADO Air Pollution Control Division CO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part'D, Section II.B.2.d. 14. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well must either be 'routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 15. On or before June 30th,2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Ft MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 10 isN y_ COLORADO 44_.11 Air Pollution Control Division CDPHE Department of Public Health 4 Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five.percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,:whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • 'Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) must 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 must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Page 5 of 10 r.M�M- COLORADO ~4' Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance,upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only ' for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. Page 6 of 10 .N� 4 - COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issued to Verdad Resources LLC Issuance 1 This Issuance Permit for natural gas venting from two (2) three-phase heater treaters at a new synthetic minor oil and gas well production facility. Page 7 of 10 COLORADO lipm 1' Air Pollution Control Division CDPHE Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission Limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 287 15 Toluene 108883 279 14 Ethylbenzene 100414 49 3 HT-VENT01 004 Xylenes 1330207 113 6 n-Hexane 110543 2,034 102 2,2,4- 540841 5 1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 a .M,,. COLORADO 4,„ Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/bbl) (lb/bbl) CO 5.32x10-2 5.32x102 AP 42 Chapter 13.5 VOC 6.285 3.14x101 ProMax 71432 Benzene 2.45x10-2 1.22x10-3 ProMax 108883 Toluene 2.38x10-2 1.19x10-3 ProMax 110543 n-Hexane 1.74x10-1 8.69x103 ProMax Note: The controlled emissions factors for this point are based on an enclosed combustor control efficiency of 95%.The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with ProMax. The pressurized liquid sample was obtained from the outlet of the three-phase heated separators on 10/04/2019.The sample temperature and pressure are 115°F and 84 psig respectively.The VOC and HAP emission factors were determined using the weight%values, gas-to-oil ratio (GOR) of 69.23 scf/bbl and molecular weight(43.6492 lb/lbmol) associated with the heater treater waste gas from the ProMax simulation in conjunction with the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10- Displacement Equation (10.4-3). The AP-42 Chapter 13.5 CO emission factor(0.31 lb/MMBtu) in the table above was converted to units of tb/bbl using a GOR of 69.23 scf/bbl and heat content of 2,479 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total hydrocarbon liquid throughput during VRU downtime. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources Page 9 of 10 4;•-•M- COLORADO -411 Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package #: 420863 Received Date: 10/17/2019 Review Start Date: 3/26/2020 Section 01 - Facility Information Company Name: Verdad Resources LLC Quadrant Section Township Range County AIRS ID: 123 NWSE 14 9N 60 Plant AIRS ID: A09D Facility Name: Rohn 9-60-14A Pad Physical Address/Location: NWSE quadrant of Section 14, Township 9N, Range 60W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment: Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? No If yes, for what pollutant? Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRs Point # Permit # (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned assigned) Permit Initial 001 Crude Oil Tank TK01-08 Yes 19WE0993 1 Yes Issuance Section 03 - Description of Project Verdad Resources LLC (Verdad) submitted an application to permit several sources at a new synthetic minor oil and gas well production facility located in the ozone attainment area. With this application, the operator has requested permit coverage for crude oil storage vessels, produced water storage vessels, hydrocarbon loadout, separator venting and spark ignition reciprocating internal combustion engines (SI RICE). The SI RICE are requesting coverage under the GP02. This analysis only evaluates the crude oil storage vessels. An APEN is required for this source because uncontrolled requested VOC emissions are greater than 2 tpy (CO AQCC Regulation 3, Part A, Section II .B.3.a.). Further, a permit is required for this source because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 5 tpy (CO AQCC Regulation 3, Part B, Section II.D.3.a.). Public comment is required for this source because new synthetic minor limits are being established with this application. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required ? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 Nix CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ O ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ O ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Is this stationary source a major source? No If yes, indicate programs and which pollutants: SO2 NDx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ O ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Crude Oil Storage Tank(s) Emissions Inventory Section 01 - Administrative Information 123 AO9D 001 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Eight (8) 400 barrel fixed roof crude oil storage vessels connected via liquid manifold. Description: Emission Control Device Enclosed Combustor Description: Requested Overall VOC & HAP Control Efficiency %: 95.0 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = 225000.0 Barrels (bbl) per year Requested Permit Limit Throughput = 292500.0 Barrels (bbl) per year Requested Monthly Throughput = 24842.5 Barrels (bbl) per month Potential to Emit (PTE) Throughput = 292500.0 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2763.07 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 14.0206 scf/bbl Actual heat content of waste gas routed to combustion device = 8,716.5 MMBTU per year Requested heat content of waste gas routed to combustion device = 11331.4 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 11,331.4 MMBTU per year Control Device Pilot Fuel Use Rate: 30 scfh 0.263 MMscf/yr Pilot Fuel Gas Heating Value: 1667 Btu/scf 438.1 MMBTU/yr Section 04 - Emissions Factors & Methodologies ProMax Flow Rate 225,000.00 bbl/year W&B Gas Total Waste Gas Pollutant Flash Gas (lb/hr) Source (lb/hr) Rate (lb/hr) VOC 11.30410744 22.12321549 33.42732293 ProMax Benzene 0.0246452 0.0672197 0.0918649 ProMax Toluene 0.0177183 0.0609406 0.0786589 ProMax Ethylbenzene 0.00231627 0.00992099 0.01223726 ProMax Xylenes 0.00509973 0.02058652 0.02568625 ProMax n-Hexane 0.168642 0.624578 0.79322 ProMax 2,2,4-TMP 0.000319953 0.001207455 0.001527408 ProMax Will this storage tank emit flash emissions? Yes Emission Factors Crude Oil Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Crude Oil (Crude Oil Throughput) Throughput) VOC 1.3014 6.507E-02 Site Specific E.F. (includes flash) Benzene 3.577E-03 1.788E-04 Site Specific E.F. (includes flash) Toluene 3.062E-03 1.531E-04 Site Specific E.F. (includes flash) Ethylbenzene 4.764E-04 2.382E-05 Site Specific E.F. (includes flash) Xylene 1.000E-03 5.000E-05 Site Specific E.F. (includes flash) n-Hexane 3.088E-02 1.544E-03 Site Specific E.F. (includes flash) 224 TMP 5.947E-05 2.973E-06 Site Specific E.F. (includes flash) Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (Waste Heat (Crude Oil Combusted) Throughput) PM10 0.0075 2..887E-04 AP-42 Table 1.4-2 (PM:O/PM.2.5) PM2.5 _ 0.0075 2.887E-04 AP-42 Table 1.4-2 (PMLO/PM.2.5) NOx 0.0680 2.634E-03 AP-42 Chapter 133 Industrial Flares (NOx) CO 0.3100 1.2009E-02 AP-42 Chapter 13.5 industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) PM10 0.0075 12.4208 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 12.4208 AP-42 Table 1.4-2 (PMO/PM.2.5) NOx 0.0980 163.4314 AP-42 Table 1.4-1 (NOx) CO 0.0824 137.2824 AP-42 Table 1.4-1 (CO) Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 190.3352 146.4117 7.3206 130.3352 9.5168 1616.5 PM10 0.0438 0.0341 0.0341 0.0438 0.0438 7.4 PM2.5 0.0438 0.0341 0.0341 0.0438 0.0438 7.4 NOx 0.4067 0.3178 0.3178 0.4067 0.4067 69.1 CO 1.7744 1.3691 1.3691 1.7744 1.7744 301.4 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 1046.157 804.737 40.237 1)46.157 52.308 Toluene 895.768 689.052 34.453 895.768 44.788 Ethylbenzene 139.358 107.198 5.360 139.358 6.968 Xylene 292.515 225.012 11.251 292.515 14.626 n-Hexane 9033.189 6948.607 347.430 9033.189 451.659 224 TMP 17.394 13.380 0.669 _ 17.394 0.870 2 of 4 C:\Users\hslaught\Desktop\123A09D\19WE0993.CP1 Crude Oil Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? No If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? las N/A - the operator developed site-specific EF. If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? 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 1. According to the application, two wells produce to this facility. The well names and API numbers are as follows: (i) Name: Rohn 9-60 #14A-23-1, API Number: 05-123-47781; (ii) Name: Rohn 9-60 #14A-23-3, API Number: 05-123-47780. According to COGCC data, the API gravity of the wells is less than 40. As a result, the operator's classification of the storage vessels as crude oil storage is appropriate. The COGCC data further indicates the wells were fractured in May 2019 and began production in June 2019. Both wells produce from the Niobrara formation. 2. In order to develop site specific emission factors, the operator utilized a site specific pressurized liquid sample in conjunction with ProMax. The pressurized liquid sample was obtained from the outlet of the three-phase heated separator for the Rohn 9-60 14A-23-1 well on 10/04/2019. The sample temperature and pressure are 115°F and 84 psig respectively. The pressurized liquid sample is used as an input for the ProMax simulation used to estimate emissions and emission factors for this source. 3. While the sample used in the application to develop the site specific emission factors was obtained from the facility being permitted, it was taken upstream of the heater treaters, which are directly upstream of the storage vessels. According to Section 5.8 of PS Memo 14-03 the samples of low pressure oil required for site specific emission factor development are defined as follows: "Samples of low pressure oil, which is the pre-flash pressurized oil obtained from the separator outlet to the sales tank, must be taken during normal operating conditions." This definition clearly indicates the sample must be obtained from the separator directly upstream of the storage vessels. In this case, the sample would need to be obtained from the outlet of the heater treaters. Due to this, the permit will require the operator to obtain an initial low pressure liquid sample from the outlet of the heater treaters and develop site specific emission factors. These newly developed factors will be used to demonstrate the emission factors developed through this analysis are either accurate or conservative. 4. The produced water storage vessels, hydrocarbon loadout, separator venting and crude oil storage vessels are controlled by the same enclosed combustor at this facility. Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device. In this case, the highest emitting source is the crude oil storage vessels. As a result, the pilot light combustion emissions are included in this analysis. 5. Engineering guidance indicates that NOx and CO emissions from each source controlled by a common control device need to be added together to evaluate APEN applicability. Total CO emissions from all sources at this facility that are controlled by the enclosed combustor (produced water storage vessels, crude oil storage vessels, separator venting and hydrocarbon loadout) are greater than APEN thresholds. Total NOx emissions from all sources at this facility that are controlled by the enclosed combustor (produced water storage vessels, crude oil storage vessels, separator venting and hydrocarbon loadout) are less than APEN thresholds. As a result, this permit will only contain a limit and emission factors for CO. 6. On February 14, 2020, Regulation 7, Part D, Section I was updated to include requirements for crude oil storage vessels in the non-attainment area. Since this facility is located in the ozone attainment area, the requirements of Regulation 7, Part D, Section I do not apply to this source. This regulatory analysis is contained here because the standard regulatory analysis included in this workbook has not been updated to include this evaluation. 7. Periodic visible emissions checks for the control device are addressed by the O&M plan. As a result, the permit does not contain periodic opacity testing. 8. Ethylbenzene and 2,2,4-TMP emissions are below APEN reporting thresholds. As a result, the permit will not contain emission factors for these pollutants. 9. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator expressed they had no comments on the APEN and provided one comment on the draft permit. The comment and Division response are as follows: Comment: Crude Oil Storage Tanks (Pt 001, 19WE0993) Condition 17 — Initial Testing Requirements — Is this a new requirement for multi-stage separation? The emissions factors were developed using a site-specific analysis. Other permits we've received for applications submitted around the same time period, with the same calculation methodologies, did not include additional pressurized sampling at other locations along the process stream and only had requirements for Method 22 observations from the control systems. Are other operators being required to complete additional sampling? Can you please clarify. Division Response: While this requirement is new, it is based on engineering guidance that has been in place for some time, but wasn't necessarily being implemented correctly. According to Section 5.8 of PS Memo 14-03 the samples of low pressure oil required for site specific emission factor development are defined as follows: "Samples of low pressure oil, which is the pre-flash pressurized oil obtained from the separator outlet to the sales tank, must be taken during normal operating conditions." Based on this language it is our understanding that the pressurized liquid sample used for emission factor development should be obtained from the outlet of the separator that directly sends fluid to the storage vessels. This language mirrors the language in PS Memo 05-01 which was written in a time when multistage separation was less prevalent. As a result, we have determined that samples may be taken further upstream at facilities with multistage separation for initial emission factor development; however, initial testing will be included in these permits to verify the original emission factors are either conservative or accurate. I apologize that this determination has not been applied consistently to your recent permits. It is, however, a requirement that will be included in permits going forward for all operators that develop emission factors in this manner. Please let me know if you have any additional questions about this. The operator reviewed the response and expressed they had no further comments. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 01 4-04.003-12 Fixed Roof Tank, Crude Oil, workin +breat losses PM10 7.14E-03 a lb/1,000 gallons crude oil throughput PM2.5 7.14E-03 0 lb/1,000 gallons crude oil throughput NOx 6.62E-02 0 lb/1,000 gallons crude oil throughput VOC 31.0 95 lb/1,000 gallons crude oil throughput CO 2.89E-01 0 lb/1,000 gallons crude oil throughput Benzene 8.52E-02 95 lb/1,000 gallons crude oil throughput Toluene 7.29E-02 95 lb/1,000 gallons crude oil throughput Ethylbenzene 1.13E-02 95 lb/1,000 gallons crude oil throughput Xylene 2.38E-02 95 lb/1,000 gallons crude oil throughput n-Hexane 7.35E-01 95 lb/1,000 gallons crude oil throughput 224 TMP 1.42E-03 95 lb/1,000 gallons crude oil throughput 3 0f 4 C:\Users\hslaught\Desktop\123A09D\19WE0993.CP1 • • Crude OHS...age Tank Regulatory Analysis Wetksbeet The regulatory vui.nentsbelow ore determined basetlon requertetl emusan, • AITUNMEerr ftykOR Source isthe H h eraeaoaviml w aanawvanaremereppX u uM vomm=nmwenlun ?u=, yaanemanztp o.e nso.pvoreoem aaaae.rearerm...o.rvl eN�nawnesem==ne> 4 5.3..reerle,Irmapereln �sa w.�ane=art • lae a wand l• • • I Am lse radar u uniNr �va.l wnaxmmatnv..umra knaxue .s. sslanaemal I axavun nxla mxana.amamnunop.mn=n.we 1pmaunwa n=xv.nenaiea.amnweeamemmn..na.ai.a:pmaumapN.n , a n=m.wtr Nuanmewalen sum t. .uov mmpe.vea.vo� • Gee""5M, memo part3 of Reguieuen,secm m..ee Co m me nexauenion - . mjwM.Ca SC3 DoesIne crude el rtange tal.contain if no on, »'n pin am appry. 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I COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILTY EMISSION SUMMARY Company Name Verdad Resources LLC County AIRS ID 123 History File Edit Date 4/1412020 Plant AIRS ID AND Ozone Status Attainment Facility Name Rohn 960 14A Pad EMISSIONS Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM25 H2S SO2 NOx VOC Fug CO Total PM10 PM2 5 1125 SO2 NOx VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 New Facility No Previous Total Prevaus Penndted Facility total 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 New Facility No Previous Total I - � 001 19WE0993 Eight(8)400bblrued roof crude on 00 00 04 1903 18 57 00 00 04 96 18 03 New Source SSEF developed and approved storage vessels 002 19WE0994 Two(2)400 barrel fixed roof produced 01 01 04 295 19 33 01 01 04 15 19 02 New Source state EF used Water storage vessels 003 19WE0995 Hydrocarbon loadout 00 00 00 152 01 03 00 00 00 08 01 00 NewSource state EF used 004 19WE0990 Natural gas venting from Iwo(2) 00 00 01 368 04 14 00 00 01 19 04 01 NewSource compliance based on liquid heater treaters throughput 00a GP02 Si RICE GM Vott c 5 7L 4SRB 92 01 01 124 07 98 01 01 01 09 07 18 01 NewSource engine used for compression HP,SN 13219341 006 GP02 SI RICE Caterpillar G3306TA,4SRB 02 02 325 14 325 06 02 02 20 14 40 06 NewSeuree engine used for compression 203 HP,SN 06X00072 XA Two(2)05 MMBtuihr Separator 00 00 05 00 05 00 00 00 05 00 05 00 Insignificant Source Heaters XA Two(2)05 MMBtu/hr Heater Treater 00 00 05 00 05 00 00 00 05 00 05 00 insgnficanl Source Heaters XA Fugitives 02 00 02 00 Insignificant Source 00 00 00 00 00 00 FACILITY TOTAL 04 04 00 00 469 2739 02 474 113 04 04 00 00 49 160 02 109 12 VOC Syn Minor(PSD and OP) NOx True Minor(PSO and OP) CO True Minor(PSD and OP) NAPS True Minor Hit Area source no affected sources 7272 Area source Pemulled Fecilrty Total 1 03 03 00 00 458 2739 00 465 113 03 03 00 00 38 159 00 100 12 Excludes was exempt loom pemuts/APENs (A)Change in Permitted Emissions 03 03 00 00 38 159 00 100 Modeling not required based on A change in emissions Pubeom is required bin new syn minor limits are being established with this application Total VOC Facility Emissions(point and fugitive) 161 Facilityis eligible for GP02 because<95 tpy (A)Change in Total Permitted VOC emissions(point and fugrtrve) 159 Protect emissions less than 50 tpy Note 1 Note 2 - Page 1 of 2 i Printed 4/21/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A09D Facility Name Rohn 9-60-14A Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TAW H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0993 Eight (8) 400 bbl fixed roof crude oil 1047 896 1»:: 293 9034 1 5.7 storage vessels 002 19WE0994 Two (2) 400 barrel fixed roof produced 1575 4950 3.3 water storage vessels 003 19WE0995 Hydrocarbon loadout 468 0.3 004 19WE0996 Natural gas venting from two (2) heater 287 279 49 113 2034 5 1 .4 treaters 005 GP02 SI RICE GM Vortec 5.7L, 4SRB, 92 HP, 0.2 1.4 0.1 SN: 13219341 006 GP02 SI RICE Caterpillar G3306TA, 4SRB, 980 : ' ' - .. 0.4 3.1 0.6 203 HP, SN: G6X00972 XA Two (2) 0.5 MMBtu/hr Separator Heaters 0.0 XA Two (2) 0.5 MMBtu/hr Heater Treater 0.0 Heaters XA Fugitives . - 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.6 0.0 0.0 1.5 0.6 0.1 0.2 8.2 0.0 0.0 0.0 0.0 11.3 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text uncontrolled enuss,ons < de in n'nws Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0993 Eight (8) 400 bbl fixed roof crude oil 53 45 15 452 0.3 storage vessels 002 19WE0994 Two (2) 400 barrel fixed roof produced 79 248 0.2 water storage vessels 003 19WE0995 Hydrocarbon loadout 24 0.0 004 19WE0996 Natural gas venting from two (2) heater 15 14 6 102 0.1 treaters 005 GP02 SI RICE GM Vortec 5.7L, 4SRB, 92 HP, 11.5 -• ' _ 1.4 0.1 SN: 13219341 006 GP02 SI RICE Caterpillar G3306TA, 4SRB, 980 - 25.: _ 3.1 0.6 203 HP, SN: G6X00972 XA Two (2) 0.5 MMBtu/hr Separator Heaters 0.0 XA Two (2) 0.5 MMBtu/hr Heater Treater 0.0 Heaters XA Fugitives 0.3 7 . 0.0 0.0 0.0 0.0 TOTALI(tpy) 0.6 0.0 0.0 0.1 0.0 0.0 0.0 0.4 0.0 0.0 0.0 0.0 1.2 2_ I23A09D 4,21/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package #: 420863 Received Date: 10/17/2019 Review Start Date: 3/25/2020 Section 01 - Facility Information Company Name: Verdad Resources LLC Quadrant Section Township Range County AIRS ID: 123 NWSE 14 9N 60 Plant AIRS ID: A09D Facility Name: Rohn 9-60-14A Pad Physical Address/Location: NWSE quadrant of Section 14, Township 9N, Range 60W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segmentOil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? No If yes, for what pollutant? Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRs Point # Permit It (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 002 Produced Water Tank PW01-02 Yes 19WE0994 1 Yes Issuance Section 03 - Description of Project Verdad Resources LLC (Verdad) submitted an application to permit several sources at a new synthetic minor oil and gas well production facility located in the ozone attainment area. With this application, the operator has requested permit coverage for crude oil storage vessels, produced water storage vessels, hydrocarbon loadout, separator venting and spark ignition reciprocating internal combustion engines (SI RICE). The SI RICE are requesting coverage under the GP02. This analysis only evaluates the produced water storage vessels. An APEN is required for this source because uncontrolled requested VOC emissions are greater than 2 tpy (CO AQCC Regulation 3, Part A, Section II.B.3.a.). Further, a permit is required for this source because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 5 tpy (CO AQCC Regulation 3, Part B, Section II .D.3.a.). Public comment is required for this source because new synthetic minor limits are being established with this application. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No if yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ O ❑ ❑ Title V Operating Permits (OP) ❑ LI ❑ D ❑ LI ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Is this stationary source a major source? No If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory Section 01 - Administrative Information 123 A09D 002 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Two (2) 400 barrel fixed roof produced water storage vessels connected via liquid manifold. Description: Emission Control Device Enclosed Combustor Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 150,000 Barrels (bbl) per year Requested Permit Limit Throughput = 225,000 Barrels (bbl) per year Requested Monthly Throughput = 19110 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput 225,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 1496.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 36.0 scf/bbl Actual heat content of waste gas routed to combustion device = 8078.4 MMBTU per year Requested heat content of waste gas routed to combustion device = 12117.6 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 12117.6 MMBTU per year Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (Ib/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) Produced Water State E.F. (includes flash) - Front VOC 0.2620 1.310c-0i'. Range & Other Produced Water State E.F. (includes flash) - Front Benzene 0.0070 3.500E-0. Range & Other Toluene 0.0000 Ethylbenzene 0.0000 Xylene 0.0000 Produced Water State E.F. (includes flash) - Front n-Hexane 0.0220 1.100E-03 Range & Other 224 TMP 0.0000 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 0.00745 0.00040 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.00745 0.00040 AP-42 Table 1.4-2 (PM10/PM.2.5) NOx 0.06800 0.00366 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.31000 0.01570 AP-42. chapter 13.5 Industrial Flares (CO). Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 PM2.5 0.0000 NOx 0.0000 CO 0.0000 Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 29.475 19.650 0.983 29.475 1 .474 250.3 PM10 0.045 0.030 0.030 0.045 0.045 7.7 PM2.5 0.045 0.030 0.030 0.045 0.045 7.7 NOx 0.412 0.2747 0.2747 0.412 0.412 70.0 CO 1.878 1.252 1.252 1.878 1.878 319.0 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled abs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 1575.000 1050.000 52.500 1575.000 78.750 Toluene 0.000 0.000 0.000 0.000 0.000 Ethylbenzene 0.000 0.000 0.000 0.000 0.000 Xylene 0.000 0.000 0.000 0.000 0.000 n-Hexane 4950.000 3300.000 165.000 4950.000 247.500 224 TMP 0.000 0.000 0.000 0.000 0.000 2 of 4 K:\PA\2019\19WE0994.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO. NSPS Subpart OOOOa Storage Tank is not subject to NSPS OOOOa (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Ae � 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 modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. t N/A - the operator used the state default EF to calculate emissions. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 1. According to the application, two wells produce to this facility. The well names and API numbers are as follows: (i) Name: Rohn 9-60 #14A-23-1, API Number: 05-123-47781; (ii) Name: Rohn 9-60 #14A-23-3, API Number: 05-123-47780. According to COGCC data the wells were fractured in May 2019 and began production in June 2019. Both wells produce from the Niobrara formation. 2. The produced water storage vessels, hydrocarbon loadout, separator venting and crude oil storage vessels are controlled by the same enclosed combustor at this facility. As a result, the pilot light emissions are not calculated in this workbook because the are evaluated with the crude oil storage vessels (19WE0993). Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device. In this case, the highest emitting source is the crude oil storage vessels. 3. Even though CO emissions from this source specifically are below APEN reporting thresholds, the total CO emissions from all sources controlled by the enclosed combustor (produced water storage vessels, crude oil storage vessels, separator venting and hydrocarbon loadout) are greater than APEN thresholds. As a result, the permit for each source controlled by the common control device will include limits on CO emissions. It should be noted that combined NOx emissions from all sources controlled by the enclosed combustor are below APE N reporting thresholds. 4. Periodic visible emissions checks for the control device are addressed by the O&M plan. As a result, the permit does not contain periodic opacity testing. 5. On February 14, 2020, Regulation 7, Part D, Section I was updated to include requirements for produced water storage vessels in the non-attainment area. Since this facility is located in the ozone attainment area, the requirements of Regulation 7, Part D, Section I do not apply to this source. This regulatory analysis is contained here because the standard regulatory analysis included in this workbook has not been updated to include this evaluation. 6. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments. Section 09 - Inventory 5CC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control '% Units 002 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses PM10 0.0096 0.0 lb/1,000 gallons liquid throughput PM2.5 0.0096 0.0 lb/1,000 gallons liquid throughput NOx 0.0872 0.0 lb/1,000 gallons liquid throughput VOC 6.2381 95.0 lb/1,000 gallons liquid throughput CO 0.3975 0.0 lb/1,000 gallons liquid throughput Benzene 0.1667 95.0 lb/1,000 gallons liquid throughput Toluene 0.0000 95.0 Ib/1,000 gallons liquid throughput Ethylbenzene 0.0000 95.0 lb/1,000 gallons liquid throughput Xylene 0.0000 95.0 lb/1,000 gallons liquid throughput n-Hexane 0.5233 95.0 Ib/1,000 gallons liquid throughput 224 TMP 0.0000 95.0 lb/1,000 gallons liquid throughput 3 of 4 K:\PA\2019\19WE0994.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet The regulatory requirements below ore determined bosed on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)? Yes Source Requires an APEN. Go to the next question 2. Is the operator claiming less than 1%crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3,Part B,Section II.D.1.M) No Go to next question 3. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B.Section II.D.3)? Yes Source Requires a permit Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A,Section Il.D.1.a)? 2 Is the operator claiming less than 1%crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.O.1.M) 3. Arc total facility uncontrolled VOC emissions greater than 2 TPY,NOx greater than 5 TRY or CO emissions greater than 10 TPY (Regulation 3,Part B.Section II.D.2)? You have :eel:ated that source;s in the Attainment Area Colorado Regulation 7.Section XVII 1. Is this tank located at a transmission/storage facility? Nc Continue - You have indicated the source category on the Project Summary sheet. 2. Is this produced water storage tank' located at an oil and gas exploration and production operation ,well production facility', natural gas compressor station'or natural gas processing plant? Y Continue-You have indicated the facility type on the Project Summary sheet. 3. Is this produced water storage tank a fixed roof storage tank? Yes Go to the next question 4. Are uncontrolled actual emissionsr of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to parts of Regulation 7, Sections XVILB&C. Go to the next question Storage tans !Osten to Ref;u'ation 7. Section xViI, S. C.1 & C.) Section XVILB—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C-3- Recordkeeping Requirements 5. Does the produced water storage tank contain only"stabilized"liquids? If no.the following additional provisions apply. No -- Source is subject to all provisions of Regulation 7,Section XVII,Subsections B& C [Storage tank is •uby,ct to Regulation 7, Section 2 Section XVII.C-2 -Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR,Part 60,Subpart Kb Standards of Performance for VolatlltQgank Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or 'g pd y equal to 75 cubic meters (m ) (`4J2 BBLs]. No Storage Tank is not subject NSPS Kb •The storage vessel capacity is below the applicable threshold. 2. Does the storage vessel meet the following exemption in 60.lilb(d)(4)? NA a. Does the vessel has a design capacity less than or equal to 1,589.874 m'('10,000 BBL] used for petroleum' or condensate stored, processed,or treated prior to custody transfer'as defined in 60.1116? 3. Was this condensate storage tank constructed,reconstructed,or modified (see definitions 40 CFR,60.2) after July 23, 1984? NA 4. Does the tank meet the definition of "storage vessel-3 in 60.11lb? NA 5. Does the storage vessel store a 'volatile organic liquid(VOL)"as defined in 60.111b? NA 6. Does the storage vessel meet any one of the following additional exemptions: NA a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (`29.7 psi] and without emissions to the atmosphere (60.I10b(d)(2))?;or NA b. The design capacity is greater than or equal to 151 m3("950 BBLI and stores a liquid with a maximum true vapor pressures less than 3.5 kPa(60.110b(b))?:or NA c. The design capacity is greater than or equal to 75 M' ('-472 BBL] but less than 151 m'("950 BBL) and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b))? NA 7. Does the storage tank meet either one of the following exemptions from control requirements: NA a. The design capacity is greater than or equal to 151 m'(^'950 881) and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?;or NA b. The design capacity is greater than or equal to 75 M (-472 BBL) but less than 151 m' ('950 BBL) and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? NA 'Storage Tani Is not subject te NSPS Ra 40 CFR, Part 60,Subpart OOOO/0000a,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Continue You have indicated the source category on the Project Summary sheet. 2. Was this produced water storage vessel constructed,reconstructed,or modified (see definitions 40 CFR,60.2) between August 23,2011 and September 18, 2015? No Storage Tank is not subject NSPS OOOO-Go to the next question to continue determination of NSPS 0000a applicability. 3. Was this produced water storage vessel constructed, reconstructed,or modified (see definitions 40 CFR,60.2) after September 18, 201.5? Yes Go to the next question 4. Are potential VOC emissions: from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not subject NSPS 0000a. S. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430/60.5430a? NA 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? NA 'Storage. Tank is not subject !o NSPS 0000a (Note: If a storage vessel is previously determined to be subject to NSPS OOOO/0000a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS OOOO/0000a RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act. its nnplemenbng regulations. and Air Quaky 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 Ths document does not change or substitute for any law, regulatbn, 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 regulaton wit control. The use of non-mandatory language such as 'recommend,""may,"should."and 'can.'is intended to describe APCD interpretations and recommendations Mandatory terminolgy 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 bgaly binding requirements in and of itself Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package #: 420863 Received Date: 10/17/2019 Review Start Date: 3/25/2020 Section 01 - Facility Information Company Name: Verdad Resources LLC Quadrant Section Township Range County AIRS ID: 123 _ NWSE 14 9N 60 Plant AIRS ID: A09D Facility Name: Rohn 9-60-14A Pad Physical Address/Location: NWSE quadrant of Section 14, Township 9N, Range 60W County: Weld County Type of Facility: Exploration & Production Weil Pad What industry segmentiOil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? No If yes, for what pollutant? Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRs Point # Permit # (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 003 Liquid Loading TL01 Yes 19WE0995 1 Yes Issuance Section 03 - Description of Project Verdad Resources LLC (Verdad) submitted an application to permit several sources at a new synthetic minor oil and gas well production facility located in the ozone attainment area. With this application, the operator has requested permit coverage for crude oil storage vessels, produced water storage vessels, hydrocarbon loadout, separator venting and spark ignition reciprocating internal combustion engines (SI RICE). The SI RICE are requesting coverage under the GP02. This analysis only evaluates the hydrocarbon loadout source. An APEN is required for this source because uncontrolled requested VOC emissions are greater than 2 tpy (CO AQCC Regulation 3, Part A, Section ll .B.3.a.). Further, a permit is required for this source because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 5 tpy (CO AQCC Regulation 3, Part B, Section II.D.3.a.). Public comment is required for this source because new synthetic minor limits are being established with this application. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ E ❑ ❑ Title V Operating Permits (OP) ❑ ❑ O ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Is this stationary source a major source? No If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) LI LI ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Hydrocarbon Loadout Emissions inventory Section 01 - Administrative Information 123 A09D 003 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Hydrocarbon liquid loadout from storage vessels to tank trucks using submerged fill. Description: Emission Control Device Emissions from this source are captured and routed to the enclosed combustor using vapor balance. Description: Is this loadout controlled? Yes Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 225,000 Barrels (bbl) per year Requested Permit Limit Throughput = 292,500 Barrels (bbl) per year Requested Monthly Throughput = 24S42 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 292,500 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2763.07 Btu/scf Actual Volume of waste gas emitted per year = 183119 scf/year 0.813862959 Requested Volume of waste gas emitted per year = 238055 scf/year Actual heat content of waste gas routed to combustion device = 506 MMBTU per year Requested heat content of waste gas routed to combustion device = 658 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 653 MMBTU per year Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? The state default emissions factors may be used to estimate emissions. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (Ib/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 1.04E-01 5.20E-0} Crude Oil Loadout State E.F. Benzene 1.80E-04 9.00E-06 Crude Oil loadout State E.F. Toluene 0.00E+00 0.00E+00 Ethylbenzene 0.00E+00 0.00E+00 Xyl e n e 0.00E+00 0.00E+00 n-Hexane 1.60E-03 8.00E-05 Crude Oil Loadout State E.F. 224 TMP 0.00E+00 _ 0.00E+00 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.0075 1.68E-05 AP-41 table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 1.68E-05 AP-42 Table 1.4-2 (PM10/PM.2.5) SOx 0.0006 1.32E-06 AP-42 Table 1.4-2 (SOx) NOx 0.0680 1.53E-04 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 6.9712E-04 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM10 0.0000 PM2.5 0.0000 h < ,� MEWS�.- ,o se3�r,Ma A.e.2}° 5 v S,�� 5, u lr $d`.� .,v l� A.wf .V .�i ) Sa61 FF Y .k, fc3sr.s 4 a r ux x >. .v.. . Pti"o-a,TYN3xr wti. SOX 0 /� .000 00 $ k5f i� 4 4 >�Sb wiry film FT 4 > ≥Y 5 ;..< .x< e%'a :J y, a.,` Y��g .v v4'zr3,e 3' .✓ �_y.;:.. NOx 0.0000 CO 0.0000 2 of 4 C:\Users\hslaught\Desktop\123A09D\19WE0995.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.002 0.002 0.002 0.002 0.002 0 PM2.5 0.002 0.002 0.002 0.002 0.002 0 SOx 0.000 0.000 0.000 0.000 0.000 0 NOx 0.022 0.017 0.017 0.022 0.022 4 VOC 15.210 11.700 0.585 15.210 0.761 129 CO 0.102 0,078 0.078 0.102 0.102 17 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 52.65 40.50 2.03 52.65 2.63 Toluene 0.00 0.00 0.00 0.00 0.00 Ethylbenzene 0.00 0.00 0.00 0.00 0.00 Xylene 0.00 0.00 0.00 0.00 0.00 n-Hexane 468.00 360.00 18.00 468.00 23.40 224 TMP 0.00 0.00 0.00 0.00 0.00 - Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7 Part D Section II.C.5. The hydrocarbon liquids loadout source is subject to Regulation 7 Part 0 Section I€.C.5. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? . If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08 - Technical Analysis Notes -- -- .__ -. _ .._ _ _____ ___ ______..._:... All , 1. According to the application, two wellsproduce to this facility. The well names and API numbers are as follows: i Name: Rohn 9-60 #14A-23-1, API Number: 05-123-47781; (ii) Name: Rohn 9-60 #14A-23-3, API Number: 05-123-47780. According to :"' ' N pp ( ) COGCC data, the API gravity of the wells is less than 40. As a result, the operator's classification of the storage vessels as crude oil storage is appropriate. The COGCC data further indicates the wells were fractured in May 2019 and began production in June 2019. Both wells produce from the Niobrara formation. _ .<..n,:.....t ..."'''''''"":',:c.7-'''' .c—r.n. ‘"7.":'!.-'"''''':-_. . .. .. -... _. .... :_:^..:?' .. r.>. is ... . .:.r :. z. z .c y :x <v... t tl : : .1_ t uf.4' :: . x L ='L4i::�:'L':::T N ICU ...AY �i n.,. ::% , Y .t • <n.........t n.. ...f*: ;n..._..n.. 1..........n. ......%..n.. .1._ ........ : 2. Benzene emissions are below APEN reporting thresholds (i.e. < 250 lb/year). As a result,an emission factor will not be included in the permit for this pollutant .r,. al :_ '' -� <-y-� ' :N ';'T!' :;:!::: ::-_; ra r '"� . ...- '.� I , l" X S F ..L- X .f K 1. IC I .. .. ._.... qn_ ..:: .«. :: :: ...... _ - _- _ _. _ .- _..-. ... ._ L._ :: <I Kll .l.i I ,v..Al>.. tin J%...; .. . iir)% ;Itl }).. i. 1'. .t....�..;....t...n ElLr:.7t::.t } ' n.. V.Si .IS..Y. . - ..-..J..........F......<.....%....... 3........Y. . .Y._. ... .-..- . ._.�... -..n .%.. %.._ ,( X :.. ... . :n.:. ....... ::: . .:::::'4. .. 5:_:'4 '.).C. .. : .. 4::x.;R�.:: •. [: : ._ a . . r:%.a^. "_.y. w..2Y••.^Y_'t'? ..y.T.._ )i:i1__v'3.'::4::'-'^)E:: ^Y.....N._... c^^..y 3. The produced water storage vessels, hydrocarbon loadout, separator venting and crude oil storage vessels are controlled by the same enclosed combustor at this facility. As a result, the pilot light emissions are not calculated in this workbook because the are evaluated with the crude oil storage vessels (19WE0993). Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device. In this case, the highest sa,: emitting source is the crude oil storage vessels. 4. Even though CO emissions from this source specifically are below APEN reporting thresholds, the total CO emissions from all sources controlled by the enclosed combustor (produced water storage vessels, crude oil storage vessels, separator venting and hydrocarbon loadout) are greater than APEN thresholds. As a result, the permit for each source controlled by the common control device will include limits on CO emissions. It should be noted that combined NOx emissions from all sources controlled by the r P r n re holds.enclosed cambusto are below A EN epofi gth s .. .. , ::... .. .. ::.%. ... .-:--- _ . -:: :: ,_. . . ., n _ ::....x..n.,..�°: 5. The heat input rate of loadout waste gas routed to the ECD was calculated using the following equation: MMBtu/year = [Uncontrolled VOC (ton/year)]*f 2000 lb/ton]/[Molecular Weight (Ib/Ib-mol)]*[379 scf/lb-molj;[Heat Content (Btu/scf)]\[1,000,000 -,:iird Btu/MMBtu). The molecular weight and heat content used in this equation were obtained from the total emission stream as estimated by the ProMax simulation used to estimate crude oil storage vessel emissions at this faci€ity. The specific values for ''` molecular weight and heat content are 48.43075796 lb/lb-mol and 2,763.07 Btu/scf respectively. When the state emission factors are used to estimate emissions, a molecular weight of 50 lb/lb-mot and heat content of 3,535 Btu/scf are typically used in this equation to estimate the heat input rate. in this instance, the values used by the operator result in slightly less conservative emissions but are acceptable because they are based on site specific data. _., ': a1. >.� - _,a ,.4.: :, :::i 6. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 003 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 3.99E-04 0 lb/1,000 gallons transferred PM2.5 3.39E-04 0 Ib/1,000 gallons transferred S0x 3.15E-05 0 lb/1,000 gallons transferred NOx 3.64E-03 0 lb/1,000 gallons transferred VOC 2.476 95 lb/1,000 gallons transferred CO 1.66E-02 0 lb/1,000 gallons transferred Benzene 4.29E-03 95 lb/1,000 gallons transferred Toluene 0.00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n-Hexane 3.81E-02 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 3 of 4 C:\Users\hslaught\Desktop\123A090\19WE0995.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Go to next question. 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? Yes Go to the next question 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No Go to next question 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next question 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next question 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes The loadout requires a permit Source requires a permit 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 II.D.1.I)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? S. 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 S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? You have indicated that source is in the Attainment Area Colorado Regulation 7 Part D Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, natural gas compressor station or natural gas processing plant? Yes Go to next question. 2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? YQc Source is subject to Regulation 7 Part D Section II.C.5. The hydrocarbon liquids loadout source is subject to Regulation 7 Part D Section II.C.5. Section II.C.5.a.(i) - Compliance Schedule Section II.C.5.a.(ii) - Operation without Venting Section II.C.5.a.(iii) - Loadout Equipment Operation and Maintenance Section II.C.5.a.(iv) - Loadout observations and Operator Training Section II.C.5.a.(v) - Records Section II.C.S.a.(vi) - Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend," "may." "should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package #: 420863 Received Date: 10/17/2019 Review Start Date: 3/30/2020 Section 01 - Facility Information Company Name: Verdad Resources LLC Quadrant Section Township Range County AIRS ID: 123 NWSE 14 9N 60 Plant AIRS ID: A09D Facility Name: Rohn 9-60-14A Pad Physical Address/Location: NWSE quadrant of Section 14, Township 9N, Range 60W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment! Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? No If yes, for what pollutant? Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRs Point # Permit # (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned assigned) Permit Initial 004 Separator Venting HT-VENT01 Yes 19WE0996 1 Yes Issuance Section 03 - Description of Project Verdad Resources LLC (Verdad) submitted an application to permit several sources at a new synthetic minor oil and gas well production facility located in the ozone attainment area. With this application, the operator has requested permit coverage for crude oil storage vessels, produced water storage vessels, hydrocarbon loadout, separator venting and spark ignition reciprocating internal combustion engines (SI RICE). The SI RICE are requesting coverage under the GP02. This analysis only evaluates the separator venting source. An APEN is required for this source because uncontrolled requested VOC emissions are greater than 2 tpy (CO AQCC Regulation 3 , Part A, Section II .B.3.a.). Further, a permit is required for this source because uncontrolled requested VOC emissions from all APEN required sources at this facility are greater than 5 tpy (CO AQCC Regulation 3, Part B, Section II.D.3.a.). Public comment is required for this source because new synthetic minor limits are being established with this application. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ O ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ O ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) ❑ ❑ Is this stationary source a major source? No If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review (NANSR) O ❑ Separator Venting Emissions Inventory Section 01 - Administrative Information 123 A09D 004 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Natural gas venting from two (2) three-phase heater treaters during vapor recovery unit (VRU) downtime. Detailed Emissions Unit Description: Enclosed Combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: 95 Limited Process Parameter Liquid Throughput Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 9000.0 Barrels (bal) per year Requested Permit Limit Throughput = 11,700.0 Barrels (bbl) per year Requested Monthly Throughput = 993.7 Barrels (bbl) per month Potential to Emit (PTE) Throughput = 11700.0 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 2479.0 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: 69.225089 scf/bbl Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04 - Emissions Factors & Methodologies Description The two wells at this facility produce to two (2) inlet three-phase separators. Hydrocarbon liquid from the three-phase separators is routed to two (2) three-phase heater treaters for further separation. The gas from the three-phase separators is always routed to a sales pipeline or used for gas lift. During normal operation gas from the three-phase heater treaters is captured using a vapor recovery unit and routed to the sales pipeline. During VRU downtime, gas from the three-phase heater treaters is routed to the enclosed combustor to be controlled. A site-specific pressurized three-phase separator liquid sample was obtained from separator for the Rohn 9-60 14A-23-1 well on 10/04/2019. The temperature and pressure of the sample are 115°F and 84 psig respectively. This liquid sample was used in conjunction with ProMax in order to determine the volume and composition of waste gas vented from the three-phase heater treaters. The weight % values and gas molecular weight from the ProMax simulation along with the displacement equation (shown below) were used to estimate emissions from this source. MW 43.6492 Ib/Ib-mol Displacement Equation Ex = Q ' MW * Xx / C Weight % Helium 0.00000000 CO2 2.02119000 N2 0.12373200 methane 6.86174000 ethane 12.07490000 propane 31.82520000 isobutane 5.58153000 n-butane 16.17080000 isopentane 5.31622000 n-pentane 7.08200000 cyclopentane 0.70972400 n-Hexane 2.18300000 cyclohexane 0.65907800 Other hexanes 4.46873000 heptanes 2.15596000 methylcyclohexane 0.67581700 224-TMP 0.005010830 Benzene 0.30706600 Toluene 0.29922800 Ethylbenzene 0.05243230 Xylenes 0.12105900 Octane 0.99370800 Nonane 0.31175600 C10+ 9.901990E-05 Total 100.0000 VOC Wt % 78.91841315 2 of 5 C:\Users\hslaught\Desktop\123A09D\19WE0996.CP1 Separator Venting Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source Pollutant (Liquid Throughput) (Liquid Throughput) VOC 6.2851 3.14E-01 ProMax Benzene 2.44547E-02 1.22E-03 ProMax Toluene 2.383E-02 1.19E-03 ProMax Ethylbenzene 4.1757E-03 2.09E-04 ProMax Xylene 9.6411E-03 4.82E-04 ProMax n-Hexane 1.7385E-01 8.69E-03 ProMax 224 TMP 3.9906E-04 2.00E-05 ProMax Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 1.2786E-03 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 1.2786E-03 AP-42 Table 1.4-2 (PM10/PM.2.5) SOx 0.0006 _ 1.0095E-04 AP-42 Table 1.4-2 (SOx) NOx 0.0680 1.1669E-02 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 5.3198E-02 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 PM2.5 0.0000 S O x 0.0000 __ NOx 0.0000 CO 0.0000 Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.0075 0.0058 0.0058 0.0075 0.0075 1 PM2.5 0.0075 0.0058 0.0058 0.0075 0.0075 1 SOx 0.0006 0.0005 0.0005 0.0006 0.0006 0 NOx 0.0683 0.0525 0.0525 0.0683 0.0683 12 VOC 36.7676 28.2828 1.4141 36.7676 1.8384 312 CO 0.0000 0.2394 0.2394 03112 0.3112 53 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) ti Benzene 286.120 220.093 11.005 286.120 14.306 Toluene 278.817 214.475 10.724 278.817 13.941 Ethylbenzene 48.856 37.581 1.879 48.856 2.443 Xylene 112.801 86.770 4.339 112.801 5.640 n-Hexane 2034.092 1564.686 78.234 2034.092 101.705 224 TMP 4.669 3.592 0.180 4.669 0.233 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.8.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) 3 of 5 C:\Users\hslaught\Desktop\123A09D\19WE0996.CP1 Separator Venting Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements • • • • Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on apressurized liquid sample (Sampled upstream of then S P Y P P ( P P k � '� ; equipment covered under this AIRs ID) and process simulation to estimate emissions? This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site-specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. 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 1. According to the application, two wells produce to this facility. The well names and API numbers are as follows: (i) Name: Rohn 9-60 #14A-23-1, API Number: 05-123-47781; (ii) Name: Rohn 9-60 #14A-23-3, API Number: 05-123-47780. The COGCC data indicates the wells were fractured in May 2019 and began production in June 2019. Both wells produce from the Niobrara formation. Since the wells at this facility were newly constructed and hydraulically fractured after 08/01/2014, they are subject to Regulation 7, Part D, Section II.F. The heater treaters are controlled by an enclosed combustor during VRU downtime that meets the requirements of Regulation 7, Part D, Section II. 2. In order to develop site specific emission factors, the operator utilized a site specific pressurized liquid sample in conjunction with ProMax. The pressurized liquid sample was obtained from the outlet of the three-phase heated separator for the Rohn 9-60 14A-23-1 well on 10/04/2019. The sample temperature and pressure are 115°F and 84 psig respectively. The pressurized liquid sample is used as an input for the ProMax simulation. The ProMax simulation is used to estimate the waste gas volume and composition for the three-phase heater treaters. The weight % values and gas molecular weight from the ProMax simulation along with the displacement equation (shown in Section 03) were used to estimate emissions from this source. 3. The operator has requested to use liquid throughput to demonstrate ongoing compliance for this source rather than gas throughput. According to engineer guidance, liquid throughput may be used for ongoing compliance for separation equipment when uncontrolled requested VOC emissions are less than 100 tpy. In this case, uncontrolled requested VOC emissions are 36.77 tpy. As a result, liquid throughput was accepted as a viable option for demonstrating ongoing compliance. It should be noted that the operator will measure hydrocarbon liquid throughput at the outlet of the crude oil storage vessels to demonstrate compliance with this source. 4. The produced water storage vessels, hydrocarbon loadout, separator venting and crude oil storage vessels are controlled by the same enclosed combustor at this facility. Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device. In this case, the highest emitting source is the crude oil storage vessels. As a result, the pilot light combustion emissions are included in the analysis for the crude oil storage vessels (19WE0993). 5. Emissions from this source are only routed the enclosed combustor during VRU downtime. As a result, the operator is required to track VRU downtime and the liquid throughput during the downtime in order to demonstrate compliance with the process and emission limits included in the permit. The permit contains a condition requiring the operator to track these parameters for ongoing compliance demonstration. 6. Even though CO emissions from this source specifically are below APEN reporting thresholds (2 tpy), the total CO emissions from all sources controlled by the enclosed combustor (produced water storage vessels, crude oil storage vessels, separator venting and hydrocarbon loadout) are greater than APEN thresholds. As a result, the permit for each source controlled by the common control device will include limits on CO emissions. It should be noted that NOx emissions from all the sources controlled by the enclosed combustor are below APEN reporting thresholds. 7. Periodic visible emissions checks for the control device are addressed by the O&M plan. As a result, the permit does not contain periodic opacity testing. 8. The pressurized liquid sample used to estimate emissions and develop site specific emission factors is site specific, was obtained within one year of application submittal and was taken upstream of the three-phase heater treaters. The sample was also obtained after all the wells at this facility began production. As a result, the permit will not require the operator to obtain an initial sample to demonstrate initial compliance. Ongoing testing is also not required because permitted facility VOC emissions are less than 90 tpy. 9. N-Hexane, benzene and toluene are the only HAPs with emissions above APEN reporting thresholds (i.e. >250 lb/year). As a result, they are the only HAPs for which emission factors are included in the permit. 10. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments. i .... ...".x... w.. 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'_ .4 . • Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point It Process # SCC Code Pollutant Uncontrolled Emissions Factor Control % Units 004 01 3-10-001-29 Oil & Gas Production: Gas/liquid separation PM10 1.3 0 Ib/1000bbl PM2.5 1.3 0 Ib/1000bbi SOx 0.1 0 Ib/1000bbi NOx 11.7 0 ib/1000bbl VOC 6285.1 95 Ib/1000bbi CO 53.2 0 ib/1000bbl Benzene 24.5 95 Ib/1000bb1 Toluene 23.8 95 lb/1000bbi Ethylbenzene 4.2 95 Ib/1000bbl Xylene 9.6 95 Ib/1000bbl n-Hexane 173.9 95 lb/1000bbi 224 TMP 0.4 95 Ib/1000bbl 4 of 5 C:\Users\hslaught\Desktop\123A09D\19WE0996.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is u: the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3, Part A, Section II.D.1.a)? Yes Source Requires an APEN. Go to the next question 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes Source Requires a permit Source requires a pernlit 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. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? You have indicated that source s in the Attainment Area Colorado Regulation 7,Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after Augus: 1, 2014? Yes Source is subject, go to next question Source b subject to Reguiation 7. Section XVII.8.2. G Section XVII.B.2 -General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section' a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? .: The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVI1.8.2.e Section XVII.B.2.e-Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, ifs implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysts it contains may not apply to a pa.licular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as 'recommend,' "may," 'should,"and 'can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Hello