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Home My WebLink About20202325.tiff .,.„ COLORADO Department of Public CDPH Health&Environment Weld County - Clerk to the Board RECEIVED 11500 St PO Box 758 Greeley, CO 80632 JUL 1 3 2020 July 1, 2020 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On July 2, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Verdad Resources LLC - Timbro 9-59-8B 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 Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator foY CO<r,., 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe 5 ,o''n '7,s'- " Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director ,, ., *, Pvbl i C Re V ;ew CC:PL(TP),HL_(Ds)pa(si/ER/cH/ci ), 2020-2325 Og/O3/2O OG(3m) 0 7/27/20 MGM Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Verdad Resources LLC - Timbro 9-59-8B Pad - Weld County Notice Period Begins: July 2, 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: Timbro 9-59-8B Pad Well Production Facility NWSW SEC 8 T9N R59W Weld County The proposed project or activity is as follows: Applicant proposes a new synthetic minor well production facility in the nonattainment area. Emission sources include crude oil tanks, produced water tanks, hydrocarbon liquid loadout, heater treaters, vapor recovery tower and reciprocating internal combustion engines The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0227 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 COLORADO 1SOWo. Department of Public Icxt Health 5 Environment Denver, Colorado 80246-1530 COLORADO Department of Public 2 I Health 6 Environment r COLORADO 40 *404 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: 20WE0227 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Timbro 9-59-8B Pad Plant AIRS ID: 123/A000 Physical Location: NWSW SEE 8 T9N R59W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description TK01-16 001 Sixteen (16) 400 bbl fixed roof crude oil Enclosed Combustor storage tanks This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at Page 1 of 8 rY COLORADO >� Air Pollution Control Division ite Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.Rov/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: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type TK01-16 001 --- --- 18.2 4.1 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TK01-16 001 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, iI.A.4 ) Process Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point TK01-16 001 Crude oil throughput 2,126,125 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 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) i1. 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. Page3of8 ... COLORADO 40 ,.441,061". Air Pollution Control Division GRPH'-.-. Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 fin 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 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtM) 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 This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, 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 Page 4 of 8 C ;Yp COLORADO Vir Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 18. 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 ancdthe required fee. 19. 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. 20. 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. Page 5 of 8 :v;; COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 21. 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. 22. 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. 23. 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. 24. 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 6 of 8 •Cr COLORADO �/ Air Pollution Control Division tar, Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no 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 1,109 55 001 Toluene 108883 792 40 n-Hexane 110543 9,238 462 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 animal emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) VOC 0.340000 0.017000 Site-specific 71432 Benzene 0.000520 0.000026 emission factors 108883 Toluene 0.000370 0.000019 Promax 110543 n-Hexane 0.004300 0.000215 simulation Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please Page 7 of 8 rY� COLORADO 4. Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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, CO, NOx, HAP 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.govi 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 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 r �» COLORADO 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: 20WE0228 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Timbro 9-59-8B Pad Plant AIRS ID: 123/A0D0 Physical Location: NWSW SEC 8 T9N R59W County: Weld County Description: Welt Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Four (4) 400 bbl fixed roof produced water PW01 04 002 Enclosed Combustor storage tanks 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 clays (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 8 r.Y COLORADO 110 Air Pollution Control Division 1n Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.Rov/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: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type PW01-04 002 --- 3.3 11.8 15.1 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 8 r•:•y COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID PW01-04 002 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, II.A.4.) Process Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point PW01-04 002 Produced Water throughput 1,800,000 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 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 Page 3 of 8 r COLORADO � Air C Pollution Control Division it Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 Et MAINTENANCE REQUIREMENTS 16. Upon startup of these points, 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 OEM 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. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 3e whenever a significant increase in emissions occurs as follows: Page 4 of 8 C ,. .y .....v.r. COLORADO Air Pollution Control Division Department of Public Health 5 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 (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO.per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; 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. GENERAL TERMS AND CONDITIONS 20. 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. 21. 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. 22. 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 Page 5 of 8 C -r COLORADO 41 '400 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 23. 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. 24. 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. 25. 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. 26. 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 6 of 8 C )17. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pair 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 farm 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 ackiressing 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 10,500 525 002 n-Hexane 110543 33,000 1,650 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.068 (lb/MMBtu) 0.068 (lb/MMBtu) AP 42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) VOC 0.262 0.0131 71432 Benzene 0.007 0.00035 CDPHE default 110543 n-Hexane 0.0220 0.0011 emission factors Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each Page 7 of 8 0 C ,;•;, COLORADO Air Pollution Control Division �ii6 Department of Public Health&Environment Dedicated to protecting and improving the heath and environment of the people of Colorado 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, CO, NOx, HAP 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 rf, COLORADO 410 16.14 Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0229 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Timbro 9-59-8B Pad Plant AIRS ID: 123/A0D0 Physical Location: NWSW SEC 8 T9N R59W County: Weld County Description Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description Truck loadout of crude oil by TL01 003 submerged fill using vapor balance Enclosed Combustors This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 C1 :IT COLORADO Air Pollution Control Division iiiil Department of Public Health h Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.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: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type TL01 003 --- --- 5.6 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 10 yv. COLORADO `/ Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 TL01 003 Enclosed Cumbustors VOC and HAP 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 TL01 003 Crude Oil Loaded 2,126,125 barrels The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous 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. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) Page 3 of 10 r.,„ COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 12. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 13. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 14. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control 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. Page 4 of 10 C r COLORADO Air Pollution Control Division Department or Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. • 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 Et MAINTENANCE REQUIREMENTS 18. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtM) 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 OEM 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. Page 5 of 10 r•:". COLORADO 49 44401.0 Air Pollution Control Division tie Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: 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. GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does Page 6 of 10 Cr~iit��.�� COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division`(APCD)on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Page 7 of 10 rY:: COLORADO -4440440 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued Verdad Resources LLC • Page 8 of 10 r.Yx COLORADO 40 4,1,94111 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no 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 ackiressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: 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 383 19 003 n-Hexane 110543 3,402 170 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 animal emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled Pollutant CAS # Emission Factors Emission Factors Source lb/bbl lb/bbl V0C 0.104 0.0052 Benzene 71432 0.00018 0.000009 CDPHE default emission factors n-Hexane 110543 0.0016 0.00008 Controlled emission factors are based on a flare efficiency of 95%and a collection efficiency of 100%. Page 9 of 10 Cr��•� COLORADO -444 .0 Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP 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: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 �� r�r COLORADO Air Pollution Control Division Department of Pubttc Health&Env ronment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0230 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Timbro 9-59-8B Pad Plant AIRS ID: 123/A0D0 Physical Location: NWSW SEC 8 T9N R59W . County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description Emissions from two heater treater HT-VENT01 004 separators during VRU compressor Enclosed Combustor 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 C 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 www.cotorado.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: Equipment ID AIRS Tons per Year Emission Point PM2.5 NO. VOC CO Type HT-VENT01 004 --- --- 5.0 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 10 C ,, ,e...z:,.. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled Emissions from the heater treater are HT-VENT01 004 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, II.A.4.) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point HT-VENT01 004 Crude oil throughput 74,414 bbl/yr during VRU downtime 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 while emissions are routed to the control device. 11. The owner or operator must use monthly VRU downtime records, monthly crude oil throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 12. 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) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 15. The separator covered by this permit is subject to Regulation 7, Part D, Section IIF. 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. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0EtM) 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 Oa_tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 C � • COLORADO Air Pollution Control Division Department of Public Health b Env ronrrent Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements. 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the Last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO.per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; 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 Page 5 of 10 Crv.. COLORADO tom/ Air Pollution Control Division i.`' Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • No later than 30 days before the existing APEN expires. 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. 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 Page 6 of 10 COLORADO _ _ _ Air Pollution Control Division + Department of Public Health&Envwonment Dedicated to protecting and improving the health and environment of the people of Colorado 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 7 of 10 rYY 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 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 621 31 HT-VENT01 004 Toluene 108883 575 29 n-Hexane 110543 4,729 236 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 COLORADO Air Pollution Control Division Department of Public Health b 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) VOC 2.66 0.133 71432 Benzene 0.0083 0.00042 Site-specific 108883 Toluene 0.0077 0.00039 emission factors 110543 n-Hexane 0.0636 0.00318 Promax simulation Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call.the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP 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 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 Page 9 of 10 �•., COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.8980-End , Subpart NNNNN - Subpart XXXXXX Page 10 of 10 r COLORADO I / Air Pollution Control Division ® Department of Public Heath&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0231 Issuance: 1 Date issued: Issued to: Verdad Resources LLC Facility Name: Timbro 9-59-8B Pad Plant AIRS ID: 123/ADDS Physical Location: NWSW SEC 8 T9N R59W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Equipment Description Emissions Control ID Point Description VRT-VENT01 005 Emissions from two vapor recovery towers Enclosed Combustor (VRT) during VRU compressor 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 permt. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 9 �r.~.x- COLORADO 111 ®_/ Air Pollution Control Division �� Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 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 VRT-VENT01 005 --- --- 0.8 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 9 y .IM COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) Equipment AIRS Control Device Pollutants ID Point Controlled Emissions from the VRTs are routed to an VRT-VENTO1 005 enclosed combustor during Vapor Recovery VOC and HAP 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, II.A.4.) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point Crude oil throughput VRT-VENTO1 005 74,414 bbl/yr during VRU downtime 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 while emissions are routed to the control device. 11. The owner or operator must use monthly VRU downtime records, monthly condensate/crude oil throughput records, calculation methods detailed in the OEtM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS Page 3 of 9 Cam. -xY: COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. 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.)E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 15. The 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, a- 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. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Page 4 of 9 GYM COLORADO 4. illi Mr Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Initial Testing Requirements 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, 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 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. Page 5 of 9 C10 r.y.: COLORADO Air Pollution Control Division ite Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 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. Page 6 of 9 r COLORADO %/ Air Pollution Control Division ® Department of Public Health 8 Eneronment Dedicated to protecting and improving the health and environment of the people of Colorado 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 7 of 9 CCr,7M COLORADO 0 'AO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ` AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) VRT-VENT01 005 n-Hexane 110543 489 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: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/bbl) (lb/bbl) VOC 0.428 0.0214 Site-specific emission factors 110543 n-Hexane 0.0066 0.0033 Promax simulation Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A Page 8 of 9 C40 , ,,,,....:,:t.rCOLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and ianproving.the health and environment of the people of Colorado 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, CO, NOx, HAP 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 NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A = Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63..1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: -Ci,ristopher Kester Package#: Received Date: 1. Review Start Date: =516,2520 Section 01-Facility Information Company Name: Vertad Resources Quadrant Section Township Range County AIRS ID: 323 NWSW 8 9N 59'.. Plant AIRS ID: HT-_ Facility Name: T,-,br..3:,9-88 Physical Address/Location: _ -.._,c r ;: )1,11 County: Weld County Type of Facility: <np(a'aticn&Produrt on Weti Pad What industry segment?WI&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 Permit# AIRS Point# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Control? APCD has already # Required? Action Remarks has already assigned) assigned) Permit initial 001 Storage Tank TK01-16 - Yes 20W E0227 1 Yes - issuance Condensate _ - - Permit Initial Produced 002 - Storage Tank PWO1-04 Yes 20WE0228 1 Yea Issuance Water Permit Initial 003 Liquid Loading. TL01 Ym 2OAEO229 1 Ves tnsuance Permit Initial 004 Separator Venting .- HT-VENTOI - Yea 20WE0230. 1 Yes Issuance Heater?cater - - - - - - - Permit Initial 005 - Separator Venting = VRT-VErdTO1 Yes 2OWEO231 1 Yes - Issuance VRT _. Permit Initial 006 Natural Gas RICE V-ENG01 -Yes 55-32 - - issuance Permit Initial 007 Natural Gas RICE V-ENGO2 - Yes CY02 ' Issuance Permit Initial 008 Natural Gas RICE V•6N003 Yes G-02 Issuance Permit Initial 009 Natural Gas RICE- -- GL-ENG01 Yes -?'t'-2 - issuance Section 03-Description of Project =ev synthetic outside of the nor-_- :nment area. Sections 04,05 6,06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? --Requesting Synthetic Minor Rdax;t Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? do If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? _. If yes,indicate programs and which pollutants: 002 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration IPSO) 0000130 Title V Operating Permits(OP) ❑ © ® 6 0 0 0 Non-Attainment New Source Review(NANSR) ❑ 0 Is this stationary source a major source? _. If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 0 0 0 0 ❑ 0 Title V Operating Permits(CO 0 0 0 0 0 ❑ 0 0 Non-Attainment New Source Review(NANSR) ❑ ❑ Storage Tank(s)Emissions Inventory Section 01-Administrative Information 123 AODO CO1 Facility AIRs ID: County Plant Point Section 02-Equipment Description Details Storage Tank Liquid Detailed Emissions Unit ifrted'roof crude" t`?''g°t rs--, "tqWlV - k'^^rTf '� Description: � ft .it�r" a Emission Control Device EnaPased'C m)hustgrs.,' Description: Requested Overall VOC&HAP Control Efficiency U: SOW,-;:cot Limited Process Parameter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= .sa`„ 1,700,ROO.0"Barrels(bbl)per year (Requested Permit Limit Throughput= 4x,2;1;6,125.0_x.Barrels(hbl)per year Requested Monthly Throughput= 180575.0 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput 21Zfr,125.0.;Barrels(bbl)per year Secondary Emissions-Combustion Device(s) • Heat content of waste gas= 2346.8-Btu/scf Volume of waste gas emitted per BBL of liquids produced= 5.2 scf/bbl Actual heat content of waste gas routed to combustion device= 22.537 MMBTU per year Requested heat content of waste gas routed to combustion device= 25,7.16.3 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= -....3 MMBTU per year Control Device Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf ..-..MMBTU/yr Section 04-Emissions Fasters&Methodologies Will this storage tank emit flash emissions? EMEIZEI Crude Oil Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Crude Oil (Crude Oil Throughput) Throughput) • 0.340000.. IIMMM .....: r y t v lerziisisztameemml Control Device Uncontrolled Uncontrolled Pollutant llb/MMBtu) llb/hbl) Emission Factor Seorce (waste heat (Crude Oil . combusted) Throughput) ® x wf I If >. ® -{P-1,41"42•5) 0.0000 0;0681 0.0008 AP CTa r33,5 lndvstr al Flares ll6O 4 MINEBEIMIS®AP- aP₹e113 5 hfdu trial F13r 6505 E"" Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source(Pilot Gas Heat (Pilot Gas Combusted) Throughput) 0.0000 ® 0-0000 • 0.0000 f,,j., ,`,, 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) (tans/year) (tans/year) (lbs/month) PM10 0.1 0.1 9 0.1 0.9 .16- PM2.5 0.1 0,1 2 0.1 0.1 16.3 50x 0.0 0.0 0.0 0.0 0.0 NOx 0.9 0.7 2 7 0.9 1 148.7 VOC 351.4 289.2 14.5 361.1 13.1 2460 4a CO 4.0 3.2 30 4.0 -50 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ihs/yeerl (lbs/year) (lbs/year) (lbs/year) Benzene 1108.5 834.5 -.4.2 1105.5 53.3 Toluene 706.7 629.3 3_.5 786.7 .f,._ Ethylbenzene 91.4 73.1 3.7 91.4 • 2 of 22 K:\PA\2020\20WE0227.CP1 Storage Tank(s)Emissions Inventory Xylene 212 170.1 3.5 212.6 10.8 n-Hexane 9142.3 7313.9 365.7 9182.3 4571 224 TMP 63.8 51.0 _.8 63.33 3.2 • • 3 of 22 K:\PA\2020\20W E0227.CP1 Storage Tati'(s)Efliissio s[nventory Section 06-Regulatpry Summary Analysis Regulation 3,Parts A,B Soo rc_requires a Regulation 7,Part D,Section I.C,D,E,F s"towage Tank is•< - ,. ,, Regulation 7,Part D,Section I.G,C 5terago Tank Is I Regulation 7,Part D,Section II.B,Cl,. C.3 _ ge tank is> Regulation 7,Part D,Section ll.C.2 Storage.tank is a: Regulation 7,Part D,Section ll.C.4.a.(i) Storage Tank is^, Regulation 7,Part D,Section ll.C.4.a.(ii) Storage Teak is r; ... Regulation 6,Part A,NSPS Subpart Kb Stwage Tank€s,- Regulation 6,Part A,N5P5 Subpart 0000 SZaragetank is+? _ ..1. NSPS Subpart 0000a. Tani,is,, -. .tea Regulation 8,Part E,MACE Subpart fill St's--=g„Tans , - (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors t t '{+ estimate emissions? If yes,are the uncontrolled actual or requests emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the d ` uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? Ryes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? c/ z Ryes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being s r permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis).This sample Ors s 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 fine),then it maybe appropriate to use an Zr ka k5' (y, alder site-specific sample. ` If no,the permit will contain en"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? ,1 �✓Z`" t ., If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 01 PM10 ,_.. lb/1,000 gallons Crude Oil throughput PM2.5 .3.331 lb/1,000 gallons Crude Oil throughput 50x -..<_;. 0 lb/1,000 gallons Crude Oil throughput NOx 0.3.1 0 lb/1,000 gallons Crude Oil throughput VOC 88.10 95 lb/1,000 gallons Crude Oil throughput CO C:,VS 0 lb/1,000 gallons Crude Oil throughput Benzene 0,01 95 lb/1,000 gallons Crude Oil throughput Toluene 0.03 95 lb/1,000 gallons Crude Oil throughput Ethylbenzene S O 95 lb/1,000.gallons Crude Oil throughput Xylene 0.10 95 lb/1,000 gallons Crude Oil throughput n-Hexane 0.1-68 95 lb/1,000 gallons Crude Oil throughput 224 TMP 0:00 95 lb/1,000 gallons Crude Oil throughput 4 of 22 K:\PA\2020\ZDWE0227.CP1 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below ore determined based on requested emissions. Colorado Reeulation3 Parts A and B-APES and Permit Requirements sosmeslEptho Ams, - ATTAINMENT 1. Are uncontrolledactual emissions from any criteria pollutants from this Individual source greater than 2TPV(Regulation 3,Part A,Section Il.D.1a)? Y&WI,V Source Requires an APES.Go to Ar 2. Is the conrtructian date prior to 4/14/2014 and not modified after 4/14/14 with storagetankthroughput less than 40,000 gallons per year(See PS Memo 34-03 for additional guidance on grandfather applicability)? AIV1145.4 Go to next question 3. Aetotal facility ancontrolled VOC emissions greaterthan 5 TPY,NO5 greater than 10TPV or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.D.317 :14-51-/t'2,151 Source Requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l WY(Regulation 3,Part A,Section ll.D.1.a)7 2. the coistructiondate prior to 4/14/2014 and not modifiedafter 4/14/14 with a storagetankthroughputless than 40,000 gallons per year(See PS Memo 14.03 for additional guidance on grandfather applicability)? 3 Are total f ility wco.rolled VOC emissions greater than 2TPY,Not greater than 5TPY or CO emissions greater than sl WI(Regulation 3,Part B,Section 110217 Colorado nsosf0tion],Part D,Section I.C-F&G 1. Isthsstorage teak located in the 8-hr ozone control area or any ozone non.attalnment area or attainment{naintenance area(Regulation 7,Part 0,Section 1.6.117 No Storage Tank is not subject to Rs 2. Is this storage teak located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation 7,Part D,Section IAA)? 3. Is this storage tack located et a natural gas processing plant(Regulation 7,Part D,Section 1.617 No StoregeTank is not subject to Rs 4, Does this storage tank contain condensate? nlu 5. Does thisstoragetank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation 7,part D,Section 1.0.2)? Yos 6 Are uncontrolledactual emissions ofth [ g nit equal[or greater than 2 tons per year VOC(Regulation 7,Part I,Sadist l.D.3al i)1?• • i .k Part D,Section 12.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Part 0,Section 12.2—Emission Estimation Procedures Part 0,Section Emissions Control Requirements Part D,Section II—Monitoring Part D,Section LE—Recordkeeping and Reporting Ts4SE is rapt ecCoats,RE4≤3,47447 7.Ses_vn l.b Part D,Section l Sx2-Emissions Control Requirements Part 0,Section IS.l.a and b—General Requirements for Air Pollution control Equipment—Prevention of IFeakage Colorado Regulation,.Part D.Section II 1. Is this storagetaek located at a transmission/storagefaciley7 Continue-You have indicatedth 2. Is thisztoragetaek'located at an oil and gas exploration and production operation,well production facileµ,natural gas compressor stations or natural gas processing plant°(Regulation 7,Part 0,Section II.C)? Go tothe nexiquestion-You ha 3. Does this storage tank have afixed roof(Regulation 7,Part D,Section 33..0.20)7 .:s Go to the next question 4. Are uncontrolled actual emissions ofthh storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part 0,Section 11.51.4? Sowces subject to parts of Roe 144,,,,m4hissubjest ESE ,,I' _i5 C.3 Part 0,Norton ISO—seneial Provisions for Air Pollution Control Equipment and Prevention of Emissions Part 0,Section 160:1-Emissions Control and Monitoring Provisions Part 0 Section I5C3 RecordkeepingRequirements 5 Does the rag k contain only ''stabilized liquids(Regulation 7,Part D,Section ll.C.2.h)? P,> 'Sources subject to all provision: Part 0,Section ICC.0.Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural;gas processing plant constructed on or after May 1,2020 or located at afaciliry that was modified on or after May 1,2020,such 6. that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput al hydrocarbon liquids or produced water(Regulation 7,Part 0,Section It C.4.a.D17 No Storage Tank is not subject to Re is the trolled storage tank l t d at a wellproduction facility,natural gas p rstaton,or naturabgw processing plant connected on or afterlanuary 1,2021 or located at a facility that was modified on ar afterianuary 1, 7. 2021,such that at additional controlled s age vessels constructed t n cipated increasein throughput of hydrocarbon liquids or produced water(Regulation],Part 0,Section llCda.()7 40 CFR,Part60,Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels 1 Is the Individual storage vessel capacity greater than or equal to 7S cubic meters 1m51(`412 BBLs](40 CFR bD.110b(a)17 1,16 Storage Tank is not subject N5P5 2. Does the storagevessel meet the following exemption in 60.111b(d)(4)? ;OAR a.Doesthe vessel has a design capacity less than or equal to 1,589.874 ma(^10,000 BBL1 used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined in 60.111? 3. Was this storage vessel constructed,reconstructed,or modified(seedefinitions 40 CFR,60.2)after July 23,1984(40 CFR60.110b(a)l? 4. Does the tank meet the definition of"storage vessel"'in60.111b? 5. Does the etoragevessel store a"volatile organic liquid(VOL)"sas defined in 60.1116? 6. Does the storagevesel meet any one of thefollawingaddeional exemptions: a.Istheaorage vessel a pressure vessel designed to operate In excess of 204.9 kPa F-29.7 psi'andaeithout emssionstothe atmosphere(60.110b(d)(3)17;or b.The design cxpaary is greater than or equalto 151 ma(-950 BBL]and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa(60.110b(b))7;or c.The design Capacity Is greater than or equal to 75 M°[-472 BBL]but Iessthan 151 m°['950 BBL]and stores a liquid with a maximum true vapor pressure less than 15.0 kPa(60.110b(b))? 7. Does the storagetank meet either one of the following exemptions from control requirements: a.The design capacity Is greater than or equalta 151 m(^950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa7;or b.The design capacity Is greater than or equal to 75 M°[-472 BBL]hut less than 151 ma[`950 BBlland stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? In.• i..n4,n not.a,blegty NSPS Kb I • 40 CFR,Part 50.Subpart0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution 1. Is this 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? c Continue-You have indicatedth 2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)between Augpst 23,2011 and September 18.20157 Storage Tanks not subject NSPS 3. Was this storage v sel constructed,reconstructed,or modified(see definitions 40CFR,60.2)after September 18,2015? Y v Go m the next question 4. Are potential AOC emissions'from the individual aoragevessel greater than or equal to Suns per year. fop. n",4.t•Storage Tank is not subject NSPS 5. Does ihlsstoragevessel meet the definition of"storage vessel'per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 45 CF&Part 60 Subpart Kb or 40 CFR Part 63 subpart HH7 [Note:If a storage vessel is previously determined to be subject to NSPS 0000/0000a duets emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS 0000/000c.per 60.5365]e)(2)/6o5365ale)(1)even If potential VOC emissions drop below 6 tons per year] 40 CFR,Part 63.Subpart MAR HH.Olt and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criseria: (Continue-you have Indicated th a.Afacilry that processes,upgrades or stares hydrocarbon liquids'(63.760131(2)1;OR b.Afacilny that processes,upgrades or stores natural gas prior to the point at which natural gas eaters the natural gastransmission and storage source category or is delivered to a final end user'(63.760(a)(3)I? 2. Is the tank located at a facility that is majors for HAPs? ,.•r StorageTanks not subject MAC 3. Does thetank meet the definition of"storage vessel"'in 63.7617 4. Doesthetank meet the definition of"storage vessel with the potentialfor flash emissions"'per 63.7617 5. Is the tank subject to control requirements under 40 CFR Part GO,Subpart lob or Subpart 0000? St_ art t;. Subpart A,General provisions per 063.764(a)Table 2 §63.756-Emissions Control Standards §63.773-Monitoring 063.724-Recordkeeping §63.775-Reporting BAR Review PACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area.Hobe-tank meets both criteria,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation, or any other legally binding requirement end is not legally enforceable.In the event of any conflict between the language of this document end the language of the Clean Air Act„its implementing regulations, and Air Quality Conrol 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 end Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. • -i Ta:+t0 . ciL: .k:`ci"t3 Section 01-Administrative Information Facility Al Rs ID: 123'. . ' A0130 002 ' County Plant Point Section 02-Equipment Description Details Storage Tank Liquid T": Detailed Emissions Unit Voitt[4}l(0601fsmil roof tti43t(ttCE5E'W7.t44"6totagotiolm'•°' Description: - . -- Emission Control Device '3<itclgsedCoMbastofu ' Description: . . Requested Overall VOC&HAP Control Efficiency l: 89,tO Limited Process Parameter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tankls) Actual Throughput= - 1,300,000;0 Barrels(bbl)peryear 'Requested Permit Limit Throughput= -., 3,$0(!400,6 Barrels(bbl)per year Requested Monthly Throughput= 10,70 7 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= 2,800;000;0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 4996.0 etu/scf Volume of waste gas emitted per BBL of liquids produced= 06.0 scf/bbl Actual heat content of waste gas aouted to combustion device= ' . 'MMBTU per year Requested heat content of waste gas routed to combustion device= •: - MMBTU peryear Potential to Emit(PTE)heat content of waste gas routed to combustion device= - MMBTU per year Control Device .'Pilot Fuel Use Rate: -';t'f`ir0�, - .'MMscf/yr�' scfh Pilot Fuel Gas Heating Value: - . Btu/scf .MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? 4 -_ gill Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) VOC u03426 Benzene r '6 70 50 IUL t Toluene :t.-5el'ii. _ Ethylbenzene 's„,r u Ifi,g, ., €.7J XYlene M • 0.8100 n-Hexane '42i3.74.';?.-2::, 0.0211 .1. 4 n 224 IMP t:s" ;t21,A 0.2000 ,ii-,=tya"', eM- 0 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lh/hbl( Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 rO.-Rr'T(t:Yi$7 tr, V U Ic PM2.5 500 yr r..3E4c0;, -P r^us'K NOx 'nit f °q,{' o .-,r t ..:X�f- CO �a-"r, . 2 u'1d+ 16'.', ie• �714Tf^ so Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 .:, • _... '._tt ''' ,-,. •, PM2.5 C3 4, 50x - _ '1097C ,.. NOx VOC D0 4.k 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) PMSO 2.4 03 03 04 CA 61.5 PM2.5 O4 0.3 .3 0.4 04 61.3 SOx 02 0.a1 :_ 0.0 0.3 0.0 NOx 3 i _.. 2 7 3.3 3.3 559.4 VOC :1i 73 104- 48 2358 01.8 .00,'..1 CO tS 0 __0 -2.5 15 0 15.4 2352.3 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 11600.•1 11521.2 520.0 120:0 0 r530 4 Toluene ._ 0.7 OA GA 0.0 Ethylbenzene ... 1 3 ,, if 1 0.0 7 of 22 X:\PA\2020\20W E0227.CP1 Storage Tank(s)ErTrissions In°gym tor' xyIene. 0.0 0.9 0.0 0.0 0.3 n-Hexane 39600.0 33000.0 1650.0 39600 0 _950.0 224 TMP 0.0 0.0 0.0 0.0 0. • • • • 8 of 22 K:\PA\2020\20WE0227.CP1 Storage Tank(s)-Emissions Inventory Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a pern^P Regulation 7,Part D,Section LC,0,E,F Storage.7anks not sub -i t D.Section 1.C-F Regulation 7,Part D,Section I.G,C Storage,Tag,.s not cub,. _.,on I Regulation 7,Part D,Section II.B,0.1,C.3 Storage E subject to s0ntion II,0,0.1 2 C.3 Regulation 7,Part D,Section 11.02 5,rag.tana i_ biect to Regisiiii- rpsiction 11.0.2 Regulation 7,Part D,Section II.C4a.(i) 0'., .o:...6.s not,o bie t too _. action II.C Regulation 7,Part D,Section II.C.4.a.(iil .:Poi-age r_,-x;s not subject to 1. 'on C.n Regulation 6,Part A,NSPS Subpart Kb Storages-arts is rot subject o Sr_ Regulation 6,Part A,NSPS Subpart 0000 ..-_ ,...is:.wt s.il:iect re O. _C NSPS Subpart 0000a Stgrbige T_n:is::.tsu hies- ',5 PS!''0(5G Regulation 8,Part E,MACE Subpart HH .v,,.sCSister.S.o ragetools s not Jest,o Nitter^:H (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors to fib estimate emissions? , If yes,are the uncontrolled actual or requested emissions fora crude oil tank estimated to be greater tharror equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than orxqual to 80 tpy?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? If yes and if there are flash emissions,are the emissions factors based one pressurized liquid sample drawn at the facility being ,,;e permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation arnlysls)?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 mot been modified(e.g.,no new wells brought on-line),then it may be appropriate to use en n. ,� t}-"`i older site-specific sample. ti.4 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 devices fgn If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-0X Section OB-Technical Analysis Notes Section 09-SCC Coding and Emissions Factors(For Inventory Use Odd Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 002 01 PM10 0.01 - 16/1,000 gallons Produced Water throughput PM2.5 G. 16/1,000 gallons Produced Water throughput 5Ox 'o.,u/Srii 0 lb/1,000 gallons Produced Water throughput NOx e,0' _ lb/1,000 gallons Produced Water throughput VOC _,_, lb/1,000 gallons Produced Water throughput CO 0:40 0 16/1,000 gallons Produced Water throughput Benzene 1,17 95 lb/1,000 gallons Produced Water throughput Toluene 0.30 95 lb/1,000 gallons Produced Water throughput Ethylbenzene C:00 95 lb/1,000 gallons Produced Water throughput Xylene 1,r11 95 lb/1,000 gallons Produced Water throughput n-Hexane 1 52 95 lb/1,000 gallons Produced Water throughput 224 TMP 0 O 95 lb/1,000 gallons Produced Water throughput 9 of 22 Kr\PA\2020\20WE0227.CP1 • • Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Calaredo AandB APEN d Permit lie auirements ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants fromthls Individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? rr". iSource Requires an APEN.Go to 2. Produced Water Tanks have no grendfatirenng provisions ,., Go to next question 3. Aretotel facility uncontrolled VOC emissions greater than 5 TPV,NOx greater than IOTPY or CO emissions greater than 1OTPY(Regulation 3,Part R,Section 11.0.3)? - Source Requires permit ISouwe requlr�a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria p llutants from this individual source greater than 1TPY(Regulation 3,Part A,Section llTla)? 2. Produced Wat Tanks h o g dith gpovisions 3 Are total facility uncontrolled VOC missions greater than 2TPY,NOx greeter than 5TPY or CO emissions greater than IOTPY(Regulation 3,Part B,Section 11.0.2)7 ":u a.,< .I... •:;'..r_.._......t".c.krtaimnert Aren Caloredo Regulation].Part D.Section I.C-F&G • 1. Is this storage tank located in the 0-hr ozone control area or any oznon-attainment area or attainment/maintenance area(Regulation 7,Part 0,Section I.A.1)? Nn Storage Tank Is not subjectto DE 2. Is this storage tank located at oil and gas operations that collect,sto e,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation 7,Part 0,Section IA.1)? Vas 3. Isthustorage tank located ate natural gas processing plant(Regulation 7,Pert 0,Section 1.617 Ne Storage Tank Is not subject to so 4. Doesthis storage tank contain condensate? Eta 5. Does this storage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation],part D,Section 1.6.217 r 6. Are uncontrolled actual emissions of this storagetank equal to or greater than 2 tons per year VOC(Regulation 7,Parts,Section l.0.3.a(R))? ..w. Part O,Section 1.C.1 General Requirements for Air Pollution Control Equipment—Prevention of Leakage • Part D,Section I.C.2—Emission Estimation Procedures Part la,Section l.0—Embsions Control Requirements Part D,Section I.1—Monitoring Part 0,Section I.F—Recordkeeping and Reporting ., m =ulo -kiun,.G Part 0,Section I.G.2-Emissions Control Requirements Part 0,Section I.C.1.a and b—General Requirements for Alt Pollution Control Equipment—Prevention of Leakage Colorado Regulation 7,Part e,Section 11 1. Is this storage tank located ate transmission/storagefacility? .-. Continue-You have indicated Oh 2. Is this storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressor Malian'on natural gas processing plant"(Regulation 7,Part 0,Section II.4' iros Go tothe next question-You ha 3. Does this storage tank have afxed roof(Regulation 7,Part 0,Section ll.A.20)? Yetrt"rtglr.Go tothe rem question 4. Are uncontrolled actual emissionsof this t ge tank equalt or greater than 2 tons per year VOC(Regulation 7,Part 0,Section ll.C.l.cf? .vaargo.Source is subject to parts of Reg, P art 0,Section II.e—General Provisions for Air Pollution Control Equipment and Prevention of Emissions P ate,Section 11.C.1-Emissions Control and Monitoring Provision Part 0 Section IIC3 RecordkeepingR q 5 Does thestorage k contain only"stabilised"quid(Regulation 7,Part 0,Section II.C.2.61? N8°-7.15ource is subject to all provision Parte,Section llC2 Capture and Monitoring for StorageTanks fitted with Air Pollution Control Equipment Is the controlled storage tank l ated at a well production faciltty,natural gas compressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified on or after May 1,2020,such 6. that en additional controlled storage vessel h constructed to receive an anticipated increase inthroughput of hydrocarbon liquids or produced water(Regulation 7,Part D,Section ll.C.4.a.(1)7 Yu- -:'Storage Tank isnot subject to Re It; is the controlled storage tankl d at a wellp d facility,natural g p or station,or natural gas processing plant constructed on or afterlanuary 1,2021 or located at a facility that was modgied on or after January 1, p.T 7. 2021,such that an additional controlled storage vessel s constructed t c anticipated Increase In throughput of hydrocarbon liquids or produced water(Regulation 7,P000 Section ll.C.4,a1i1)7 40 CFR Part%.5 by rt Kb.Standards of Performancefor Volatile Organic Liquid Storage Vessels 1. the di dal storage p ity g ater than or equal to 75 cubic meters lml['472 BBLs](40CFR 60.110bla))7 In Storage Tank Is not subject NSPS 2. Doesthe storage vessel meet the f lI g exemption In 60.111b(d)(4)? a.Does the vessel has design capacity less than or equal to 1,589.874 m'[`10,000 BBL]used for petroleum'or condensate stored,processed,en treated prior to custody transfer'as defined in 60.1116? 3. Wasthis storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984(40 CFR 60.ltab(a)[? 4. Does the tank meet the definition of"storage vessel"'In 60.1136? 5. Does the storage vessel More a"volatile organic liquid(VOL)"'as defined in 60.1116? 6. Does thestorage vessel meet any one of the following additional exemptions: a.Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa[-29.7 psi]and without emissions to the atmosphere(60.11ob(d)(2))7;or -*I;f , b.The design capacity is greater than or equal to 151m'I`950 BBL)and stores a liquid with a maximum true vapor pressure`less than 3.5 kPa(60.110h(b))7;or •T.Vii c.The design capacity is greater than or equal to 75 Ma(-472 BBL]but less than 151 m'(-950 BBL)and stores a Squid with a maximum true vapor pressure`less than 15.0 kPa(60.11ob(b))7 ? 7. Does the storage tank meet either one of the following exemptions from control requirements: and stores a liquid with a maximum true vapor greater than or equal to 3.5 kPa but less than 5.2 kPa?;or a.The design capactyisgreaterthanorequalto 151m r950 BBL] qui porpressure b.The design capacity Is greater than or equal to 75 M'[-472 BBL]but Iessthan 151 m5[-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? 40 CFR,Part 60.Subpart 0000/0000a.Stenderdsot Performance for Crude Oil and Natural Gas Production,Transmission and misnibu0on 1. Is this 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? hrt. Continue-You have indicated th 2 Wasthis storage ves sel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? rtrt rh.?.Storage Tank Is not subject NSPS 3. Wasthis storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,2015? "`,Go to the next question 4. Are potential VOC emissions'from the individualstorage vessel greater than or equal to goons per year? rts Storage Tank is not subject NSPS 5. Does this storage vessel meet the definition of"storage vessel"'per 60.5430/60.5430a? G. Is the storage vessel subject to and controlled in accordance with requirements forstorege vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart OH? ,. [Note:If a storage vessel Is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,It should remain subject to NSPS 0000/00008 per 60.5365(e)(2)/60.536See(e)(2)even If potential VOC emissions drop below 6 tons per year] 40 CFR,Part 53,Subpart MAR NH,Oil and Gas Production Facilities 1. Is thertarege tank located at an oil and natural gas production ferny that meets either of the following criteria: Yes Continue-You have Indicated tit a.Afacllity that processes,upgrades or stores hydrocarbon liquids'(63.76D(e)(2));OR b.AtacilOy that processes,upgrades or stares natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered toe final end user'(63.760(`)(3))? 2. Is thelerk located et a facility that 6 major'for HAPs? E Storage Tank is not subject MAC 3. Does the tank meet the definition of"storage vessel"'in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for-rash emissions"'per 63.761? r, S. Is the tank subject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 0000? I Produced Valor Stornire'.,c, -iinr,ioct.MACTIi Fl Subpart A,General provlsions per 463.764(a)Table 2 453.755-Emissions Control Standards 463.773-Monitoring 463.774-Recordkeeping 463.775-Reporting RACT Review RAC'review is required If Regulation 7 does not apply AND if the tank is in the rwmatteinment area.If the tank meets both criteria,then review PACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a curs or regulation,and the analysis it contains may not apply to a particularsituetion Erased upon the individual facts and circumstances.This document does not change or substitute for any tar✓,regulation, or any other legally binding requirement end 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 reguletim will control.The use of non-mandatory language such as"recommend,""may,""should,"and"oan,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and°required"am intended to describe controlling requirements under the terms ofthe Clean Air Act end Air Quality Control Commission regulations,but this document does not establish legally banding requirements in and of itself. drocar 3 r ro ov°Er-ps;r Orfv Inve,t0.7 Section 01-Administrative Information Facility AIRS ID: d. a '1tt''�'w` "--�;,tfir,,ie un '°',..cto ... County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit 744 . tea' • rag .44 Description: rt�1Y.p Emission Control Device ` c0.,ga ▪a;."-" '- ,c.-5444,455V;55' • r." r ,5, Ts as r1 . y ?.,.z 4 4 M a Description: r Is this loadout controlled? rs . Requested Overall VOC&HAP Control Efficiency%: Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= 1745;5400 Barrels(bbl)per year !Requested Permit Limit Throughput= '_.'-5 Barrels(bbl)per year Requested Monthly Throughput= 110575 Barrels(bbl)per month Potential to Emit((PTE)Volume Loaded= ? Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= Btu/scf Actual Volume of waste gas emitted per year= ,.s._..:,.scf/year Requested Volume of waste gas emitted peryear= '-7EG^?scf/year Actual heat content of waste gas routed to combustion device= >_,'MMBTU per year Requested heat content of waste gas routed to combustion device= ; t3 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= MMBTU per year Control Device I I I - Pilot Fuel Use Rate: t'▪ .1- .'„ ..l g'scfh � MMscf/yr Pilot Fuel Gas Heating Value: sr^�*'g { 7 Btu/scf _.1 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? ,,.::E..__c - •m,ns a._-s^ay 0.,a,.. e..n-v. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC _CvaCc 4.crg,v Benzene 0.10011 "00007~ 5551,55:55k55,555,54555.5554,545.-4.4(554'45545155 '5C44454494434,5- Toluene 0.00407 4.00;r}G7 Ethylbenzene 0.60000 XYlene 0.00007 C.^.nCC" ,40,5515'5'55'-4 c'4155-455541474.55445444455k- n-Hexane 05M160 ,._. _ =,as55555 . °, 224 TMP 0.76000 5,5-5 5::54455-5D-05541ACCA5555,5545,4,50 1:505,555,145505-5.575,5:45c 455. Control Device Uncontrolled Uncontrolled Pollutant Emission Factor Source (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 ` 5_ 455115',514`50,1544,4551-114113:; PM2.5 SOx ,.,.+. NOx Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM10 PM2.5 64,4„44 4.4 4.44474.44444444444444444,4410-. Sox NOx VOC w_€;3 .0'44 5044455454 tict-444050-"040.445,540x4h5555,54.45, 12 of 22 K:\PA\2020\20WE0227.CP1 Hydrocarbon L'i1 tt)o'1)x0IOLs In Yv to'y Section OS-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled uncontrolled Controlled Uncontrolled Controlled Controlled Itons/year) (tons/year) (tons/year) (tans/year) Bons/year) (Ibs/month) PM10 d.ilY 0.01 sal. PM2.5 0.01 '1.01 0.05. 3__ 5Ox 0.00 0.01 _ 0.00 __> Nog 0393 ..,,. ,)1/ 0.13 3'.10 voc t 1o.s6 130313 .3312 20.s6 0,03 CO ,._.. 3._. v._ 0.01 051 Potential to Emit - Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled -Uncontrolled Controlled uncontrolled Controlled (Ibs/year) (Ibs/year) (lbs/year) (lbs/year) (Ibs/year) Benzene .333 300 _ 303 1 Toluene 11 +? 0 3 Ethylbenzene 0 0 3 0 Xylene .. .. 0 1. n-Hexane _. 33 3433. 129 224TMP 0 Section OR-Regulatory Summar/Analysis Regulation 3,Parts A,B ,. Regulation 7 Part 0 Section ll.C.5. (See regulatory applicability worksheet for detailed analysis) ' Section 07-Initial and Periodic Samolinz and Testing Requirements Does the cam an request acontrol device efficient p y ygreaterthan 95%fora flare or<ombustion device? Dyes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point If Process0 5CC Code Pollutant Factor Control% Units 003 Ol PM10 '.-2, .. lb/1,000 gallons transferred PM2.5 3.30C� _ lb/1,000 gallons transferred 000 _.'0 0 lb/1,000 gallons transferred NOx 3.•30'3 .. 15/1,000 gallons transferred VOC os lb/1,000 gallons transferred CO (1.01 15/1,000 gallons transferred Ben ne ,.i>; 5s 15/1,000 gallons transferred Toluene :i.C• 33 Ib/1,000 gallons transferred Ethylbenzene '.0. 01 lb/1,000 gallons transferred Xylene 0 113, 33 lb/1,000 gallons transferred n-Hexane lb/1,000 gallons transferred 224TMP 2.10 0' lb/1,000 gallons transferred • 13 of 22 K:\PA\2020\20WE0227.CP1. Hydrocarbon Laadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput, .lorado Regulation 3 Parts A and B-AP.and Permit Requirements ATTAINMENT 1.Are �a,,, uncontrolled actual emissions from any criteria pollutants from thislndlvldual source greater than 2TPY(Regulation 3,Part A,See. ^ extgdeseon. 2. Is the loadout located at an exploration and production site(e.g.,well pall(Regulation 3,Part a,sec.11.0.1.11} p;+y«$: i Gob the next question 3. Is the loadout operation loading lessthan 10,000 gallons{t32Nisi of crude ollpertlay on an annual average basis] NriDDEW Go to next question k the loadout operation loading less than G,]Sn bbls per year of condensate via splash DP y. '' • 5. Is the loadout operation loading less than 15,30E obis per year of condensate Na submerged fill procedure} ss Gob neat question facility u ed VOC emissions greater Man 5 Tir,N.greater than 10 ITN or CO emissions greater Man lO INT(Reguation 3,PartB section 103)} Ry` Theloadoutrequee permit NONATTAINMENT 1.Are uncontrolled missions from any criteria pollutants from this Individual source greater frog l TPY(Regulation 3,Part A,Secb'on 11.0.1.a1i 2. the loadout located at an exploration and production site(e.e well pad)(Regulation 3,Part 3,Section 11.0.1.11} 3. Is the loadout operation loading less than 10,000 gallons(239 9Eu1 of crude oil per day on an annual average basis} 6. Is the loadout operation loading less than 6,750 obis per year of condensate via splash fill} 5. Is the loadout operation loading less than lq,aos obis per year of condensate via submerged fill procedure} 6.Are total faciliNu VOC emissions from the greater thanYR,NOx greater than 5 TPY or CO emissions greater than lO TIN(Regulation 3,Part 3,section 11.0.21, Colorado Regulation]Part o section US. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility,natural gas compressor station or natural gas processing plant, ";Got°next quesdptr 2. Does Me facility have houghput of hydrcrarbon transport vehicles greater ton or equal to 5000 barrels} v,s Soufres subject to Regulation]Part°Section ll.C.5. Serfitritil.CS.a.71- schedule Sectiona.ldl-C vjIoadotut Equipment Operation and Maintenance Section .a.(v)-Reords observations and OcemmrTaining Section cs.a.(v1-Record: Section II.GS.a(vil-pequifements for Air Pollution Control Equipment • Disclaimer This document assists operators with determining applicability d certain requirements of the Clean Air Act,its implementing raga/Miens,and Alr quality Control Commission regulations.This document's not rule orregulaHon,and the analysis it contains may net apply toe particular situation based upon the individual facts and circumstances.This document does not change orsubsotde for tiny law,regulation,or eny other legally binding requirement end is not legally enforceable In the event of any conflict between the language d this document end the language of the Clean Air Act„its implementing regulations, and Alr quality Control Commission regulations,the language tithe statute or regulation will control The use alnanmendetoy language such as"recommend,"'prey,""slould,"end"can,"is Intended to • describe APCb Interpretations end recommendations.Mandatory temunolooy such as"must"end"squired"are intendedfodescnbe controlling requirements under the femas of the Clean Air Act and Air quality Control Commission regulations.Out this document d net establish legally binotng requirements in end d ifsei. Section 01-Administrative Information Facility AIRs ID: 123 AODO 004 County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Description: Two heatert€egtetawlsdans during ktfiLt compressor downtime . Emission Control Device Description: EnetpaedCo hnstors Requested Overall VOC&HAP Control Efficiency%: 95 Limited Process Parameter A Section 03-Processing Rate Information for Emissions Estimates > Primary Emissions-Separator Actual Throughput= ,O33AZ t Barrels(bbl)per year Requested Permit Limit Throughput 74,41433 Barrels(bbl)per year Requested Monthly Throughput= :i;<=:; Barrels(bbl)per month Potential to Emit(PTE)Throughput= -.n Barrels(hbl)per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: ..7036.6 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: .:43,.3 scf/bbl Control Device Pilot Fuel Use Rate: srfh 'MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04-Emissions Factors&Methodologies Description . s7'sed . uplrfwsne svmtita anuf'prptnaxtp estimate emirsintis, MW 36.8 Ib/Ib-mol Displacement Equation Ex=Q.MW•Xx/C Weight% Helium :'-6F<'Bge, CO2 F..,. ,. N2 . Tr:$#2' methane s13729 ethane propane 539a isobutane 136 n-butane ___5 3 isopentane _ n-pentane cyclopentane 458 n-Hexane 071 cyclohexane _ Other hexanes heptanes 1,02 methylcyclohexane - 224 TMP 19 Benzene 9.236 Toluene 9,19.1. Ethylbenzene i°60673 Xylenes .'31=371 CB+Heavies ,..." 2 Total VOCWt% .. ... 15 of 22 K:\PA\2020\20W E0227.CP1 St?pc1: (t l ,•ent •` E i1;,S.D iS€,bentory Emission Factors Separator Venting Uncontrolled Controlled (113/13b1) (1113/13131) Emission Factor Source Pollutant (Liquid Throughput) (Liquid Throughput) VOC 2.'6036 0.13333 Benzene .,,.v_ 0 0004, 3.0 Toluene 3 000030 Ethylbenzene _. 0.0000E Xylene -- 0.0001= ,.,...::: n-Hexane 224 TMPlia - _ Primary Control Device Uncontrolled - Uncontrolled Pollutant (Ib/MMBtu) lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0 OC.75 0.0300 _ ) PM2.5 11.091.5 0.0003 ,# SOx 010009 - 0 1001 NOx C:.0F 1 1.91' CO 0.3100. 0 0170 1 44A14t,M a_ s(I34-441133 Pilot Light Emissions Uncontrolled - Uncontrolled _ Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Comhusted) (Pilot Gas Throughput) PM10 C 000C PM2.5 C•7 - - ...."3101-1.0 3331h1"113"133" 1.ts SOx 0.39313y. VOC c,v3, - _ Section OS-Emissions Inventory , Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tors/year) (lbs/month) PM10 0.3 0.0 c it 0 0 :`.t 4 PM2.5 9.0 0.0 0,3 04 4 SOx 0.0 0 0 .1 4 .,,s 0 NOx 02 n2 is? 0.2 ..2 37 VOC 79.3 .1.1 .1 5." 003 CO 10 G.9 1:" 1._ 17? Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ms/year) (lbs/year) (lbs/year) (Ibs/year) Ohs/year) Benzene =97 24 021 3.1 Toluene .:., 0,31 21 -.0 29 Ethylbenzene 70 37 -, Xylene .. 2 _._ - 25-2 11 n-Hexane 141 a?r} ___ 224 TMP _. < ,_ Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Cu,...•r.siu.rss a perm... Regulation 7,Part D,Section II.B,F 5•:mre is s sb ect o 0agularan 7.Past•e,00 t.,9 t1.4 2 F Regulation 7,Part D,Section II.B.2.e rho contra!de3333.foe tissy.par 5'..,.. ........,,_. ..,., .•r ,.+9,.,.=..e,, :1 r (See regulatory applicability worksheet for detailed analysis) 16 of 22 K:\PA\2020\20WE0227.CP1 Section 07-Initial and Periodic Sampling and Testing Requirements rv<i Y,�J� .%ue-:',' zT."�s�lx::ff:'%e z:F�r::�. �-::E�E&v" r - .f:�n _ ,f£<l:.�J.. :s..x, <Ji.:..:..:.. ..:ri�,.. <.:.s:i.. sx'-: !/:i- .1 11111111 h 41,W: yy - ,a ,., :.: , ::.,f3:. —.fir;i . _ � h V : %' Lr: .. 71f. I J - 5 , , v..'6v.". _ :f,Ex:.,,.,_ ,'of ms w, - �rfrf jrosrmjimAswAmwiwkwsw s _::.. E<:: �"qY'{, �r«:v: <':.,Y �' � :.zmm, tj'.Ci a�� -�Ys rs _ "�':' _Z;....: %{ ,c T-�-<z e z��- , f-.""fir fr 5J � ;`�� '� EE�� !. .. '.is• .�',ixs;:::E✓i.;.re:v�'r'°!n-✓ .: � "'. _: �„r �' 0JT% E .:.J.*ire.` �' ; f, .. ,G-Y,✓,, :..: ,,: _ , f ✓' V i ..f f h'l.:srf_::kS"�.%"i::�i... fil 90 . r�iY��_.✓ry 3 r v sn';,.f.::- Ye,s, z'" £,9% ..nz„�,.r5z:x _ _ f'�i5iFa _ _ E. : , ".xis ��!� ,,<:r r , f" < a::r < s .r a, v,=.:.�f '. .. Q'.rY,v,,:af�.0 r FJ/U. .' e <:.. fz,:sjn:a�a � E'FY 'x✓e" �fi / �",��'��f xi'r'.n5:..-,_, .e �I.;. ��..�5 3,£n« ,.,, nfv,4._ >,�✓,r';1y .�Y��x�. < Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample(Sampled upstream of the equipment covered under this AIRS ID)and process simulation to estimate emissions? s "+ 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 maybe appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to collect a site<speciffc 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 co nbustion device? If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) AIRS Point q Process If SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 004 01 .,.0_0,00..-_i,7eslligiud Sep-0 ancr PM10 vase?z PM2.5 :,0 '3 S=r,!s 5O0 0.1 ::ba.rzis NOx 5.9 ban-e15 VOC 2660.6 _:oar-el. CO 27 0 Benzene 8.3 Toluene 7.7 Ethylbenzene 1.2 Xylene 2.9 'sr -;.00111, �-.- n-Hexane 63.0 224 TMP 0.5 17 of 22 _ K:\PA\2020\20WE0227.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 coerce es in she Attstnr,c,t.Arca ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? Yes - Source Re 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than lO TPY(Regulation 3,Part B,Section 11.0.317 Source Re 'source requires a oe.mit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than!TPY(Regulation 3;Part A,Section 11.0.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than lO TPY(Regulation 3,Part B,Section 11.0.217 Yo..... and toted that sources it the Attainment Aran Colorado Regulation 7 Part 0,Section II 1. Was the well newly constructed,hydraulically f t d or recompleted on or after August 1,20147 5 'Source ist Section 1l.B,2-General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Emissions Control(Optional Section). a. Is this separator controlled by a back-up or alternate combustion device Q.e.,not the primary control device)that is not enclosed? 'The cents, ? this--c;-.:-' not tsubieco to Regt hitters 0,Par O,Section'I B.Ae Section 11.a.2.e-Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply toe 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. • Section 01-Administrative Information Facility Allis ID: 123 A000 005 County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Description: TWO vapor recovery tower(VET)emissions during YOU compressor downtime Emission Control Device Description: Enclosed combustion device Requested Overall VOC&HAP Control Efficiency%: 95 Limited Process Parameter '. .i. i= ' : ;/ - Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 3P53L.&Barrels(bbl)per year IRequested Permit Limit Throughput= 74,81.44 Barrels(bbl)per year Requested MonthlyThroughput= •. .- Barrels(bbl)per month Potential to Emit(PTE)Throughput= 2._."Barrels(bbl)per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 4192.6 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: 6.8 scf/bhl Control Device I Pilot Fuel Use Rate: scfh . - MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04-Emissions Factors&Methodologies Description blued upstream sample antiproton to estimate emissions.' IMW I _ 36.8 Ib/Ib-mol Displacement Equation Ex MW°Xx/C Weight Helium CO2 3.358. N2 .=:5:.3 methane 20.457 ethane propane 52.309 isobutane n-butane isopentane 33.240 n-pentane 4,130 cyclopentane . `5.345 n-Hexane cyclohexane Other hexanes - heptanes methylcyclohexane 99.228 224-TMP 4.557 Benzene 3.30. Toluene Ethylbenzene acqz Xylenes 0.4.70 CB+Heavies 0.327 Total_ .. .. VOC Wt% 19 of 22 K:\PA\2020\20WE0227.CP1 Separator Vertilg Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source Pollutant (Liquid Throughput) (Liquid Throughput) VOC Benzene " z:- _ Toluene Ethylbenzene -1:. Xylene ._.. n-Hexane _ 224TMP a Cc_-_ ..... Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0,0075 AP:42 TaNe 1 4--2..(PM n/PM,2 5)- , PMZ.5 0.0075 1P.72 TahJe1:.421(PM10/PM.2,55) } sox 0.0006 - 'E eT a-2(SOX NOx 0.06E0. ,*`'g0 , CO +0.3100 t .V Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM2.5 �t r1,4 SOx 1'"" ��.0 NOx ,f,4,`Kc CO P-; 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 0,0 0.0 0.3 0.0 0.4 .. PM2.5 =3,.e 11,1 0.0 0.0 .:.C _ 50x 0.0 0,0 0,0 0.0 0.3 ., NOx 0,0 0.C 5.0 0,0 6 VOC 12.1 0,0 15.9 0.3 135 CO 0.2 6,., 0.1 0.2 G.2 28 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 .,_ 5u _ 66 3 Toluene 53 43 _. 50 2 Ethylbenzene E, 6 0 Xylene t-, ii 14 1 n-Hexane 350 392 490 24 224TMP 4 _ S 4 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,0 Not enough infarmat'on Regulation 7,Part D,Section II.B,F Not enough ir:farirratioe Regulation 7,Part D,Section 11.0.2.e Not enough inforzatton (See regulatory applicability worksheet for detailed analysis) 20 of 22 K:\PA\2020\20WE0227.CP1 - - "lissolla -e-ita v Section 07-Initial and Periodic Sampling and Tenting Requirements r"T'NN 1 ,,+v;;'�i�ec%� .s/. rt: '6.,5.. asr '- L,' `�,' A✓_' Y ,7" "'IE,y WF, ✓ „.t,..":," ter. .`-�,�,,'_..a,'- y'i₹r"�f: kmamiromh 111;v .. .. :: .„ �. 7' r a'i'D �.r�'' envoir . ; ,:.sz :, :s , i r�' :x.z- OllMilleUeellauellilllul'rer�r r it - ,o ....,le l.,}v:•, - h gr .:.lelli"t: •.Elhl ₹%:- >ntF ,t ,,,A,O��...'.:.�:Fx: ''/rri''/�`.','% z F =r��'�i.,x r r. ., r...•.ss.rz elleelellePlleul �',' € ....,':s,.r,,P` rP Il i^s r,: m. .-„.: : f r. _VjgragrlOgrektiftikaktigesemeje.gritTitiMitarogiwolc•x.4:"�; ':' )'.s'i, ¢v:i x i 3e i -' "'.-,' ,'rc,,e'' 91'r,;,4/x"' Wm x"i.:: ;i .;ia 3. a; Eft u / ` ' /. ,.E n —iv-l z: . 11;611>rr n ,a iL s �. d;t h, 0,,i e.: <r. :, r , -:x,r",r„i .,.tim :«-r,b?c::r.,, r fts y r; '/r,'/G•",'�s, ,.M. ",r'� ..4�! '; ,� .. ,F„,M2 fji aria umaot r mittigammou ,F , .e .r. '. � � � � is r..r„=�✓."" 'F a�,rr� ..c,� 3t- L��s, _(�,_ ,,i.z��_.� v ,,z " �.u, ',�.� "�..Nr'?e r_,, :i.:�lllX+++ :�:.;,,e,:z-,;. .:. :s :' l"'✓ iz :r/ ',I -.7•;.e "r" -zE >✓� d_ - ,�. z��z i �.:� n.,.s�ii ��;.'rs�� ¢ '.f3 f - :E�'r, .F,}:ter::. „...,„.,,.,,,,,,,„„.„,,,,,,,,,,,,,,,,,,..„,,,,,,.„.„4.,,,,, n£ mut og ,;,,,'ME ,,,,, yn .zs. k ,,r,z, t. z •' Nf,,�3;.'e'",H"e:r.: ti>a �'t,".r b - r.:,..:r,Rj'.::r"�W✓:`:r.�� _ ". ._ .z .✓�rt .f�•...': ≥: _ ..,<,Y.:' i �� :; .: �'a., ,r.r` i ::2,'W„'a. ",r.. /„' f= mrs'. t: a v✓r I s 'o;!" i::"".�,.v..r.�.:;.,, "F:FF¢ gip: v :.:::ri:::,�.., x",r.ry:>r�E�h r v Fa:r�-"'a:�•�`�•' .r�,��'s� .�ir ` r - it h,y:��„^i;3-y'F''�:.::i✓, r,-<,,, r. :�.... '.,,L :r, ;;„' .,.�.:'£,,ie ,,�,� '..."..,'..�:aE`�4F5�i„l:s�`.�r�;,z• ,� � ri, IF / / ''� f ,;fry ,� , :,. — ti'iiiti��e.:,,' ,.e , ti iu t„. ,_, ,J,,,..„,n'e5S%L3:.tAn`.'�,..'L d7d£<` ';hh,rs s':,Af r,.w„t:E:'3. z/z'w,5.{: 4 ,uvnre rm�',r'm`m,ice°,r, ,xrr,.vi,'I„zzvr,mrrwa,rr.,rumu.: y, .E " „,rrin'ni''-"rzm'�� , Using Liquid Throughput to Monitor Compliance Does the company use sites spec emission factors based on a ressurized liquid sam le Sam led u tream of the P Y Pe P p I P Ps 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 maybe appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to collect site-specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the em lssions factors established with this application. Does the company request a control device efficiency greaterthan 95%for a flare or combustion device? 3 If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes eCA Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control Units 005 01 „„ ,t`.1,",_ , ., _ .:c.�,a PM10 p l _ S.rges PM2.5 0L - r�= SOx G 0 0007% ..0 - 900 1.0 VOC 425,0 S^ ,- CO 4.4 C ,95 Benzene 0.9 0.7 95 Toluene Ethylbenzene 0.1 -1 _ - Xylene 0,2 99 n-Hexane G G as 224TMP +)0 E.,5 21 of 22 K:\PA\2020\20W E02Z7.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 Regulrements (source Is In the AY;oinmeol Anen ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? -- 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than to TPY or CO emissions greater than 10TPV(Regulation 3,Part B,Section 11.0.3)? (Not enough Infcrma:io NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants front this individual source greater than l TPY(Regulation 3,Part A,Section ll.O.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than 5 TPV or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)? f"ou have indica,o,.__:_a,ca_.nthe A:tainmen.area Colorado Regulation 7,Part D,Section II . 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? I I Mot enough inlormnt+on Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Emiulons Control(Optional Section]. a. Is this p ator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? Section 11.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts end 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. • • Prc'rr J,!,,,, JAW 1 5 2028 Crude Oil Storage Tank(s) APEN Y Form APCD-210 5 CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment fora new filing fee. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading,etc.). In addition, the General APEN (Form APCD-2OO) 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. 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, li.C. for revised APEN requirements. Permit Number: 2(4lik)EijZ�7 MRS ID Number: 123 /AcDp/DOI [Leave blank unless APCD has already assigned a permit#and AIRS ID] • Section 1 -Administrative Information Company Name': Verdad Resources LLC Site Name: Timbro 9-59-8B Pad Site Location Site Location: NWSW Sec 8 T9N R59W County: Weld 40.761695/-104.009524 NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Contact Person: Brad Ganong Phone Number: 720-845-6918 E-Mail Address2: bganong@verdadresources.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. 424373 �/�► COLORADO Form APCD 210 Crude Oil Storage Tank(s) APEN Revision 12/2019 1 > b Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action 12 NEW permit OR newly-reported emission source ® Request coverage under traditional construction permit ❑ Request coverage under General Permit GPO8 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 O Change permit limit O Transfer of ownership"' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Initial Permit Application - Site-Specific Emission Factors 3 For company name change, a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Crude oil storage tanks Company equipment Identification No. (optional): TKO 1-1 6 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 11/15/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑I Exploration£t Production(EaP)site O Midstream or Downstream (non EEtP)site Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes El No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) Yes No 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 ® Yes ❑ No emissions a 6 ton/yr(per storage tank)? COLORADO Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 12/2019 2 �'"° ""`°" Permit Number: AIRS ID Number: 1 / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbt/year) Crude Oil Throughput: 1,700,900 2,126,125 From what year is the actual annual amount? Projected 2020 Average API gravity of sales oil: -35 degrees RVP of sales oil: —6.8 Tank design: ❑✓ Fixed roof ❑ Internal floating roof ❑External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production• (bbt) Storage Tank(month/year) (month/year) TK01-16 16 6,400 10/2019 11/2019 Wells Serviced by this Storage Tank or Tank Battery6(E£tP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 47568 Timbro 9-59#8B-9-1 (05-123-47568) ❑� 05 - 123 - 47575 Timbro 9-59#88-9-2(05-123-47575) ❑� 05 - 123 - 47581 Timbro 9-59#8B-9-4(05-123-47581) ❑ 05 - 123 - 47572 Timbro 9-59#86-9-8(05-123-47572) ❑✓ 05 - 123 - 47578 Timbro 9-59#86-9-9(05-123-47578) ❑✓ 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 The EEtP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.761695/-104.009524 • ❑ Check box if the following information is not applicable to the source because emissions wilt not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack Discharge Height/above Temp. Flow Rate Velocity ID No. Ground Level(Feet) ("F) (ACFM) (ft/see) EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) ❑✓ Upward 0 Downward ❑Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter(inches): 96 ❑Square/rectangle Interior stack Nadth(inches): Interior stack depth(inches): ❑Other(describe): COLORADO Form APCD 210 Crude Oil Storage Tank(s) APEN Revision 12/2019 3 �'`"""NW�T6f.M1.l[gp11 O Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#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: 0 Recovery Unit(VRU): Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC/HAPs Rating: N/A MMBtu/hr Type: 2x Enclosed Combustors Make/Model: 2x GCO Beast 20O0 ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2,346.8 Btu/scf Constant Pilot Light: El Yes ❑ No Pilot Burner Rating: 0.0534 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 (EttP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -7 psig Describe the separation process between the well and the storage tanks: Produced fluids from the wells are directed to ten 3-phase horizontal heated separators. From the separators, oil is directed to two 3-phase horizontal heater treaters for further separation and pressure reduction. From the heater treater, oil is directed to two VRTs. From the VRTs, oil is directed to the storage tanks. leeCOLORADO Form APCD 210 Crude Oil Storage Tank(s) APEN Revision 12/2019 4 i lieilT En"monma`6 t Permit Number: MRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? 0 Yes 0 No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency , Control Efficiency Pollutant . Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC Enclosed Combustor 100 95 NOx CO RAPS Enclosed Combustor 100 95 Other: From what year is the following reported actual annual emissions data? Projected 2020 Use the following table to report the criteria pollutant emissions from source: ? Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions8 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (torts/year) VOC 0.34 Ib/bbl Site-Specific 290.71 14.54 363.38 18.17 NO. 0.00085 Ib/bbl Calc/AP-42 e 0.72 0.72 0.90 0.90 CO 0.0038 Ib/bbl Calc/AP-42 3.21 3.21 4.01 4.01 5 Requested values will become permit limitations or wilt be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on ail APENs,including APEN updates. 7 Attach crude oil laboratory analysis,stack best results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 9 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑ No pollutants (e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Uncontrolled Service(CAS) ncontroed Units (AP-42, Emissions Emissions8 Number Basis Mfg.,etc.) Os/year) (lbs/year) Benzene 71432 0.00052 Iblbbl Site-Specific 887.08 44.35 Toluene 108883 0.00037 Ib/bbl Site-Specific 633.65 31.68 Ethylbenzene 100414 0.0(30043 Ib/bbl Site-Specific 73.95 3.70 Xylene 1330207 0.00010 Ib/bbl Site-Specific 166.49 8.32 n-Hexane 110543 0.0043 lb/bbl Site-Specific 7,390.20 369.51 2,2,4-Trimethylpentane 540841 0.000030 Ib/bbl Site-Specific 50.46 2.52 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. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. coLoaAoo Form APCD-21O Crude Oil Storage Tank(s) APEN - Revision 12/2019 5 a. ,a" Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 10- 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 GP08, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP08. ///1//2o 20 Signature of eg Authorized Person (not a vendor or consultant) Date Michael Cugnetti Director of EHS&R Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692.3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD 210 Crude Oil Storage Tank(s)APEN Revision 12/2019 6 th6Bal lie• S ,/qN jszo2o- Produced Water Storage Tank(s) APEN MfM.IM �`Y_�ru Form APCD-207 CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks,condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C.for revised APEN requirements. Permit Number: -Z0 W E 02-2$ AIRS ID Number: 123 /AJ)c6/002 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Verdad Resources LLC Site Name: Timbro 9-59-8B Pad Site Location Site Location: NWSW Sec 8 T9N R59W County: Weld 40.761695/-104.009524 NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Contact Person: Brad Ganong Phone Number: 720-845-6918 E-Mail Address2: bganong@verdadresources.com I 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. 424379 COLORADO Form APCD 207 - Produced Water Storage Tank(s)APEN - Revision 12/2019 1 I ® °"bblim '""c HY11�60R COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ID NEW permit OR newly-reported emission source ❑� Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment ❑ Change company name3 O Change permit limit O Transfer of ownership4 ❑ Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: 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: Produced Water Storage Company equipment Identification No. (optional): PW01-04 For existing sources, operation began on: For new or reconstructed sources,the projected start-up date is: 11/15/19 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: ✓❑ Exploration Et Production(EftP)site O Midstream or Downstream(non EEtP)site Will this equipment be operated in any NAAQS nonattainment area? O Yes 0 No Are Flash Emissions anticipated from these storage tanks? ❑✓ Yes O No Are these storage tanks located at a commercial facility that accepts oil production Yes No wastewater for processing? ❑ ❑ Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? 0 Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) Yes ✓ No 805 series rules?If so, submit Form APCD-105. ❑ ❑ Are you requesting≥6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual emissions≥6 ton/yr(per storage tank)? 0 Yes ❑ No COLORADO " Form APCD-207 - Produced Water Storage Tank(s)APEN - Revision 12/2019 2 I °gent Zwasonsnent ' '°""`AD Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bb/year) (bbU!ear) Produced Water Throughput: 1,500,000 1,800,000 From what year is the actual annual amount? Projected 2020 Tank design: ❑✓ Fixed roof ❑Internal floating roof 0 External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) • Storage Tank(month/year) (monthtyear) PW01-04 4 1,600 10/2019 11/2019 Wells Serviced by this Storage Tank or Tank Battery'(E&P Sites Only) • API Number Name of Well Newly Reported Well 05 - 123 • 47568 Timbro 9-59#8B-9-1 (05-123-47568) ❑✓ 05 • 123 - 47575 Timbro 9-59#86-9-2(05-123-47575) ❑� 05 - 123 - 47581 Timbro 9-59#8B-9-4(05-123-47581) ❑✓ 05 - 123 - 47572 Timbro 9-59#8B-9-8(05-123-47572) ❑� 05 - 123 - 47578 Timbro 9-59#8B-9-9(05-123-47578) 0 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. 'The EEtP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or LITM) 40.761695/-104.009524 ❑Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case,the rest of this section may remain blank. Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec) EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) O Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) EJ Circular Interior stack diameter(inches): 96 ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN • Revision 12/2019 3 I '°"° lIW,1,6Hmvonmul Permit Number: AIRS ID Number: (Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: El Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC/HAPs Rating: N/A MMBtu/hr Type: 2x Endosed Combustors Make/Model: 2x GCO Beast 2000 Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 99 Minimum Temperature: N/A Waste Gas Heat Content: 1 496 Btu/scf Constant Pilot Light: l] Yes ❑ No Pilot Burner Rating: 0.0534 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)? -35 psig Describe the separation process between the well and the storage tanks: Produced fluids from the wells are directed to eight 3-phase horizontal heated separators. From the separators,oil is directed to two 3-phase horizontal heater treaters for further separation and pressure reduction.From the heater treaters,oil is directed to two VRTs. Produced water at the horizontal separators and heater treaters is directed to the storage tanks. kEee COLORAD Form APCD-207- Produced Water Storage Tank(s)APEN • Revision 12/2019 4 I : "O Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Criteria Pollutant Emissions Information Attach all emissions 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 collection and control efficiencies(report the overall,or combined,values if multiple emission control methods were identified in Section 6): Collection Efficiency Controt Efficiency Pollutant Control Equipment Description (X of total emissions captured (X reduction of captured by control equipment) emissions) VOC Enclosed Combustors 100 95 NOx CO HAPs Enclosed Combustors 100 95 Other: From what year is the following reported actual annual emissions data? Projected 2020 Use the following table to report the criteria pollutant emissions from source: Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-11, Emissions Emissions Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 0.262 lb/bbl CDPHE 196.50 9.83 235.80 11.79 NO5 0.0037 lb/bbl Calc/AP-42 2.75 2.75 3.30 3.30 CO 0.017 lb/bbl Calc/AP-42 12.52 12.52 15.03 15.03 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. Section 9- Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor' Actual Annual Emissions . Source Uncontrolled .Controlled Chemical Name service Abstract ) UncomroQad Units (AP-42, Emissions a Number Basis Mfg.,etc.) (lbs/year) (lbsl1Kar) Benzene 71432 0.0070 lb/bbl CDPHE 10,500.00 525.00 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.022 Ib/bbl CDPHE 33,000.00 1,650.00 2,2,4-Trimethylpentane 540841 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLORADO Form APCD 207 Produced Water Storage Tank(s)APEN Revision 12/2019 5 I liWiltberairoammt °'""""""'" Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 10- Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operat in full compliance with each condition of the applicable General Permit. //W2&z Signature of Legally Au rized Person (not a vendor or consultant) Date Michael Cugnetti Director of EHS&R Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD 207 Produced Water Storage Tank(s)APEN Revision 12/2019 6neirebrast 01 MA. E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Forml Company Name: Verdad Resouces LLC Source Name: Timbro 9-59-8B Pad Emissions Source AIRS ID2: 123 /A00 I al- Wells Services by this Storage Tank or Tank Battery(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-47559 Timbro 9-59#8A-9-2(05-123-47559) 05-123-47557 Timbro 9-59#8A-9-4(05-123-47557) 05-123-47560 Timbro 9-59#8A-9-5(05-123-47560) 05-123-47562 Timbro 9-59#8A-9-8(05-123-47562) 05-123-47556 Timbro 9-59#8A-9-9(05-123-47556) - - ❑ 0 0 0 0 0 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter N/A Form APCD-212 B05a_Tank APEN-Addendum Jq',is 289 •,f Hydrocarbon Liquid Loading APEN ''' .... •. Form APCD-208 C CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit,glycol dehydration unit, condensate storage tanks,etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. 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: 2 0 yj(E(P 2 ZcJ AIRS ID Number: '23 /AcDi/603 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name1: Verdad Resources LLC Site Name: Timbro 9-59-8B Pad Site Location: Site Location NWSW Sec 8 T9N R59W County: Weld 40.761695/-104.009524 NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Contact Person: Brad Ganong Phone Number: 720-845-6918 E-Mail Address2: bganong@verdadresources.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes wilt require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 424380 COLORADO Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 12/2019 1 I SO lie4M I, `." Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action O NEW permit OR newly-reported emission source ZJ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ID Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Initial Permit Application -Application to cover emissions prior to installation of the LACT system and oil pipeline 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: Hydrocarbon Truck Loadout Company equipment Identification No. (optional): TL01 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 11/15/2019 Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes ❑Q No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes ❑� No emissions? Does this source load gasoline into transport vehicles? 0 Yes ID No Is this source located at an oil and gas exploration and production site? C] Yes ❑ No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes ❑Q No average? Does this source splash fill less than 6,750 bbl of condensate per year? ❑ Yes ❑ No Does this source submerge fill less than 16,308 bbl of condensate per year? ❑ Yes ❑ No COLORADO Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 12/2019 2 O "a Permit Number: AIRS ID Number: (Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑ Condensate p Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 2,126,125 bbl/year Actual Volume Loaded: 1,700,900 bbl/year This product is loaded from tanks at this facility into: tank trucks (e.g. "rail tank cars"or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Average temperature of Saturation Factor: °F bulk liquid loading: True Vapor Pressure: Psia®60 °F Molecular weight of lb/lb-mol displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable, and should consider future process growth.Requested values are required on all APENs,including APEN updates. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.761695/-104.009524 ❑Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. I!1o. ':k. ;•tip%: `'�^�"r.Yr•':•rS ' EC01-02 ( 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) Upward O Downward O Upward with obstructing raincap ❑ Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 96 ❑Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 12/2019 3 I NYFR b¢�ntanmmr Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Loading occurs using a vapor balance system: Requested Control Efficiency: 100 % Used for control of: VOC,HAPs Rating: N/A MMBtu/hr Type: 2x Enclosed Combustors Make/Model: 2x GCO Beast 2000 rn Combustion Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A °F Waste Gas Heat Content: 2,346.8 Btu/scf Constant Pilot Light: El Yes O No Pilot Burner Rating: 0.0534 MMBtu/hr Pollutants Controlled: O Other: Description: Requested Control Efficiency: Section 7- Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑No If yes, describe the control equipment AND state the collection and control efficiencies(report the overall,or combined,values if multiple emission control methods were identified in Section 6): ui Collection Efficiency Control Efficiency Pollutant Control Equipment pment Description (%of total emissions captured (X reduction of captured by control equipment) emissions) PM SOS NOS CO VOC Vapor Balance/Enclosed Combustor 100 95 HAPs Vapor Balance/Enclosed Combustor 100 95 Other: El Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑� Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected 2020 Use the following table to report the criteriapotlutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units ( 2, Emissions EmissiOns6 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOS NOS 0.00015 lb/bbl Calc/AP-42 0.13 0.13 0.16 0.16 CO 0.00069 lb/bbl Calc/AP-42 0.59 0.59 0.73 0.73 VOC 0.104 Ib/bbl CDPHE 88.45 4.42 110.56 5.53 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLORADO Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 12/2019 4 °' Mm Palk a e Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical - Emission Factor Actual Annual Emissions Chemical!lame Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, • Emissions Emission° Humber Mfg.,etc.) (lbs/year) (fbs/year) Benzene 71432 0.0018 lb/bbl CDPHE 306.16 15.31 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.0016 lb/bbd CDPHE 2,721.44 136.07 2,2,4-Trimethylpentane 540841 Other: 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. 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 GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. 1 Iq/20 a Signaturr'72 Legally horized Person (not a vendor or consultant) Date Michael Cugnetti Director of EHS&R _ Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 12/2019 5 `°"°"" """MbNk66ni.o DO JAN 1 5 2020 M.74M„, Gas Venting APEN - Form CAPCD-211,,-,-� Air Pollutant Emission Notice (APEN) and CDPHE Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment - for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. 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: 20 /602-30 AIRS ID Number: 123 /A02,05/609, [Leave blank unless APCD has already assigned a permit'and AIRS ID] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Timbro 9-59-8B Pad Site Location: NWSW Sec 8 T9N R59W Site Location Weld County: 4O.761695/-1O4.OO9524 NAICS or SIC Code: 1311 Mailing Address: 1125 17th Street, Suite 55O (Include Zip Code) Denver, Colorado 8O2O2 Contact Person: Brad Ganong Phone Number: 720-845-6918 E-Mail Address2: bganong@verdadresources.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 424381 COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 1 i .m`. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly-reported emission.source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 0 Add point to existing permit ❑ Change permit limit 0 Transfer of ownership' 0 Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: 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. (optionalr HT-VENT01 For existing sources, operation began on: For new,modified, or reconstructed sources, the projected start-up date is: 11/15/2019 ❑Check this box if operating hours are 8,760 hours per year;if fewer, fill out the fields below: Normal Hours of Source Operation: Variable hours/day Variable days/week Variable weeks/year Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes No Is this equipment located at a stationary source that is considered a Major Source of(HAP)Emissions? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? 0 Yes ❑ No go COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 2 1 i Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Process Equipment Information Ej Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Slowdown Events #of Events/year: Volume per event: MMscf/event O 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? 0 Yes 0 No Vent Gas BTU/SCF Gas Venting Heating Value: Process Parameterss: Requested: MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput Process Parameters5: Requested: 74,414 bbl/year Actual: 559,532 bbl/year Molecular Weight: 36.77 VOC (Weight%) 65.82 Benzene(Weight%) 0.206 Vented Gas Toluene(Weight%) 0.191 Properties: Ethylbenzene(Weight%) 0.029 Xylene(Weight%) 0.071 n-Hexane(Weight%) 1.571 2,2,4-Trimethylpentane(Weight%) 0.0134 Additional Required Documentation: O Attach a representative gas analysis (including BTEX ft n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX&n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 3 rSun I, , Permit Number: AIRS ID Number: I I [Leave blank unless APCD has already assigned a permit#and AIRS IDi Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.761695/-104.009524 O Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Abw+ t ;.f EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) 0 Upward O Downward O Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 96 ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑ Other(describe): 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: Size: Make/Model: ❑ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC/HAPs Rating: N/A MMBtu/hr Type: 2x Enclosed Combustors Make/Model: 2x GCO Beast 2000 ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NSA Waste Gas Heat Content: 2,086.56 Btu/scf Constant Pilot Light: 0Yes O No Pilot burner Rating: 0.0534 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 4 I Mk � „ , • Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7- Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑Yes O No If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency • Control Efficiency Pollutant Control Equipment Description (x of total emissions captured is reduction of captured by control equipment) emissions) PM Sax NO, CO VOC Enclosed Combustor 100 95 HAPs Enclosed Combustor 100 95 Other: Projected 2020 From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emlesionss Emissions Emissions Basis Mfg',etc-) (tons/year) (tans/year) (tans/year) (tans/year) PM Sox NO, 0.0059 Iblbbl CaIdAP-42 0.18 0.18 0.22 0.22 CO 0.027 Ib/bbl Calc/AP-42 0.80 0.80 1.01 1.01 VOC 2.66 IbIbbl Site-Specific 79,26 - 3.96 99.08 4.95 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. Section 8- Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical • - Emission Factor . Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled ' Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions6 Number Alb-,etc.) ( Year) • • (lbs/year) Benzene 71432 _ 0.0083 lb/bbl Site-Specific 496.96 24.85 Toluene 108883 0.0077 lb/bbl Site-Specific 459.64 22.98 Ethylbenzene 100414 0.0012 lb/bbl Site-Specific 70.18 3.51 Xylene 1330207 0.0029 lb/bbl Site-Specific 171.14 8.56 n-Hexane 110543 0.064 lb/bbl Site-Specific 3.783.19 189.16 2,2,4-Trimethylpentane 540841 0.00054 Ib/bbt Site-Speafic 32.26 1.61 Other: 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 5 ® ice"�, Permit Number: AIRS ID Number: ! / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. ///i//2.40 ZO Signature of Legally Au ed Person (not a vendor or consultant) Date Michael Cugnetti Director of EHS&R Name (print) Title Check the appropriate box to request a copy of the: ❑Draft permit prior to issuance ' ❑r Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303)692-3148 Denver,CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 6 I I JAN 1 5 2020 -.M,M, Gas Venting APEN - Form APCD-21 • CtY Air Pollutant Emission Notice (APEN) and CDPHE Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. 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: 20 w'Etp 2-3 / AIRS ID Number: (2L /Apm/6 o5 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Verdad Resources LLC Site Name: Timbro 9-59-8B Pad Site Location Site Location: NWSW Sec 8 T9N R59W Weld County: 4O.761695/-1O4.OO9524 NAICS or SIC Code: 1311 Mailing Address: 1125 17th Street, Suite 55O (Include Zip Code) Denver, Colorado 80202 Contact Person: Brad Ganong Phone Number: 72O-845-6918 E-Mail Address2: bganong@verdadresources.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. 424382 COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 1 I illa Permit Number: AIRS ID Number: [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- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit o Change permit limit ❑ Transfer of ownership4 0 Other(describe below) -OR APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ID Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et 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: VRT venting during VRU compressor downtime Company equipment Identification No. (optional): VRT-VENTOI For existing sources, operation began on: For new,modified, or reconstructed sources, the projected start-up date is: 11/15/2019 ❑Check this box if operating hours are 8,760 hours per year;if fewer, fill out the fields below: Normal Hours of Source Operation: Variable hours/day Variable days/week Variable weeks/year Will this equipment be operated in any NAAQS ❑ Yes Q No nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of(HAP) Emissions? ❑ Yes No Is this equipment subject to Colorado Regulation No. 7, Yes 0 No Section XVII.G? COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 2 Snot " Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Process Equipment Information El Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event El Other Description: Vapor Recovery Tower 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 ❑✓ No Vent Gas BTU/5CF Gas Venting Heating Value: Process Parameterss: Requested: MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput Process Parameterss Requested: 74,414 bbl/year Actual: 59,532 bbl/year Molecular Weight: 36.87 VOC (Weight%) 64.28 Benzene(Weight%) 0.133 Vented Gas Toluene(Weight%) 0.100 Properties: Ethylbenzene(Weight%) 0.012 Xylene(Weight%) 0.029 n-Hexane(Weight%) 0.989 2,2,4-Trimethylpentane(Weight%) 0.0074 Additional Required Documentation: ❑ Attach a representative gas analysis (including BTEX Et n-Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and ❑ f pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. SO COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 3 .n« t Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (LatitudelLongltude or LITAf) 40.761695/-104.009524 0 Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. ..•....tic,ID Na; . rFI � dalie�) .. ,Feet) EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) Upward 0 Downward 0 Upward with obstructing raincap 0 Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 96 ❑ Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑Other(describe): 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: N/A MMBtu/hr Type: 2x Enclosed Combustors Make/Model: 2x GCO Beast 2OOO ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2,092.56 Btu/scf Constant Pilot Light: ❑ Yes 0 No Pilot burner Rating: 0.0534 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: SC COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 4 I • Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7- Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? O Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or combined, values if multiple emission control methods were identified in Section 6): Equipment Description Collection Efficiency Control Efficiency Pollutant Control E 4uiP ►iP (X of total emissions captured (%reduction of captured by control equipment) emissions) PM 5O, NO, CO VOC Enclosed Combustor 100 95 HAPs Enclosed Combustor 100 95 Other: Projected 2020 From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: • Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)s Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/yeas) (toralyear) (tons/year) PM SOx NO. 0.00097 lb/bbl Caic/AP42 0.029 0.029 0.036 0.036 CO 0.0044 lb/bbl Calc/AP-42 0.13 0.13 0.17 0.17 VOC 0.43 lbibbl Site-Specific 12.72 0.64 15.90 0.79 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APEN5,including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑No pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical . Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Endst ions6 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0.00088 Ibibbl Site-specific 52.63 263 Toluene 108883 0.0066 Itibbl site-specific 39.44 1.97 Ethylbenzene 100414 0.000083 lb/bbl Site-Specific 4.91 0.25 Xylene 1330207 0.00019 lb/bbl Site-Specific 11.60 0.58 n-Hexane 110543 0.0066 lb/bbl Site-Specific 391.24 19.56 2,2,4-Trimethylpentane 540841 0.000049 lb/bbl Site-Specific 2.91 0.15 Other: 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLORADO Form APCD-211 Gas Venting APEN • Revision 12/2019 5 I ® COLORADO e.anbltmearrN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. „Avere7//---z„4000. ///4 ZO Z c� Signature of Leg lly horized Person (not a vendor or consultant) Date Michael Cugnetti Director of EHS&R Name(print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 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 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303)692.3148 Denver, CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 6 e :M,"NO . Hello