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Home My WebLink About20200676.tiffCOLORADO Department of Public Health b Environment Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 February 10, 2020 Dear Sir or Madam: RECEIVED FEB 18 2020 WELD COUNTY COMMISSIONERS On February 11, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Verdad Resources LLC - Peggy 2501 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 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Publ: c Rev;et,J CC: PL(TP), HL0A), P4,3(SK/BR/cH/cW), 3/02/20 01.9 2M-1/20 2020-0676 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Verdad Resources LLC - Peggy 2501 Pad - Weld County Notice Period Begins: February 11, 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: Peggy 2501 Pad Exploration Et Production Well Pad SESW Sec 25, T9N, R60W Weld County The proposed project or activity is as follows: The applicant proposes to construct a new EEtP Well Pad with an annual crude oil throughput of 260,000 bbl/yr. Permitted sources will include a crude oil storage tank battery, a produced water storage tank battery, hydrocarbon liquid loadout to tank trucks, and separator gas venting. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0969 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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health @ Environment COLORADO Air Pollution Control. Division Department of Public Health & Envirownent Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0969 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Verdad Resources LLC Peggy 2501 Pad 1 23/A097 SESW SEC 25 T9N R6OW Weld County Welt Production Facility Equipment or activity subject:. to this permit: 1 Facility Equipment ID! AIRS Point Equipment Description Emissions Control Description TK01-08 001 Eight (8) 400 barrel fixed roof storage vessels used to store crude oil Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.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 II.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 Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,, ' VOC CO TK01-08' 001 - - --- 18.8 3.5 Point Note:', See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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 9 COLORADO Air Pollution Control. Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK01-08 001 Enclosed Flare 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 Equipment ID AIRS Point' Process Parameter Annual Limit TK01-08 001 Crude Oil throughput 260,000 barrels The owner or operator must monitor monthly processrates 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, Section XVII.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 XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; 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 following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; Page 3 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. 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 O&M plan are subject to Division approval prior to implementation. (RegulationNumber 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with'.. opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. 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 (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.i 19. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). 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 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 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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: DRAFT Ben Fischbach Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 6 of 9 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 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 Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 1,506 ' 75 001 Toluene 108883 `' 1,088 54 Ethylbenzene 100414 158 8 Xylenes 1330207 218 11 n -Hexane 110543 10,382 519 2,2,4- Trimethylpentane 540841 47 2 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: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 6.022 * 10-3 6.022 * 10-3 AP -42 Chapter CO 2.694 * 10-2 2.694 * 10-2 13.5 VOC 2.89 0.1446 ProMax / TANKS 71432 Benzene 5.79 * 10-3 2.90 * 10"4 4.0.9d Page 7 of 9 COLORADO Air Pollution Control. Division Department of Pubtic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 108883 Toluene 4.19 * 10"3 2.09 * 10"4 ProMax / TANKS 4.0.9d 100414 Ethylbenzene 6.08 * 10"4 3.04 * 10-5 1330207 Xylene 8.39 * 10-4 4.20 * 10"5 110543 n -Hexane 3.99 * 10-2 2.00 * 10-3 540841 2'2'4-1.80 Trimethylpentane * 10-4 9.02 * 10"6 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 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 805p(2)(A) when applicable. 8) This facility is classified as follows:, call the Division at (303)-692-3150. Applicable Requirement Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC MALT HH`... Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY Page 8 of 9 COLORADO Mr Pollution Control. Division Department of Public Health &Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 COLORADO? 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: 19WE0970 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Verdad Resources LLC Peggy 2501 Pad 123/A097 SESW SEC 25 T9N R60W Weld County Well Production Facility Equipment or activity subject to this permit: 1 Facility Equipment ID AIRS Point Equipment Description Emissions Control Description PW01-02 002 Two, (2) 400 barrel fixed roof storage vessels used to store produced ' water Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission ' and the Colorado Air Pollution ' Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 8 COLORADO Air Pollution Control Division Department of Pubic Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 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 Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO PW01-02 002 --- --- 1.2 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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 &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 Equipment ID AIRS Point Control Device Pollutants Controlled PW01-02 002 Enclosed Flare 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 Equipment ID AIRS Point Process Parameter Annual Limit PW01-02 002 Produced Water throughput 180,000 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, Section XVII.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 XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; 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 following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health &-Environment Dedicated to protecting and improving the health and environment of the people of Colorado • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O8M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit.' Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation. Number 3, p art B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with, opacity standards, using EPA Reference Method 22, 40 C.F.R., Part 60, Appendix A, .to determine the presence or absence iof visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one ` minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in Page 4 of 8 COLORADO Air Pollution Control. Division Department of Pubkrc Health & :£nvirorsment Dedicated to protecting and improving the health and environment of the people of Colorado 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 /henever a permit limitation must be modified; or No Later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4) 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 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 COLORADO Air Pollution Control Division Department of Pubkc Health &environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 25-7-1.14.7(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 theregulations 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: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 6 of 8 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 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-reps 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 Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr), 002 Benzene 71432 1,260 63 n -Hexane 110543 3,960 198 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: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.66 * 10"3 3.66 * 10"3 AP -42 Chapter 13.5 CO 1.67* 10-2 1.67 * 10-2 VOC 0.262 0.0131 CDPHE 71432 Benzene 0.007 3.50* 10-4 110543 n -Hexane 0.022 1.10 *10-3 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 COLORADO Air Pollution Control Division Department of Public Heatth &Environment Dedicated to protecting and improving the health 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC MACT HH Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr. ov/ 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 COLORADO Air Pollution Control. Division Department of Public Heath br Ettvtronment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0971 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: Verdad Resources LLC Peggy 2501 Pad 123/A097 SESW SEC 25 T9N R60W etd County Equipment or activity°subjec' ell Production Facility to this permit: 1 Equipment ID AIRS Point e Equipment Description ,, Emissions Control Description TL01 003 ` Truck loadout of crude oil by submerged fill using vapor balance system Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health £t Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III II.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. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TL01 003 -- 0.7 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled TL01 003 Enclosed Flare VOC and HAP Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health &Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Equipment ID AIRS Point Process Parameter Annual Limit TL01 003 Crude Oil Loaded 260,000 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. 9. Condensate loading to truck tanks must be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 13. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. 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 loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Heatth Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 14. For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. Include devices to prevent the release of vapor from vapor recovery hoses not in use. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtH) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. 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: Page 4 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,t) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). 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. Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health &Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 allsources 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: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 6 of 8 1� COLORADO Air Pollution Control. Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr)I 003 Benzene 71432 47 2 n -Hexane 110543 416 21 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/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: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.39 * 10"4 1.39 * 10-4 AP -42 Chapter 13.5 CO 6.34 10 6.34 10" VOC 0.104 5.20 *10-3 CDPHE Benzene 71432 1.80 * 10-4 9.00 * 10-6 n -Hexane 110543 1.60 * 10-3 8.00 * 10-5 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 COLORADO Air Pollution Control Division Department of Pubhc Health & Environment Dedicated to protecting and improving the health 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: 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 MALT' 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0972 Issuance: 1 Verdad Resources LLC Facility Name: Plant AIRS ID: Physical Location: County: Description: Peggy 2501 Pad 123/A097 SESW Section 25 T9N R60W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description' Emissions Control. Description HT-VENT01 004 Heater Treater Venting during VRU downtime Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act,(C.R.S. 25-7-101 et seq), to 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section 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 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 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 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 Point Tons per Year Emission Type PM2.5 NOX VOC CO HT-VENT01 004 --- --- 1.2 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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. 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.) Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Wealth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Equipment ID AIRS Point Control Device Pollutants Controlled HT-VENT01 004 Emissions from the Separator are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime 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.) .A.4. ) Process Limits Equipment ID AIRS oin Point Process Parameter Annual Limit HT-VENTO1 004 Crude oil throughput during Vapor Recovery Unit (VRU) downtime 10,400 bbl/yr 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 08M 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 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.) I. E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 3 of 10 COLORADO Air Pollution Control Division Department of Pub€€c Health 5 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 14. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.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 XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; 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 following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). 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 date of first production 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. OPERATING Ft MAINTENANCE REQUIREMENTS 16. 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 O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health S Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, 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 • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). Page 5 of 10 COLORADO Air Pollution Control Division Department of Pub3ic Health & 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 10 COLORADO Air Pollution Control Division Department at Public Heaitn &Environment 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: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Page 7 of 10 COLORADO Air Pollution Control Division Department of Pubtc 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-reps 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 ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) HT-VENT01 004 Benzene 71432 129 6 Toluene 108883 111 6 Ethylbenzene 100414 19 1 Xylenes 1330207 28 1 n -Hexane 110543 839 42 2,2,4- Trimethylpentane 540841 4 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab e 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 & 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: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source NOx 0.0093 0.0093 AP -42 Chapter 13.5 CO 0.0425 0.0425 VOC 4.74 0.2370 PraMaX; 71432 Benzene 1.24 * 10-2 6.22 * 10-4 108883 Toluene 1.06 * 10-2 5.32 * 10"4 100414 Ethylbenzene 1.81 * 10"3 9.07 * 10-5 1330207 Xylene 2.65 * 10"3 1.32 * 10-4 110543 n -Hexane 8.06* 10-2 4.03 * 10'3 540841 2,2,4- Trimethylpentane 4.20 * 10-4 2.10 * 10"3 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on a modeled separator at a temperature of 120 °F and a pressure of 30 psig. 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU Page 9 of 10 COLORADO Air Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Corado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fischbach Package#: 420245 Received Date: 10»/'2014 =,1 Review Start Date: 11/6/2020 Section 01-Facility Information Company Name: 'f dad Resources LLC Quadrant Section Township Range County AIRS ID: 173 - SESW I 25 { 9N:- - -c0 PlantAIRSID: 5597 Facility Name: J ggy 2501 Pad< --- _ - Physical Address/Location: SESiw.lr;adr.rct of Section 25,Tewnsship 9Dd,Range SOW County: Weld County Type of Facility: €'tppacatlon,&PraductinnWetFart a.i What industry segment?Yk6&Natural Qas pmduction&Processing Is this facility located in a NAAQS non attainment area?If yes,for what pollutant? Section 02--Emissions Units In Permit Application Leave Blank-For Division Use Only Permit AIRS Point ir r1 Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source T ype Equipment Name Control? APCD has already k Required? Action Remarks has already assigned) assigned) points 502-1104 ' have keen - - _ 'Permit[yltiat hidden in thfs,i' 3111 • Crude Oil Tank.'. -TIS01-08 19WE0969 - 1 Yes- Issuance -PA , se K1PA1;2013\18 WE0070 CP1.xls Perrxfit%flitiat rrrfor 002 002 ProducedWat=_r Tank PW5102 .`}'ias' .. "15Nr0070 - 1 'less Issueriae-,=analysis K:\PA\2019\13- - VVE097LCP1.als Recmitlttitial m for 003 O03 ' ktgUad^"wading. - 1101 Yes. 194VIE0571- 1 Inc tacuance analysi See WE0972.CP1,xls _ at"Portr 1O'Ct011:�.m fur 004 004 5eperaturverticg ^HT-VFNl-01 Yes:. - =19VdF0972- - 1 Yes d<sserrce_>analysis - Section 03-Description of Project NOTE:Per Lot/long P�nrded on APEN,this facilityJII,,falls north,f the NAA ho2,.da ry.Fa,iit, 1 �₹ Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? LRegaestir g4yecthtrc talinor Pernet _.. ._. --... - Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? o 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? „ye If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) - -J Title V Operating Permits(OP) J Non-Attainment New Source Review(NANSR) Is this stationary source a major source? Re If yes,indicate programs and which pollutants: S02 NOxx CO VOC PM2.5 PIV110 TSP HAPs Prevention of e Deterioration(PSD) 3 p © C ❑ Title V Operating Permits(OP) ILJF L Nan-Attainment New Source Review(NANSR) Crude Oil Storage Tank(s)Emissions Inventory Section 01-Administrative Information Facility AIRS ID: as,,,uz y„ ,mt's 1, ... `,7�,' 9�'�.NS fga ,.. County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit E'igfut 18�4fR3Ghi Ctgdeh9dilorag�e Tantts , �� £ `3 ��Description: F Li : .r1 % LJhUy. I�" Emission Control Device ;Efc ' �4T ��"fir ',,,,04i,,,*. o.t, DescriPtion: fr78� fir y yy _ _ TA'k Z E . 3 Requested Overall VOC&HAP Control Efficiency%: 9S`{f Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= :.'5',5',..,0„.41W01 Barrels(661)per year Requested Permit Umit Throughput= �' ( )per year Requested Monthly Throughput= 22082,2 Barrels(bbl)per month ,,,,,,,m,400,00,01 Barrels h61 3 Potential to Emit(PTE)Throughput= , --'„� t4 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste "�'�gas= f li BtU/Scf Heat(:nF£teYlA of Waste Gas calculated as weighted a£1L'ragC of Flash and WW1 waste gas stream f£ea4 CtlS£t£:r575. Volume of waste gas emitted per BBL of liquids 0 n produced= �, scf/6hl From Pramax outputs(combination of G'J&B and Flash Gas volumes) Actual heat content of waste gas routed to combustion device= 17,304.1 MMBTU per year Requested heat content of waste gas routed to cornkustibn device= 22,495,4 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 22,495.4 MMBTU per year Control Device Pilot Fuel Use Rate: r.',".90'.„40 Y,scfh Si, MMscf/yr v+�D; Pilot Fuel Gas Heating Value: ,, Y;4021 Btu/s6 - 388.4 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? reoic- l emmemmimatcasirimm Uncontroled Controlled Emission Factor Source Pollutant (Ib/hbi) (lb/bbl) (Crude Oil (Crude Oil Throughpet) Throughput) ®' 'z89,'i MEESE 1', 5 9 E:, a yT //j 979Etf =gm= t' e �, ,,;t'--;O 4.191~-OO5 L 209E-04 ''4e ry EMEEMMM 600E-,0 H 11th+5 ?f yc)B eh ti -rte '- 8.3914OO 9Ste SPegiii: (31 ` _ 3.99E02' - 2.00E-03 OtteSpecificEF(p fl aJ 7 1,8OE04..., 9.1121 06 61SpaelfttU: ,r Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtn) (16/1361) Emission Factor Source (Waste Heat (Crude Oil Combusted) Throughput) ®' 0.0008 0.0000 IMMIZEINEEMEIN 0.0059 MEIMIEMEM 0.3200. D,0268 ..:..x a f � _ _. S :K Pilot Light Emissions - Uncontrolled Uncontrolled - , Pollutant (Ib/MMBttr) (Ib/MMscf) Emission Factor Source(Waste Heat (Pilot Gas Combusted) Throughput) ®' 0.0000NMIREMEMEMPFSPOW41:, IMEZIENIM`, 7/38T/'0,. 0.0000 0111101400116840Ainegalit �' 0 68241. .�' 115.458$ .4 ffi,, Section OS-Emissions Inventory . Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled- Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 376.1 289.3 14,5 376.1 18.8 3193.8 PM10 O,0 O,0 0.0 0,0 0.0 0.0 Combustion Product Combined Emission PM2.5 0.0 0.0 0.0 0.0 0.0 0.0 Factors NOx 0.8 0,6 0.6 0.8 0.0 133,0 NOx 5.02.2E-03 Ib/hhl CO 3.5 2.7 2.7 3.5 3.5 59425 - CO 2.694E-02 lb/bbl 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 1506 1119 58 1106 75 Toluene 1088 837 42 1088 54 Ethylbenzene 118 122- 6 158 0 Xylene 218 168 8 218 11 . n-Hexane 10352 7986 399 10382 519 224 TMP 47 36 2 47 2 2 of 7 K:\PA\2019\19WE0969.CP1 Crude Cpl Storage Tank(s)Emissions Inventory Section 06-Regulatory Summary Anasisis Regulation 3,Parts A;B Source requires a permit Regulation 7,Section XVII.0,Cl,. C.3 Storage tank is sob)eotto Regulation 7,Section X411,R.Cl&C.3 Regulation 7,Section XVII.C.2' Storage Wok is subject to Regulation 7,Section X011,02 Regulations,Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS K6 - Regulation 6,Part A,NSPS Subpart 0000 Storage tank is not subject to NSPS OO01), NSPS Subpart OOOOa Storage Took is not subject to NSPS 0000n Regulation 8,Part E,MACT Subpart HH Storage Tank is not subject to MACT HtI (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements • Does the company use the state default emissions factors to estimate emissions? �„ ; If yes, re the uncontrolled actual or requested emissions estimated to be greater that or equal to 20 tons VOC per year? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific enffisions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? is If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 9554 for a flare or combustion device? n,K ',yes,the permit will contain and initial compliance test condition to demonstrate the destruction.efflciency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes Flash emission factors estimated via Promax modeling, WAS emission factors estimated via Promax'Sunk Losses'stencif. W&B emission factors verdied via TANKS 4.0.94 For TANKS 40.9d model I used the"input summary"sheet included with application package to specify model pammetersiso onginal a see cation package documenkenfrtled"Tank Working and Breathmg.Ldsson for parameters used) A a entitled measure,I modeled based on an excessively high RVP liquid,and found that operator estimated W&B emissions are higher than estimated by my TANKS 4.0.94 model seeing that operator results are more conservative,wilt acceptand use m permitting, ' r' ^ f4�e X: �d_ 1 Section 09-Inventory 5CC Ceding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# SCC Cod Pollutant Factor Control% Units 001 01 y� t„ d �� _„ ,,,,�, y„ � t:# ,4'153s� �„s r° PM10 060 fl Ib/1,OW.gallans crud oil throughput PM2.5 0.00 U 16/1,000 gallons crude oil throughput NOx 4 1 (1 oil throughput VOC 60.0.29 950 Ib/Ib/1,00000 gagallllonsons crude oil throughput CO 0.64 0 Ib/1,000 gallons crude oil throughput Benzene 0.14 9b Ib/1,000 gallons crude oil throughput Toluene 11,30 95 Ib/1,000 gallons crude oil throughput Ethylbenzene 0,01 45 16/1,000 gallons crude ail throughput Xylene 0. 95 I , oscreoilthroughpnt n-Hexane 11,9502 95 Ib/1000b/1000gall gallons code.ud oil throughput 224 TMP 0.00 96 Ib/1,000 gallons crude oil throughput r 3 of 7 - K:\PA\2019\19WE0969.CP1 Crude Oil Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Calorads Regulation 3 Parts A and B-APEN and Permit Requirements 'Source is in the Attainment Area ATTAINMENT L Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2TPV(Regulation 3,Part A,Section tota)? Source Requires an AP 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14(See PS Memo 14-03 for additional guidance on grandfather applicability)? Go to subquestion 2a.If answer to 62ls yes,Is the crude oil storage tank rapacity less than 40,000 gallonsperyear? rvs �rs� Gott next question 3. Are taal facility uncomralled VOC emissions greater than 5TPY,5O0 greater than 1OTPY or CO emissions greater than 10TPY(Regulation 3,Part B,Sectlan 11.0.31? E `alY%d Source Requires a parr 'Source requires a Resnik NON-A AINMENT L Are uncontrolled emLssions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section ll.0.1.al7 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14(See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a.If answer tort?Is yes,Is the crude oil storage tank rapacity less than 40,000 gallons per year? - 3. Are total facility uncontrolled VOC emissions from the greater than 2 TRY,NOx greater than 5TPY car CO emissions greater than uo TM'(Regulation 3,Part IS,Section 11.0.21? 'You have indlcated that source Is In Ina Attalnnsgnt Araa Colorado Regulation 7,Saab.XVII • 1 Is this tank located at a transmission/storage facility? Na Continue-You have In 2. Is this crude oil storage tank'located at an oil and gas exploration and production operation,well production fadlitya,natural gas compressor station'or natural gas processing plant? Yes Continue-You have In 3. Is this crude oil storage tank a fixed roof storage tank? ,y \t:'i Go to the next quassia 4 Are uncontrolled actual emission of this storage tank equal to or greater than 6 tons per year VOC? 'source is subject to pa 'Storage tank inaobject to Regulation 7,Sn0R5n lull,B, Section XVIER—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII:C.1-Emissions Control and Monitoring Provisions Section XVII-e3-Remrdkeeping Requirements • 5. Does the crude oil storage tank contain only"stabilized"liquids?One,rite foltowlne additional provisions apply. - • 5 _ Source is subject to all 'Storage tank is subject to Regulation 7,Section XVil,C.2 . Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR.Part 60,Subpart Kb,Standards of Performance for Volatile Oreank Liquid Storage%Marais 1. Is the individual storage vessel capacity greaterthan or equal to 75 cubic meters(m)[`472 BBIs]7 Storage Tank is not sul 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)7 %:E a.Does the vessel has a design capacity less than or equal to 1,589.874 m3['10,000 BBL]used for petroleum'or ondensate stored,processed,ortreated prior to custody transfer'as defined In 60.1116? 3. Was this condensate storage tank constructed,reconstructed,or modifiedlsee definitions 40 CFR,60.21 after July 23,1984? 4. Does the tank meet the definition of"storage vessel'in 60.111b7 5. Does the storage vessel stem a'voletde organic liquid(VOL)'s as defined in 60.111b7 6. Does the storage vessel meet any one of the following additional exemptions: `l " a.Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa I'29.7 psi]and without emissions to the atmosphere(60.110b(d)(2))7;or • b-The design apadty is greaterthan car equal to 151 m3[`950 BBL]and stores a liquid with a maximum true vapor pressures less than 3.5 bPa(60.11Uh(bl]?;or c The design ca parity 1s greaterthan car equal to 75 M'['472 BBL]but lass than 151 m'['95000L]and stores a liquid with a maximum true vapor pressure`less than 15.0 kPa(60.1106(6l)7 7- Does the storage tank meet either one of the following exemptions from control requirements: a.The design capadty rs greaterthan or equal to 151 m'("950 BBL]and stares a liquid with a maximum true vapor pressure greaterthan or equal to 3.5 kPa brit lessthan 5.2 kPa7;car b.The design capacity is greaterthan or equal to 75 Ma[-472 BBL]but less than 151 m'[-S50 BBL]and stores a liquid with a maximum true vapor pressure greaterthan or equal to 15.0 kPa but lessthan 27.6 kPa? _.... 'Storage Tank is not subjectto NSps k6 40 CFR.Part 60,Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution 1 is this crude oil 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? Vas Continue-you have in 2. Was this nude oil storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? (vo~/i' Storage Tanks not sal 3. Was this crude oil storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,2015? ,4' p: Go to the next questio 4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? ;IV.Store Tank is not sul 5. Oats this crude oil storage vessel 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 40CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? 'Stetage Tank is not suulect to NSP.S 00030 • ]Note:Ifastorage vessel is previously determined to be subjectto NSPS 0000/000Oa due to emissions above 6 tons per year VOC an the appikehility determination date,It should remain subjectto NS PS 0000/0000a per 60,5365(e)(2)/60.5365a(e](2]even if potential VOC emissions drop below titan per year] 40 CFR,Part 63,Subpart MAR HG,Oil and Gas Production Facilities 2. Is the storage tank located at an ail and natural gas production facility that meets either of the following criteria: Yes Continue-You have In a.A facility that processes,upgrades or stores hydrocarbon liquids'163.760(a)(2)1;OR h.A facility that processes,upgrades or stores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user'(63.760(x1(31)7 L Is the tank located at a facility that is major'for HAPs? IYs[:`,5?Storage Tank is not aril 3. Does the tank meet the definiionof"storage vessel'r in 63.7617 • 4 Dom the tank meet the definition of'storage vessel with the potential far flash emissions'per 63761? 5- Is the tank subject to control requirements under 40 CFR Part 60,Subpart Kb or subpart 0000? '...- 'Storage Tank is not subject to MAO'Hit Subpart A,General provisions per§63.764(a)Table 2 §63.766-Emissions Control Standards 563.773-Monitoring 563.774-Recordkeeping ¢63.775-Reporting PACT Review PACT review is required if Regulation 7 does not apply AND ifthe tank is In the non-attainment area.If the tank meets both criteria,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Ad,Es implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis if contains may not apply to a particular situation based upon the individual fads and circumstances.This document does not change or substdufe for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any combat between the language of this document and the language of the Clean Air Ad,Rs implementing regulations,and Air Qualty Control Commisson regulations.the language of the statute or regulation wdlcontrol. The use of non-mandatory language such as'recommend,"may," 'should,"and'can,"is intended to describe APCD interpfetatbns and recommendations.Mandatory terminology such as"must"and'required'are edended to descnbe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legaly binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT . AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Verdad Resources LLC County AIRS ID 123 History File Edit Date 2/5/2020 • Plant AIRS ID A097 Ozone Status Attainment Facility Name Peggy 2501 Pad . EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 1125 SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID - Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 _ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total Previous Permitted Facili total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 _ 0.0 001 19WE0069 Eight(8)400 bbl Crude Oil Storage Tanks 0.8 376.1 3.5 6.7 0.8 18.8 3.5 0.3 NEW 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 0.3 23.6 1.5 2.6 0.3 1.2 1.5 0.1 NEW 003 19WE0971 Crude Oil Truck Loadout 0.D 13.5 0.1 0.2 0.0 0.7 • 0.1 0.0 NEW 004 • 15WE0972 Separator Venting during VRU Downtime 0.1 24.7 0.2, 0.6 0.1 1.2 -, 0.2 0.0 NEW 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 0.1 0.1 _ 12.4 D.6 9.8 0.1 0.1 0.1 0.9 0.6 1.8 0.1 NEW/an:10CHMM405080045) 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 0.2 0.2 32.5 1.4 32.5 0.6 0.2 0.2 2.0 1.4 3.9 0.6 NEW(so:071,06205) 0.0 - 0.0 0.0 0.0 0.0 , 0.0 APEN Exempt/Insignificants 0.0 0.0 XA Separator Heaters 0.5 0.5 0.0 0.5 - 0.5 0.0 From APCD102 Form XA Heater Treater Heater 0.5 0.5 0.0 0.5 0.5 0.0 From APCD102 Form XA Fugitives 0.3 0.0 0.3 0.0 From APCD102 Form 0.0 0.0 --- -. _ 0.0 0.0 FACILITY TOTAL • 0.2 0.2 0.0 0.0 47.1 439.9 0.3 48.5 10.8 0.2 0.2 0.0 0.0 5.1 23.9 0.3 12.0 1.2 VOC: Syn Minor(PSD and OP) NOx:True Minor(PSD and OP) CO: True Minor(PSD and OP) HAPS: True Minor B,T,X,HCHO&Total HH: True Minor+affected Area 7777: True Minor Permitted Facility Total 0.2 0.2 0.0 0.0 46.1 439.9 0.0 47.5 10.8 0.2 0.2 0.0 0.0 4.1 23.9 1 0.0 11.01 1.2 Excludes units exempt from permits/APENs' (A)Change in Permitted Emissions 0.2 0.2 0.0 0.0 4.1 23.9 0.0 11.0 Pubcom&modeling(not)required based on (A change in emissions) Total VOC Facility Emissions(point and fugitive) 24.2 Facility is eligible for GP02 because a 90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive 23.9 Project emissions less than 25/50 tpy Note 1 . Note 2 • Page 5 of 7 Printed 2/7/2020. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 Facility Name Peggy 2501 Pad Emissions-uncontrolled(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpy) ',Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 1506 1088 158 218 10382 47 I 6.7 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 1260 3960 2.6 003 19WE0971 Crude Oil Truck Loadout 47 416 0.2 004 19WE0972 Separator Venting during VRU Downtime 129 111 19 28 839 4 0.6 005 GP02 GM Vortec 5.7L, 92hp,4SRB,(V-ENG01) 149 20 19 11 4 1 22 0.1 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 980 45 42 25 9 3 49 0.6 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 0.0 0.0 TOTAL(tpy) 0.6 0.0 0.0 1.5 0.6 0.1 0.1 7.8 0.0 0.0 0.0 0.0 10.8 I *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus 6 19WE0969.CP1 2/7/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 Facility Name Peggy 2501 Pad Emissions with controls(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 75 54 8 11 519 2 _ 0.3 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 63 198 0.1 003 19WE0971 Crude Oil Truck Loadout 2 21 0.0 004 19WE0972 Separator Venting during VRU Downtime 6 _ 6 1 1 42 0 0.0 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 149 20 19 11 4 1 22 0.1 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 980 45 42 25 9 3 49 0.6 0.0 0.0 APEN Exempt/lnsignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 0.0 _ 0.0 TOTAL(tpy) 0.6 0.0 0.0 0.1 0.0 0.0 0.0 0.4 0.0 0.0 0.0 0.0 1.2 7 19WE0969.CP1 2/7/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fl chhyth Package 41: ;420245 ' Received Date: 20/3/4015 Review Start Date: 1/6/2020 Section 01-Facility Information Company Name: Verdad Resources ILt Quadrant I Section I Township I Range County AIRS ID: 123 ;SEW 25 514 60 Plant AIRS ID: Facility Name: ,Peggy 2514 Pad ''b 1�z� � ` 4lik;e 3 Physical Address/Location: S3:SiN:tu,Edranl nl Section 2.5,Township 9N,Range a0W County: Weld County Type of Facility: =&toleration&^Production 55ieII Farr ., • What industry segment' ii&El tonal Gas Production.&.!recessing Is this facility located in a NAAQS non-attainment area? .J: , No'.. � If yes,for what pollutant? Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit# AIRS Point# Type Emissions (Leave blank unless -Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Equipment Name Control? APCD has already # Required? Acton Remarks has already assigned) assigned) See WE096R-CP7._xls Rerfftig7iCiak,m for 001 001 �,.Ctvdo rtil Taoh T501-08 Yes 19WED9p9 1 YeS- I'sskidi o `analysis Papeslot I ' points 001, I .. 003,004 have d L - POPfnR initial been hidden in. 002 PrtsducetWater Tani PW01-02 "'Yes - 19WED970 1 Yes lssueosce this PA See t =IS\PA\201\1H WE0971 CP1.xls 'Permitinitiai m ly 05 -. ;003 ,Liquid Loading TL01 .Yes . ISWE0971 1 :-Yes tssuarrce analysis ,See K:APA\2019\19 VVE0972.CP1.xls r. .4 -� >; -< � -Enrtms'CnSClat m for,003 004 Separator V+enting HT-VENTDI Yes 19WE0972 1 Yes Issuance analysis Section 03-Description of Project NOTE.Per Lab/long provided on OPEN,this fardIyJliST balls north of the NAA boundary.Faculty is in attainment area • Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Itoquesting5gpthetic Minor Permit., Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? pto. If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide StationarySeurce Classification Is this stationary source a true minor? "-No Is this stationary source a synthetic minor? -Yes If yes,indicate programs and which pollutants: SO2^� NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) E("�T� _ .l Title V Operating Permits(OP) LJ J o D Non-Attainment New Source Review(NANSR) Is this stationary source a major source? .No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs PreShe V pe of Significant Deterioration(P50) E _ E El E U U Title V Operating Permits(OP) Non-Attainment New Source Review(NANSR) Produced Water Storage Tank(s)Emissions Inventory Section 01-Administrative Information d Pi ' ' s• A037 002 Facility AIRS ID: =�fif 3i County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Two(2)400 bbl Produced Wac:Storage Tanks Description: Emission Control Device -` y2,�Z E60'' Description: Requested Overall VOC&HAP Control Efficiency%. 95 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Produced Water Throughput= 150,000 Barrels(hbl)per year Requested Permit Limit Throughput= 130,000 Barrels(bbl)per year Requested Monthly Throughput= 15285 Barrels(bbl)per month I Potential to Emit(PTE)Produced Water Throughput z = s' „i r S$0rt,0s1@ Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= l a%14006.,Btu/scf Volume of waste gas emitted.per BBL of liquids " produced= ,,,,`i�2.,6,(Y'..scf/hbl Actual heat content of waste gas routed to combustion device= 8078.4 MMBTU per year Requested heat content of waste gas routed to combustion device= 9634.1 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 06943 MMBTU per year Control Device Pilot Fuel Use Rate: m 0.0 MMscf/yr Pilot Fuel Gas Heating Value: ':Btu/sr--f 0,0 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? yeses ; . Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) VOC 02fi2O: 1.31E-02 B4 Benzene ``. 00040- 3.50E-04 Toluene `, 3 ...W 9.0000 Y xY,- Ethylbenz ne 0.0000 y d er ,�,y.,„' Xylene t yano 0.0000 ;; �', n-Hexane iS 0220,am 1.14E-03 Produced Water5ta1eE.F(tnc)adesflaslf1 224 IMP /.,_,,It-- .seem 0.0000 1 ii„ - ll'lll . Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 ,, t t- 0.00000 'IT, ! / /t� PM2.5 *--A "$ 0.00000 ,- , NOx 04680tl Rift 3,66E-03 fP-42.ChayOer l„5 deedusgrfok Fiax/s{0 CO '52,310642 1.'-i 1.67E-02 [5,4423bwptor13trfydootr F7argn{ „ Pilot Light Emissions Uncontrolled Uncontrolled Pollutant 116/MMBtu) lh/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 '" `l, 0.0000 „f , PML5 s d.0 4 0.0000 a NOx t4'/1t4' 2c,'v 0,UODQ CO vl: . -,,,! V.500-I � rY. ._ Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 23.6 19.7 1.0 23,W 1.2 200.3 PM10 0.0 0.0 0.0 0.0 0.0 - 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 0.0 NOx 0.3 0.3 0.3 0.3 0.3 56,0 CO 1.5 1,3 1.3 1.5 13 255.2 — Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene 1260.0 1050.0 52.5 1260.0: 63.0 Toluene 0.0 .9.0 0.0 0.0 0.0 Ethylbenzene 0.0 0.0 0.0 0,0 0.0 Xylene 0.0 0.0 0.0 0,0 0.0 n-Hexane 3060.0 3'300.0 165.0 3960.11 198.0 224TMP 0.0 0.0 0.0 0.0 0.0 2 of7 K:\PA\2019\19WE0970.CP1 • • Produced Water Storage Tank(s)Emissions Inventory • Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Not enough information Regulation 7,Section XVII.B,C.1,C.3 Storage tank is subject to Regulation 7,Section XVII,8,C.1&C-3 Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation 7,Section XVII.C.2 Regulation 6,Part A,'NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6,Part A,NIPS Subpart 0000 Storage Tank is not subject to NIPS 0000, NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a (See regulator applioahility worksheet far detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions,are the emissions factors based an a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis?This sample should be considered representative which generally 411;:flajj4japjaiiffifig 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-linej,then it trey be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compiance"testing requirement to develop a site specific emissions factor.See PS Memo 14-03,questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? a, If yes,the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical A I sis Notes "''q"s' g rs and calculations te 9W ty77 s ��,QpelakgP;s-u I state default it f ct sfarthrd:Plnretrre r d _ I a • rx � "'�vo r'y, ��M �� - f _ „� i. ss •iyc widiret'•�• v r� �: Hi y ti a*1'-� ,,$r �`X1 a cif q�R "tka ,0 ,„ «,�-- sia y o Io ray yf / _: .;;.,..s, f �..ij�'r - .. �' .ms's" ,.��•s.,,;W;, �....�:-.,...y..... ....... .....-E � T - .. Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control%Units 002 01 - 4-04-003-15 Faed Roof Tank,Produced Water,working+breathing+flashing lasses PM10 0.0000 0.0 lb/1,000 gallons liquid throughput PM2.5 0.00oo 0.0 lb/1,000 gallons liquid throughput NOx 0.0872 0.0 lb/1,000 gallons liquid throughput VOC 9.2391 95.0 lb/1,000 gallons liquid throughput CO 0.3979 0.0 lb/1,000 gallons liquid throughput Benzene 0.1999 95.0 lb/1,000 gallons liquid throughput Toluene 0,0000 95.0 lb/1,000 gallons liquid throughput Ethylbenzene 0.0000 95.0 lb/1,000 gallons liquid throughput Xylene ' 0.0000 95.0 lb/1,000 gallons liquid throughput n-Hexane 0.5239 95.0 lb/1,000 gallons liquid throughput 224 TMP 0.0000 95.0 lb/1,000 gallons liquid throughput • 3 of 7 K:PA 2019 19WE0970.CP1 • Produced Water Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and e-APEN and Permit Requirements [Source is in thc'Attainmost.area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY(Regulation 3,Part A,Section lI.D.l.z)3 tlw source Require an AP 2. Is the operator claiming less than 1°b crude oil and Is the tank located at a non-commercial facility for processing oil and gas wastewater?(Regulation 3,Part B,Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5TPy,NO2 greater than 10TPY or C0omissions greater than 10TPY(Regulation 3,Part B,Sectionll.D.3)? 'Vie Source Requires apes riot ausagb information NON-ATTAINMENT 1. Are uncontrolled emissions f/ram anycnterla pollutants from this individual source greater than 1TPY(Regulation 3,Part A,5ectlon 2. Is the operator claiming less than 114 crude oil and Is the tank located at a non-commercial facility for processing ail and gas wastewater?(Regulation 3,Part B,Section 3. Are total facility uncontrolled VOC emissions greaterthan 2TPY,NOx greater than 5TPY or CO emissions greaterthan 10TPY(Regulation 3,Part B,Section 11,0.21? IYou have indicated that source ie In the Attainment Area Colorado Regulation 7.Section)wII 1. Is this tank located at a transmission/storage facility? No Continue-You have in 2. Is this produced water storage tanks located at an oil and gas exploration and production operatnn,well production facility',natural gas compressor stations or natural gas processing plant? Yes Continue-You have In 3. Is the produced water stooge tank a flied roof storage tank? Y0 '- `Go to the nextquesto 4 Are uncontrolled actual emissions`of thls stooge tank equalto or greater than ftons per year VOC7 Source subject to pa [Storage tank is subjectte Reputation 7,Section XVR,Et,C.1 Vu C.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1-Emissions Control and Monitoring Provisions - Section XVR.c.3-Rerordkeeping Requirements 5. Does the produced water storage tank contain only"stabilized..liquids?If no,the following additional provisions apply. Nti _/,)fJ Source Is subject to all Ifs-coot tank Is oubjest to Regulation 7,.Section X011.0.2. Section XVILC.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR,Part 60,Sobpart Kb.Standards of Performance for Volatile Organic Liquid Storage Vessels i Is the individual storage vessel capacity greater than or equal to 75 cubic meters(ms)I-4728BIsj7 NG Storage Tank is not scull 2. Dees the storage vessel meet the following exemption in 60.111b(d)(417 a.Does the vessel has a design opacity lets than or equal to 1,589.874 m3[-10,000 BMA used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined In 6011167 3. Was this condensate storage tank constructed,reconstructed,or modified(see definitions 40 CFR60.2)zfterhily 73,19847 4. Does the tank meet the definition of"storage vessel"`in 50.111b? 5. Does the storage vessel store a"volatile organic liquid(VOL)ie as defined in 60.11167 6. Does the storage 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 I"24.7 psi]and without emissions to the atmosphere(60.110b(d)(2)1?;or ` b,The design capacity N greater than or equal to 151 m'['ISO BBL]and storm a liquid with a maximum true vapor `lessihan3.5kPa(60.1106(6117;or a�H, pratapre c The design opacity Is greaterthan or equal to 75 M°["472 BBL]but lots than 151 mt-950 BBL]and stores a liquid with a maximum true vapor pressure`less than 15.0 kPa(60.110b(b))? 7. Does the storage tank meet either one of the following exemptions from control requirements: a.The design capacity Is greaterthan or equal to 151 no['950 BBL]and stores a liquid with a maximum true vapor pressure greaterthan or equal to 3.5 kPa but less than 5.2 kPa?;or b.The design opacity is greaterthan or equal to73M`["472 BBL]but less than 151m'['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? Storage Tank is not aublect to NSPS Kb • 40 CFR,Part 60,Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Preuction,Transmission and Distribution 1. Is this produced water storage vessel looted 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? _ Yes Continue-You have In 2. Was this produced water storage vessel constructed,reconstructed,or modified(me definitions 400FR,60.2)between August23,2011 and September 18,2015? Nd;, /i.Storage Tank is not scull 3. Was this produced water storage vessel constructed,reconstructed,or modified)seedefinItlons 405CFR,60.2)after September 18,20157 Yis ^„Go to the next questlo 4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tam peryear7 .Nb 'Storage Tank is not scull 5. Does this produced water storage vessel meet the definition of"storage vessel"'per 60.5430/60.54B0a? 6. Is the storage vessel subject to and controlled In accordance with requirements for storage vessels Ire 40 CFR Part 60 Subpart Kb ar 40 CPR Part 53 Subpart REV IStoragc Task la not subiect to NSP5 OOOOe [Note:If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC an the appllt638y determination date,It should remain subject to NSP5 0000/0000a per RACr Review RACt review is required H Regulatlan 7 does not apply AND if the tank Is in the non-attainmet area.ifthe tank meets both criteria,then review RACr requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean At Act,Is implementing regulators,and Air Qually Control Commission regulations.This document is not a rule or regulation,and the anaysis d contains may not apply to a particular sduation based upon the individual facts and circumstances.This document does not change or subeidute for any law, regulation,or any other legally binding requirement and is not legally enforceable4n the event of any confiol between the language of this document and the language of the Clean Air Act„Is implementing regulations,and Afr Qualdy Control Commission regulations,the language of the statute or regulation will control.The use ofnon-mandatory language such as"recommeM,"may,' 'should,"and"can is intended to describe APCD interpretations and recommendations.Mandatory terminology such as'must"and'required"are intended to desedbe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Verdad Resources LLC County AIRS ID 123 I History File Edit Date 215/2020 Plant AIRS ID A097 L Ozone Status Attainment Facility Name Peggv 2501 Pad EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 . 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks _ 0.8 376.1 3.5_ 6.7 0.8 18.8 3.5 0.3 NEW 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 0.3 23.6 1.5 2.6 0.3 1.2 1.5 0.1 NEW _ 003 19WE0971 Crude Oil Truck Loadout 0.0 13.5 0.1 0:2 0.0 0.7 0.1 0.0 NEW 004 _19WE0972 Separator Venting during VRU Downtime 0.1 24.7 0.2 0.6 0.1 1.2 0.2 0.0 NEW 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 0.1 0.1 12.4 0.6 9.8 0.1 0.1 0.1 0.9 0.6 1.8 0.1 NEW(sn:10CHMM405080045) 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 0.2 0.2 32.5 1.4 32.5 0.6 0.2 0.2 _ 2.0 1.4 • 3.9 0.6 NEW fan:07Y06205) 0.0 0.0 - 0.0 0.0 0.0 . 0.0 APEN Exempt/Insionificants 0.0 0.0 _ XA Separator Heaters 0.5 - 0.5 0.0 0.5 0.5 0.0 From APCD102 Form XA Heater Treater Heater 0.5 0.5 0.0 0.5 0.5 0.0 From APCD102 Form XA Fugitives 0.3 0.0 0.3 0.0 From APCD102 Form _ 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.2 0.2 0.0 0.0 47.1 439.9 0.3 48.5 10.8 0.2 0.2 0.0 0.0 5.1 23.9 0.3 12.0 1.2 VOC: Syn Minor(PSD and OP) NOx:True Minor(PSD and OP) CO: True Minor(PSD and OP) HAPS: True Minor B,T,X,HCHO&Total HH:'True Minor+affected Area ZZZZ: True Minor Permitted Facility Total 0.2 0.2 0.0. 0.0 46.1 439.9 0.0 47.5 10.8 0.2 0.2 0.0I 0.0 4.1 23.9] 0.0 11.0 1.2 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.2 0.2 0.0 0.0 4.1 23.9 0.0 11.0 Pubcom&modeling(not)required based on (A change in emissions) Total VOC Facility Emissions(point and-fugitive) 24.2 Facility is eligible for GP02 because<90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) 23.9 Project emissions less than 25/50 tpy Note 1 Note 2 • Page5of7 Printed 2/7/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 Facility Name Peggy 2501 Pad Emissions-uncontrolled(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 1506 1088 158 218 10382 47 6.7 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 1260 3960 2.6 - 003 19WE0971 Crude Oil Truck Loadout 47 416 0.2 004 19WE0972 Separator Venting during VRU Downtime 129 111 19 28 839 4 0.6 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 149 20 19 11 4 1 22 0.1 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 980 45 42 25 9 3 49 0.6 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 0.0 0.0 TOTAL(tpy) 0.6 0.0 0.0 1.5 0.6 0.1 0.1 7.8 0.0 0.0 0.0 0.0 10.8 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus 6 19 W E0970.CP1 2/7/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 Facility Name Peggy 2501 Pad Emissions with controls(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 75 54 8 11 519 2 0.3 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 63 198 0.1 003 19WE0971 Crude Oil Truck Loadout 2 21 0.0 004 19WE0972 Separator Venting during VRU Downtime 6 6 1 1 42 0 0.0 005 GP02 GM Vortec 5.7L,92hp,4SRB, (V-ENG01) 149 20 19 11 4 1 22 0.1 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 980 45 42 25 9 3 49 0.6 0.0 0.0 0.0 APEN Exempt/lnsignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 0.0 0.0 TOTAL(tpy) 0.6 0.0 0.0 0.1 0.0 0.0 0.0 0.4 0.0 0.0 0.0 0.0 1.2 7 19WE0970.CP1 2/7/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details - For Division Use only Review Engineer: Ben Fiartinach Package tt: �3an2aa " 1 Received Date: 10/3/2019 -Review Start Date: 2/6/2020 - Section 01-Facility Information Company Name: V,d ad Rasa-antes LOS Quadrant Section Township Range County AIRS ID: 1z3 $F.dW ?5 - 90 - W Plant AIRS ID: 0097,. ' -f Facility Name: Peggy 2001 pad Physical .. Address/Location: snow n,aorant o(Sectian 2.5,Township 9N,Range 00W County: Weld County Type of Facility: apt n rat, &1?rod ct n t,Vet i,a. aFF What industry segment?Pagait4fifflas Prodo Gen=& - _ Is this facility located in a NAAQ5 non-attainment area? If yes,for what pollutant? Section 02-Emissions Units In Permit Application - - Leave Blank-Far Division Use Only AIRs Point Permit# # Emissions (Leave blank unless Issuance Self Cart Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Central? APCD has already # Required? Action Reworks has already assigned) quire assigned) � sre 'd \2019'119 y '� !!!1'51t,,!!!'„VD 1 WE9969CP'1'.xla `` g �'"' ` Permit loitl I m f r 001 U01t r'rti O* W2)''. i001 Ofi '. 446N o 19WE0969 -1 Yes :Isstaance en eivsis. �y 5 1 x If PA 2019/19_ cc �_ f ',1 / A.�� r WOO97U.(91.,lo Permit India! for 002 @;: v pvcl aGitb it,.r_r lank PW01-02 Yes 19WE0970 1 Yes- tssuance analysis- Pages for t - - : points 001. y a' 352 004 have _ - Perreit hutiat been hidden in 003 - Lipoid Loading - 1101 - To .`r 10/0 0971 !�2, yes Issvaste thrsWN' ' , - - _ IS\FA'4Z019,19= WE0972.CP1.xls Pirirmit initial m for 004 '-00 ` Seoantem Jena nG - - I-IT-VCNTOI'- -[ Yes I 9WF0972 1 Yes, Issuance analysis: — f-- 9 r Section 03-Description of project NOTE:Per fat/lung provided on AP EN,this Fs..nt2J_i Flo»,s north of t,he NAP.be irdary.=Fcitit,s it attain n=n 3,a - - - - - - - i-.= i;. ' Sections 04,05&06 For Division Use Only --� Section 04-Public Comment Requirements Is Public Comment Required? If yes,why? ...,<..J _. ..y ...,9> Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required?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? �>tido Is this stationary source a synthetic minor? Ye If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) - .F Title V Operating Permits(OP) J Eno Nan-Attainment New Source Review(NANSR) Is this stationary source a major source? ' ! ` If yes,indicate programs and which pollutants: SO2 NOx r CO VOC PM2.55'.{IM10 TSP HAPs Prevention VOperating of eant Deterioration(PSD) E ❑ P L[ E Title V Operating Permits(OP) IL..It 3₹...IF Non-Attainment New Source Review(NAN5R) Hydrocarbon Loadout Emissions inventory Section 01-Administrative Information 'Facility AIRS ID: 324 ,,,,,,;,,,,,,,,,,,,,,,,,e> ,,.. „90'�i.,,t;... County Plant Point Section 02-Equipment Description Details • • Detailed Emissions Unit a Laad Tank p,A i ' 0lout to Tr k �'?�� Description: "i .., :I - - '_='a • Y3,. ..a • Emission Control Device er 4 a ; Description: i� � �i Is this loadout controlled? Requested Overall VOC&HAP Control Efficiency%: ;#/;,94 Ol Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= - ., 'a' -0.(dtt0'Barrels(bbl)per year 'Requested Permit LimitThroughput= dL2B0.00t(1 Barrels(bbl)per year Requested Monthly Throughput= 22082 Barrels(bbl)per month Potential to Emit(PTE)Volume Loaded= y ,''s,44``4\3 0�agt4•Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= ✓ii X26@0't Btu/scf Actual Volume of waste gas emitted per year= 157664 scf/year Requested Volume of waste gas emitted per year= 204963 sd/year Actual heat content of waste gas routed to combustion device= 409 MMBTU per year Requested heat content of waste gas routed to combustion device= 932 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 532 MMBTU per year Control Device I i Pilot Fuel Use Rate: ;,scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Bto/sd 0.0 MMBTU/yr Section 04-Emissions Factors&Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? The state default emissions factors may he used to estimate emissions. Etia Hydrocarbon Loadout Uncontrolled Controlled Pollutant (Ih/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) g. 9.00E-06 a. 0.00E+00 0.00E+30 0,00E+00 MINEZEMMEIMIMMINIEMEMINIMI 0.00E+00 0.00E+00 0.00E+00 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) 0.00E+00 40, IIMIEZEIE 0.00E+30 ' . 2:12 0.00E+30 0.3100 6.34E-04 Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ih/MMEtu) (Ib/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) _ Mimr2MIN dGa3 ! 1Q� mgErnomm 2 of 7 K:\PA\2019\19W E0971.CP1 Hydrocarbon Loadout Emissions inventory Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tans/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 0,00 0.00 5110 5.05 0.00 0 PM2.5. 0.00 0.00 0.00 0.00 0.00 0 _ SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 0,02 0.01 0.01 0.01 0.02 3 _ VOC 13,52 10.20 0-51 13.52 0.68 115 CO 0,08 0.06, 0.06 0.08 0.08 14 Potential to Emit Actual Emissions 91equested Permit Limits Hazardous Air Pollutants - Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) (Ibs/year) (lbs/year) (Ibs/year) Benzene 47 36 2 47 2 Toluene Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n-Hexane 416 320 16 416 11 • 224TMP 0 0 0 0 0 Section 06-Regulatory Summan(Analysis Regulation 3,Parts A,B Source requires a permit RACE-Regulation 3,Part B,Section III.D,2.a Site is in attainment and not stcb)ect terRACT • (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes Mate default emission factors used • Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process It SCC Code Pollutant Factor Control% Units 003 01 4-06-001-32 Crude Oil:Submerged Loading Normal Service(0=0.6) PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0,00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.30 0 lb/1,000 gallons transferred VOC 2.5 95 lb/1,000 gallons transferred CO 0.02 0 lb/1,000 gallons transferred - Benzene 0,05 96 16/1,000 gallons transferred Toluene 0.08 95 lb/1,000 gallons transferred - Ethylbenzene 0,02 95 lb/1,000 gallons transferred Xylene 0,00 - 05 lb/1,000 gallons transferred n-Hexane 0.04 95 lb/1,000 gallons transferred 224 TMP 0,00 95 lb/1,000 gallons transferred • 3 of 7 K:\PA\2019\19W E0971.CP1 • Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Re•uirements [Source is in the 114,9in133Nilt Area - ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,PartA,Section ll.D.1.a)7 k'5 �..,, Go to next 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)1 Jao^''it�'I Go to then 3. Is the loadout operation loading less than 10,000 gallons(236 6BLs)of crude oil per day on annual average basis? 1501 c.,;.Go to next 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?an ;(tic;d,„Ma':Go to next 5. Is the loadout operation loading less than 16,308 bills par year of condensate via submerged fill procedure? s'?,` PAa•Go to next 6. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than SOTPY(Regulation 3,Part 6,Section 11.0.3)? y.,The loadou (Sourer requires a permit NON-ATTAINMENT • 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,PartA,Section ll.D.1.a)? /,, 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part 0,Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons(238 BBB)of crude oil per day on an annual average basis? �p 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)7 l !/dl..i (You have hrdkoted that source Is in the.Attainment Area 7. PACT-Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy(Regulation 3,Part B,Section lll.0.2.a)Y Site is in attainment and nut subject to PACT 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 pfnon-mandatory language such as'recommend,"may,"should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"muse and'required°are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements In and of itself. • COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Verdad Resources LLC County AIRS ID 123 History File Edit Date 2/5/2020 Plant AIRS ID A097 Ozone Status Attainment Facility Name Peggy 2501 Pad EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 J 0.0 0.0 New Facility-No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0960 Eight(8)400 bbl Crude Oil Storage Tanks 0.8 376.1 3.5 6.7 0.8 18.8 3.5 0.3 NEW 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 0.3 23.6 1.5 2.6 0.3 1.2 1.5 0.1 NEW 003 19WE0971 Crude Oil Truck Loadout 0.0 13.5 0.1 0.2 0.0 0.7 0.1 0.0 NEW 004 19WE0972 Separator Venting during VRU Downtime 0.1 24.7 0.2 0.6 0.1 1.2 0.2 0.0 NEW ,005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 0.1 0.1 12.4 0.6 9.8 0.1 0.1 0.1 0.9 0.6 1.8 0.1 NEW(sn:10CHMM405080045) 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 0.2 0.2 32.5 1.4 32.5 0.6 0.2 0.2 2.0 1.4 3.9 0.6 NEW(sn;07Y06205) 0.0 0.0 0.0 0.0 • 0.0 0.0 APEN Exempt/Insignificants _ • 0.0 0.0 XA Separator Heaters 0.5 0.5 0.0 0.5 0.5 0.0 From APCD102 Form XA Heater Treater Heater _ 0.5 0.5 0.0 0.5 0.5 0.0 From APCD102 Form XA Fugitives 0.3 0.0 0.3 0.0 From APCD102 Form .,,-,_.__ 0.0 0.0 0.0 _.._ ._ 0.0 �� FACILITY TOTAL "0,2 0.2 0.0 0.0 47.1 "439.9 0.3 48.5 10.8 0.2 0.2 0.0 0.0 5.1 23.9 0.3 12.0 1.2 VOC: Syn Minor(PSD and OP) NOx:True Minor(PSD and OP) CO: True Minor(PSD and OP) HAPS: True Minor B,T,X,HCHO&Total HH: True Minor+affected Area 7777: True Minor Permitted Facility Total 0.2 0.2 0.0 0.0 46.1 439.9 0.0 47.5 10.8 0.2 0.2 0.0 0.0 4.1 23.9 0.0 11.0 1.2 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.2 0.2 0.0 0.0 4.1 23.9 0.0 11.0 Pubcom&modeling(not)required based on (A change In emissions) Total VOC Facility Emissions(point and fugitive) 24.2 Facility is eligible for GP02 because<90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) 23.9 Project emissions less than 25/50 tpy Note 1 Note 2 Page 5 of 7 Printed 2/7/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 Facility Name Peggy 2501 Pad Emissions-uncontrolled(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL(tpy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 1506 1088 158 218 10382 47 6.7 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 1260 3960 2.6 003 19WE0971 Crude Oil Truck Loadout 47 416 0.2 004 19WE0972 Separator Venting during VRU Downtime 129 111 19 28 839 4 0.6 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 149 20 19 11 4 1 22 0.1 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 980 45 42 25 9 3 49 0.6 0.0 0.0 0.0 - APEN Exempt/Insignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 ' 0.0 0.0 TOTAL(tpy) 0.6 0.0 0.0 1.5 0.6 0.1 0.1 7.8 0.0 0.0 0.0 0.0 10.8 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus • 6 19WE0971.CP1 E0971.CP1 2/7/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 Facility Name Peggy 2501 Pad Emissions with controls(lbs per year) POINT PERMIT Description ' Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 75 54 8 11 519 2 0.3 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 63 198 0.1 003 19WE0971 Crude Oil Truck Loadout 2 21 0.0 . 004 19WE0972 Separator Venting during VRU Downtime 6 6 1 1 42 D 0.0 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 149 20 19 11 4 1 ' 22 0.1 006 GPD2 Caterpillar G3306TA,203hp,4SRB, (GL-ENO01) 980 46 .42 25 9 3 49 0.6 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 0.0 0.0 TOTAL(tpy) 0.6 0.0 0.0 0.1 0.0 0.0 0.0 0.4 0.0 0.0 0.0 0.0 1.2 7 19WE0971.CP1 2/7/2020 Colorado Air Perrnitting Project PRELIMINARY ANALYSIS-PROJECT SUMM_A RY Project Details For Division Use Only Review Engineer: Rem Fischbach . -- Packageg: .42nzga f ' Received Date: .10/3/2019 Review Start Date: 1/6/2520 Section 01-Facility Information Company Name: yei Owl Resunrr I Quadrant!- Section Township Range County AIRS ID: X123 - - 053W _'25 95.: 60. Plant AIRS ID: 'P497 Facility Name: Peggy?2501,Pod Physical . . _ ,.. ..�. Address/Location: SESW headnuri 4 5ectian 25,Township 9N,Range F,0W County: weld County Type of Facility qsl ratio k#:P a la !!n#ll'. Q ;;,_ What industry segment? I ,,pfiCa's.&katl4 ,,y l Is this facility located in a NAAQS non attainment area? S JA:If yes,for what pollutant? - rDIS 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 Action Control? APCD has already 4 Required? Remarks has already assigned) assignedl .� -'�'-,'6'lf,,,RWII / r� I 'hzru' See ng- k7 i -s Sri � ., ' iii:K PA\2019�,19.- a grolit,� I 2A,+� �n� - , y � � ". 0:04:„„,,„:3 tNro969 CPS.xis) y t ry •° �y�tlyaidlpr, � - f : Pe..b0 t{3SOlO In-f r0S1 ,la//r/,...6dtt:ire o _ 6 „0/,T. h(f ._Y,es 19WE5559 1JJ„tiPus .ssuance -�1,15515 P FRIOND3PIPPwlita>r - i 1 fJUili°k K\PA 2019\19 u I y g^ _ c I t,y,= u4,:::::70,::::64:::-,0 xs Q02 PWU1 tit �` S9 Ves� iq'NE0975' 1 -,Sos € Uanre naiy is '7lr y�1 R\85 20:09\1S ai �, 11'?-041115:186,,:$In t • V��e7 �e1,is a:. Vas's „:40,,,m4,0,-,,,,,,, ji 7 't ₹wti 1 m Cor OCY3 P5sA,0 t� N $'T'ir0 f„ ; ,,,,,,E0971 1 Once analysis - s}F r 3C, y m Pages for ' �� /, / I L t' i points 0tl1 00 i A �� :, �' r have nyyo �',� / ,s ., . `"�.. ,r:�:r.� v. eihnimO s NEW-MOW Form:. I hG F e-:_b. ₹is- 0©A , Ht%iWNT61 1 t/E0972" "l - 9,,,,axra.,.. rP.a n •,----- ,- -----"1 i �1 Section 03-Description of Project NOTE.Per provided on AP this north of the 5-AA boundary-Facility is in atzainmisnt area. Sections 04,05&Ofi For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? If yes,why? i/egvevtang'5iv3het,e f,rli lyeeyrnit,,. Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? wRu.8 "a , / If yes,for what pollutants? n • r s_, If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification - Isthisstationarysourceatrueminor? /.�t".+j5is5 PI Is this stationary source a synthetic minor? If yes,indicate programs and which pollutants: SO2 NOx CO^�VOC PM2.5 PM2.5 PM10 TSP HAPs Prevention oting et Deterioration(PSD) t_ ( J' D Title V Operating Permits(OP) _a .T.. fL""IT �J II lEnn Non-Attainment New Source Review(NAN5R) Is this stationary source a major source? :,." If yes,indicate programs and which pollutants: 502 NO^ CO VOC PM2.5 PM10 TSP HAPs Title V pe t Significant Deterioration(P50) E — Fi' ( B E ❑ U Title V Operating Permits(OP) Non-Attainment New Source Review(NANSR) Separator Venting Emissions Inventory Section.01-Administrative Information Facility Al Rs ID: 123-. A097 004 County Plant Point Section 02-Equipment Description Details €Deatertreater venue d g [Vf(FrgStRil4atsrpressar dawritima Parrnittnt[sh=sea on an assumed VRU dgwntEtne of 4.6 annvaBy Detailed Emissions Unit Description: .m ,,,,,,1,; ,• ••,•„ „w, . ,,1,_, - Emission Control Device Description: •-w' ,, ''. '- a i.j Requested Overall VOC&HAP Control Efficiency%. TJi Limited Process Parameter t�un#ThFnssghp .A,, ;£� �ti Section 03-Processing Rate Information far Emissions Estimates Primary Emissions-Separator Actual Throughput= W,:BLf00€o',,Barrels(hhl)per year Requested Permit Limit Throughput ,,�-.:10,400aii Barrels(bbl)per year Requested Monthly Throughput= 883.3 Barrels(bbl)per month - Potential to Emit(PTE)Throughput= 1£@400.0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 2342-2'.Btu/sd Volume of waste gas emitted per BBL of liquids throughput: 58 6''.scf/bbl Control Device. Pilot Fuel Use Rate: sdh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/sd Section 04-Emissions Factors&Methodologies Description Th Hgatrr Treaters arc looted downstream or two inlet(3 phase Heated)separators where the liquids undergo a three phase separation prier ta`thes'tetwa,'22rt[tala 8@ors k pt+dsdgrfled tlqutdsxmple wes taken- 'frotnr a3-phose Heated 5eli2rator outlet ae 106F and 76.7 prig(sampled wl 9/1S/20919'analyzed on.J20/2019 by Alliance source 7esnng)and MOdeied,e4 of g ProntaxC'S°' Eaey))ha.(featerTred[e;[a esthnptaflash lonuep o" fY Z fluR�.�n ontR yp'f.) c Mposition(mass fractions)and Molecular f the mixture r based on the PrddnaY n ea tltl ad rEeated Sep G 5 The GDR,is�, $ [�le rd[fa:Uf 3rf#14d5tC,d5:In ttF455[LE918tl Aedted 5ap�Gas t4 IIhE af3'.. � hr '£ lia}3ldxta nsgrhpei mtl3askream"ad"(16'8rge+id..ales o38 strea d+h+nstream•af�e-m ensate`rapks� � dr. I _ MW € .,r41'rIlh/Ih-mol Displacement Equation _ Ex=Q'MW.Xx/C Weight% Helium CO2 N2 methane 6.5. ethane 16 4 propane 37.9'. isobutane 5.7 n-butane :14.$: Isopentane -;4i n-pentane cyclopentane 0.4 n-Hexane 1.3 cyclohexane 114 Other hexanes 2.7 hoptones 1.1' methylcyclohexane 03 224-TMP Benzene _fl2 _ Toluene Ethylbenzene ,•;., 4.4:C1 Xylenes CB+Heavies a iF �' „n Q=E Total 100.0 VOCWt% 74.0 2 of 8 K:\PA\2019\19WE0972.CP1 Separator Venting Emissions Inventory Separator Venting Uncontrolled Controlled -� (lb/bbl) (lb/bbl) Emission Factor Source Pollutant (Liquid Throughput) (Liquid Throughput) i t S y � ProMuk a ffi€i ' S �` t 6< Zl),.' ZETEIEMINIM 2,05E-02 t- E/ r 'A Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/bbl Emission FactorSource (Waste Heat Combusted) (Gas Throughput) 0.0000 0.0000 0.0000 1,0080 0.3100 t t a *fl-> Pilot Light Emissions Uncontrolled Uncontrolled Pollutant )lb/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) IIIMEMION. _ 0.0000 0.0000 0.4040 . 0.00000 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) PM10 0.0 0.0 0.0 0.0 0.0 0 • PM2.5 0.0 0.0 0.0 0.0 0.0 0 SOx 0.0 0.0 0,0 - 0.0 0.0 0 NOx 3.3 0.007 0.037 0.048 0.040 8 VOC 24.5 18.96 0.95 24.55 1.2.3 209 CO 0.0 0.17 0,17 0.22 0.22 38 " Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) Ohs/year) (lbs/year) (Ihs/year) (lbs/year) Benzene 3.29 99 5 .L29 6 Toluene 11.1 85 4 111. 6 Ethylbenzene 19 15 1 15 1 Xylene 28 21 1 28 1 n-Hexane 839 645 32 53:9 42 224TMP 4 3 0 4 0 Section 06-Res ulatory Summary Analysis . Regulation 3,Parts A,8 Source requires a permit Regulation 7,Section XVII.B,G Source is subject-to Regulation 7.Section XVII,8.2,G Regulation 7,Section XVII.B.2.e The control device for this separator is not sub)act to Regulation 7,Section XV€L8,2.e (See regulatory applicability worksheet for detailed analysis) 3 of 8 K:\PA\2019\19WE0972.CP1 Separator Venting Emissions Inventory Section 07-Initial and Periodic Sampling and Testing Requirements x�".i/ram,f's�xr*:�. ,x��,�g,iiz<.fs'fl�- ;„r4x'r - r�✓/, ar/r,.;. ,.,. z" Par.. ...• . :.:.. .r'.' !r• �t,. ARP , ,F - 4%ia ;.;R y �: ,,,. a r -,�:,%,• ,.x a".r :•.'st:' .�,. 3. ,ze3r.,- J l,`Ct::; .^-,- .r:,:• .s 3'$ F'' ,tt? ql a <4Lt:°T'4 - .ga ��r a w�dj O1 . "s i%'4e p ag s,�rr.�,�'.%"' �:,.,, y"#9.: ,-/,,,,.i/q.«:".soli.,' z,�i,Prz;,;/�%%r"a'..13g ,o.,��,.� �`r.� ,. , , .:.05,, aim,.: `�,.,�,}3.,:. �r,'/a mil" "��" ,w� ;ra`:_<' ,„;' ,....;.y.•, ,,f///,_x/... •,.,,;.,.: : 3iu air - ..₹. _ ?' - ., /,:;." r 3: !r/". �„ .� aY. �,f,.`'= /x''41..,J'•a•. „/. :a .,'�i.,`,�s�.:>"< .:� rt.�%� at�''x'ri'�',,, ey .GN -.�a �. ;�"� •�:: ,.14-�•.,.. ,: } ,_ 1O4 ,a. Uj5%- :{�t1":<.,.,E:.r.� <..<. s.3.� u�i _ l�z�ia;?� : ..a e¢ ogy ��:.. :.,. ,,,r; `�x. • ;fir -,. ��' a� 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? This sample should have been collected within one year of the application received date.However,lithe facility has not been modified(e.g., no new wells brought on-line),then it may be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to collect a site-specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes ,,, „ ,.,,q ,� ,F g ph ep, ., P r<, a Tkese;);e'ata,Y.TYPaters are€ocafed"downstreamoftwolnlgf3,� a�:.,ei3fe'd sse aratorswheret e�{i uFdender oathree:,�asas a„'ta£fa�'tior#o dtese:Cwo;;Ver{tcaAFl�,aYnCTYeaters-A.'pre�ur4zed,lqu{d"'s"'p1Cat�tas.fa ptr{tom a3-phase;;. , p...g,is,n7p i Y :-�p�ate,d; parato;Koutiet at"106F and 7&7, sl' a, Ye,.an-5/Zs`/�U9,tB;ahal zed on 912R124S9'h�}�I�rap�g?Souree Testing�:aefdme?d�fed,ustttg Rromax 9,0;tbrzrugh,the-Hea#er.Trea#aitaes[ittta;:lad,"'passes.?h'ezcpritpasltion jrpassf#actigpS};':?'� -and'fvtoleeular weight of the mixture arekp-Gsedpy{;t(1zP.eomas'stream tsitecE"HeatedSep Gas:;<,,7hl„CnoRis based ort the,2Fl₹,o�-scfafwaste gasin<₹he•stream,'Heated:Sep-Pxas,'"tn.b�S�;gfil,Uidtf;Fa �`s�'"Y;enfi,Ele'siream;"Oit!!,jtke�fi�uir(z- les oit'I `<`st-ream;downstream afthe;'cFndphsat�a`anks:<, ... - o- fir •a`s ' ,.,c,.,.;,, n n ual permit limits:.��'e"� -�'4 "m t U which controls e - s.f t e a a(r s n,� wnta e he VR ant is mis a 0 asin r m h se se aratq 'i'`rt"` 'o ..,e:�: ...,fl"-G., p tr,�lsriii:''ii₹cc�ide„pl(1(1i44U bkrll4r}r prevents 4%oftti5'ailgt₹'ode ail'titi'oughput thro, ,₹�-�---��i{i$y�'tStxtsratar,veil required to track,'atln4a,(n,Vg��4,#)Siuntime and throughput reeordsto determine compliance with parrztiTl ,jls,;-,,,,;;;,�'ra`-. - '��-;'-- ,';�,a�;:,�"""" = `5 �°'yii�'i:% .'r;; .,y i .,�\:.;f.;IN ,,, 5 Z -:- Section 09-Inventory SCC Coding and Emissions Factors AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 004 01 3-10-001-29 Oil&Gas Production:Gas/liquid separation PM10 0.0 0 lb/1000bb€ SCC coding withpilot PM2.5 0.0 0 lb/1000bbl emissions in lbs divic 5Ox 0.0 0 I€si1L'00€+b€ NOx 9.3 1l €b/1000lnh1 VOC 4146.1 95 lb/1.001}bbl CO 42,5 0 ib/10f0bbl Benzene 12.4 90 ib(1000bbi Toluene 10,0 05 " Ib/1000bbl Ethylbenzene 1.8 90 lb/1000hbl Xylene 2.6 95 ib/S000bb€ n-Hexane 00,0 05 lb/1000bhl 224 IMP 0.4 9s lls/t"000lsbl 0 4 of 8 K:\PA\2019\19WE0972.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 Penni�ulrements Sour A is in tho AttaiDetent Are0 ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Partd,Section'late)?1.a)? {e"a' 'Source Re 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPV or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)? hi","", Source Re ' 'Source requites a penntt • NON-ATTAINMENT �/�/�/�/�/�,�//�/� 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Pert A,Section II.D,1.a)? • 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOY greater than 5 TM(or CO emissions greater than 10 TPY(Regulation 3,Part 8,5ecii0511.0.2)7 • IYau have iadicared thus source is in the.Attaioutentdree Colorado Regulation 7,Section XVII 1. Was Me well newly constructed hydraulically fractured,orrecampleted on or after August 1,2014? Vh source iss ISe rvo is oubiact 40 Regulation 7,Socstan X511.0.2, Section 0011.5.2-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Settles XVII.G-Emissions Control Alternative Emissions Control(Optional Section( a. Is this separator controlled by back-up alternate combustion device i.e,not thecontrol device)that b not enclosed? The contri a pore f primary r..„:„,,_„,1 ITheco,wrisl desist iarttde separator is tool subiect to Rogalatieo 5005150 NVil.B.be. 5ection'XVII.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 theindividual 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 canitict between the language of this document and the language of the Clean Air Act„its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and'required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. • • • • • • COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY • Company Name Verdad Resources LLC County AIRS ID 123 History File Edit Date 2/512020 Plant AIRS ID A097 Ozone Status Attainment Facility Name Peggy 2501 Pad EMISSIONS•Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 .H2S _ SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 - 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 0.8 376.1 3.5 6.7 0.8 18.8 3.5 0.3 NEW 002 19WE0070 Two(2)400 bbl Produced Water Storage Tanks 0.3 23.6 1.5 2.6 0.3 1.2 1.5 0.1 NEW 003 19WE0071 Crude Oil Truck Loadout 0.0 13.5 0.1 0.2 _ 0.0 0.7 0.1 0.0 NEW 004 19WE0972 Separator Venting during VRU Downtime 0.1 24.7 0.2 0.6 0.1 1.2 0.2 0.0 NEW 005 GP02 GM Vorlec 5.7L,92hp,4SRB,(V-ENG01) 0.1 0.1 12.4 0.6 9.8 0.1- 0.1 0.1 0.9 0.6 _ 1.8 0.1 NEW(sn:10CNMM405080045) 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 0.2 0.2 32.5 1.4 32.5 0.6 0.2 0.2 2.0 1.4 3.9 0.6 NEW(sn:07Y06205) 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempl/Insignificants 0.0 0.0 XA Separator Heaters 0.5 0.5 0.0 0.5 0.5 0.0 From APCD102 Form XA Heater Treater Heater 0.5 0.5 0.0 0.5 0.5 0.0 From APCD102 Form XA Fugitives 0.3 0.0 0.3 0.0 From APCD102 Form 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.2 0.2 0.0 0.0 47.1 439.9 0.3 48.5 10.8 0.2 0.2 0.0 0.0 5.1 23.9 0.3 12.0 1.2 VOC: Syn Minor(PSD and OP) NOx:True Minor(PSD and OP) CO: True Minor(PSD and OP) HAPS: True Minor B,T,X,HCHO&Total HH: True Minor+affected Area ZZZZ: True Minor Permitted Facility Total 0.2 0.2 0.0 0.0 46.1 439.9 0.0, 47.5 10.8 0.2 0.2 0.0 0.0 4.1 23.91 0.0 11.0 1.2 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.2 0.2 0.0 0.0 4.1 23.9 0.0 11.0 Pubcom&modeling(not)required based on (A change in emissions) Total VOC Facility Emissions(point and fugitive) 24.2 Facility is eligible for GP02 because<90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) 23.9 _ Project emissions less than 25/50 tpy Note 1 Note,2 • • Page 6 of 8 Printed 2/7/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 Facility Name Peggy 2501 Pad Emissions-uncontrolled(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 1506 1088 158 218 10382 47 6.7 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 1260 3960 2.6 003 19WE0971 Crude Oil Truck Loadout 47 416 0.2 004 19WE0972 Separator Venting during VRU Downtime 129 111 19 28 839 4 0.6 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 149 20 19 11 4 1 22 0.1 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 980 45 42 25 9 3 49 0.6 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 0.0 0.0 TOTAL(tpy) 0.6 0.0 0.0 1.5 0.6 0.1 0.1 7.8 0.0 0.0 0.0 0.0 10.8 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus 7 19WE0972.CP1 2/7/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A097 . Facility Name Peggy 2501 Pad Emissions with controls(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0969 Eight(8)400 bbl Crude Oil Storage Tanks 75 54 8 11 519 2 0.3 002 19WE0970 Two(2)400 bbl Produced Water Storage Tanks 63 198 0.1 003 19WE0971 Crude Oil Truck Loadout 2 21 0.0 004 19WE0972 Separator Venting during VRU Downtime 6 6 1 1 42 0 0.0 005 GP02 GM Vortec 5.7L,92hp,4SRB,(V-ENG01) 149 20 19 11 4 " 1 22 0.1 006 GP02 Caterpillar G3306TA,203hp,4SRB,(GL-ENG01) 980 45 42 25 9 3 49 0.6 0.0 0.0 0.0 APEN Exempt/Insignificants 0.0 XA Separator Heaters 0.0 XA Heater Treater Heater 0.0 XA Fugitives 2 2 0 1 15 0.0 0.0 0.0 TOTAL(tpy) 0.6 0.0 0.0 0.1 0.0 0.0 0.0 0.4 0.0 0.0 0.0 0.0 1.2 8 19 W E0972.CP1 2/7/2020 SU ►�� SEDER ! cee .44 c/h ( /WA/ Addeaviti 2cceive4( O(/3O/ 2,0 Lc) Crude Oil Storage Tank(s) APEN Form APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: Ict w6(161.69 AIRS ID Number: f 23 /Agp97 / cot [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Peggy 2501 Pad Site Location Site Location: SESW Sec 25 T9N R60W County: Weld 40.714774/-104.040842 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address': Brad Ganong 720-845-6918 bganong@verdadoil.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. 420242 Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 COLORADO 1 I ` u�.:mrsc �f wx:_ h b Erv��n.�n+.�t Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit O Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment 0 Change company name3 ❑ Change permit limit ❑ Transfer of ownership' 0 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 a Notes: Initial permit application. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 8/28/2019 Crude oil atmospheric storage TK01-08 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 0 Exploration Et Production (E&P) site weeks/year 0 Midstream or Downstream (non Ef&P) site Will this equipment be operated in any NAAQS nonattainment area? • Yes p No Are Flash Emissions anticipated from these storage tanks? p Yes ■ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No p • Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 ®v COLORADO 2 I n par_ sn: vl Rtil: 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 (bbl/year) Requested Annual Permit Limits- (bbl/year) Crude Oil Throughput 200,000 260,000 From what year is the actual annual amount? projected Average API gravity of sales oil: 34.9 degrees 0 Internal floating roof Tank design: El Fixed roof RVP of sales oil: 6.9 0 External floating roof Storage . Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK01-08 8 3,200 07/2019 08/2019 Wells Serviced by this Storage. Tank or Tank Battery6 (EftP Sites Only) -' API Number Name of Well Newly Reported Well 05 - 123 - 49840 Peggy 2501-01H (05-123-49840) 12 05 - 123 - 49839 Peggy 2501-02H (05-123-49839) SI ■ - ■ ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.714774/-104.040842 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECO1 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑✓ Upward 0 Horizontal 0 Downward ❑ Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) ✓❑ Circular Interior stack diameter (inches): 54 ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 3 , .,COLORADO k rent �";.';,, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: GCO ECD2000 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes O No Pilot Burner Rating: 2596 0.042 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —30 psig psig Describe the separation process between the well and the storage tanks: Produced fluids from the wells are directed to two 3 -phase horizontal heated separators. From the separators, oil is directed to the two 3 -phase vertical heater treaters for further separation and pressure reduction. From the heater treaters, oil is directed to the atmospheric storage tanks. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 4 I Agy COLORADO `na::;,, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95 NOx CO HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basin U Units Source (AP -42, Mfg., etc.) Uncontrolled - Emissions (tons/year) Controlled Emissions a (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 2.44 lb/bbl site -specific 244.43 12.22 317.76 15.89 NOx 0.0052 lb/bbl Calculated 0.52 0.52 0.68 0.68 CO 0.023 lb/bbl Calculated 2.32 2.32 3.01 3.01 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract ServiceUncontrolled (CAS) Number Emission Factor Actual Annual Emissions Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/ ear y ) Controlled Emissions8 (pounds/year) Benzene 71432 0.0033 lb/bbl site -specific 666.00 33.30 Toluene 108883 0.0023 lb/bbl site -specific 452.00 22.60 Ethylbenzene 100414 0.00032 lb/bbl site -specific 64.00 3.20 Xylene 1330207 0.00041 lb/bbl site -specific 82.00 4.10 n -Hexane 110543 0.025 lb/bbl site -specific 4,938.00 246.90 2,2,4- Trimethylpentane 540841 0.00010 lb/bbl site -specific 20.60 1.03 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. z 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 emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 1.6.4.11 iron norm AV COLORADO 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. 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. Signature of Lega - Auth•rized Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: For more information or assistance call: Small Business Assistance Program and Environment (303) 692-3175 or (303) 692-3148 Colorado Department of Public Health and Environment APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 6 I AvCOLORADO ' Ken. artmcm � , R ,ceiVed Tom^- 30,101O .3F Crude Oil Storage Tank(s) APEN Form APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 1 9 W E 096 9 AIRS ID Number: 123 / A097 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Verdad Resources LLC Peggy 2501 Pad Site Location SESW Sec 25 T9N R6OW County: Weld 40.714774/-104.040842 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 NAICS or SIC Code: 1311 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. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 12/2019 COLORADO DepaweW of Public Aee1N b Emlronmenl Permit Number: 19WE0969 AIRS ID Number: 123 /A097/001 [Leave blank sinless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Crude Oil Throughput: 200,000 260,000 From what year is the actual annual amount? projected Average API gravity of sales oil: 34.9 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 6.9 0 External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK01-08 8 3,200 07/2019 08/2019 Wells Serviced by this Storage Tank or Tank Battery6 (E£tP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 49840 Peggy 2501-01H (05-123-49840) l7 05 - 123 - 49839 Peggy 2501-02H (05-123-49839) SI - - • - - ■ - - • 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 EftP 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) 40.714774/-104.040842 ❑ 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 ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) EC01 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward 0 Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) ✓❑ Circular Interior stack diameter (inches): 54 ❑ Square/rectangle ❑ Other (describe): Interior stack width (inches): Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 12/2019 3 I gel COLORADO Dapanaaenl of Public Health &Environment Permit Number: 19WE0969 AIRS ID Number: 123 /A097/001 [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? Yes 0 No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) VOC Enclosed Combustor 100 95 NOx I CO HAPs Enclosed Combustor 100 95 Other: From what year is the following reported actual annual emissions data? projected or t the criteria pollutant emissions from source: Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP 42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 2.89 lb/bbl site -specific 289.27 14.46 376.05 18.80 NO,t 0.0061 lb/bbl AP-42/Calc 0.61 0.61 0.78 0.78 CO .0.027 lb/bbl AP-42/Calc 2.70 2.70 3.50 3.50 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 crude oil laboratory analysis, stack test results, and associated emislns 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 pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes ❑ No ollowing table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Number Emission Factor7 Actual Annual Emissions Uncontrolled Basis Source Mfg., etc.) Uncontrolled (lbs/year) y ) Controlled a (lbs/year) Benzene 71432 0.0058 lb/bbl site -specific 1,158.74 57.94 Toluene 108883 0.0042 lb/bbl site -specific 837.28 41.86 Ethylbenzene 100414 0.00061 lb/bbl site -specific 121.62 6.08 Xylene 1330207 0.00084 lb/bbl site -specific 167.84 8.39 n -Hexane 110543 0.040 lb/bbl site -specific 7,986.26 399.31 2,2,4-Trimethylpentane 540841 0.00018 lb/bbl site -specific 36.08 1.80 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. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 12/2019 5 I as COLORADO Department o! Public Health 6 Environment 2/4/2020 State.co.us Executive Branch Mail - Peggy 2501 Pad Questions STATE OF COLORADO Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Peggy 2501 Pad Questions Brad Ganong <BGanong@verdadresources.com> Thu, Jan 30, 2020 at 1:04 PM To: "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us> Hi Ben, Please find attached APENs for redlining the crude oil storage tanks (Pt 001) and Separator Venting (Pt 004) APENs. The APENs were updated based on the requested changes to the Promax model. In particular, the storage tank temperature was updated from 50.23 deg F to 61.08 deg F. Additionally, the working & breathing emissions were updated using the latest Promax W&B stencil. These updates resulted in changes to the emissions for both the oil tanks and separator venting. I also increased the requested separator venting process throughput. Let me know if you have any questions or need any additional information. [Quoted text hidden] 6 attachments B04_APCD 210, Crude Oil APEN - Peggy Addendum, Rev1.pdf 305K B05_APCD 211, Venting APEN - Peggy Addendum.pdf 284K C01_Emission Calcs - Peggy Addendum.pdf 226K . C03_W&B Losses & GOR_Peggy 2501 Pad_v2.pdf 67K C02_ProMax Report_Peggy 2501 Pad_v2.pdf 149K ... F01_AP_Form-APCD-102-Facility-Wide - Peggy Addendum.pdf 107K hf+nc•Ilmmil nnnnlc rnmlmailht/n?ik.nrirl1rriafQQRuiaw=ntRcaarrh=allRnarmmsaid=msa-f%3A1657184906498116989&simol=msa-f%3A16571849064... 1/1 RECLIVE; f�T -32 W9 A PCD Stationary ources Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options wilt not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: / CEtYN7q AIRS ID Number: ) z /4(p7 / op 2 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Verdad Resources LLC Peggy 2501 Pad Site Location SESW Sec 25 T9N R60W County: Weld 40.714774/-104.040842 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 NAICS or SIC Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 E -Mail Address2: bganong@verdadoil.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 420243 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 1 i AVCOLORADO ,te°�;�,...1., 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 ✓❑ 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 $250 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 name ❑ Change permit limit ❑ Transfer of ownership3 ❑ 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 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: For existing sources, operation began on: Produced Water Storage Tanks For new or reconstructed sources, the projected start-up date is: 08/28/2019 Normal Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: Q Exploration Et Production (EftP) site days/week 52 weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? ■ Yes 0 No Are Flash Emissions anticipated from these storage tanks? 0 Yes • No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • 0 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) 805 series rules? If so, submit Form APCD-105. Yes No • O Are you requesting ≥ 6 ton/yr V0C emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 • Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 ©© COLORADO 2I - .;m„t uJp,�.^.me 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 (bbl/year) Requested Annual Permit Limit4 (bbl/year) Produced Water Throughput: 150,000 180,000 From what year is the actual annual amount? Tank design: D Fixed roof Projected ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW01-02 2 x 400 bbl 800 07/2019 08/2019 Wells Serviced by this Storage Tank or Tank Battery5 (EEO Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 49840 Peggy 2501-01H (05-123-49840) D 05 • 123 -49839 Peggy 2501-02H (05-123-49839) CI CI - ■ ■ 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 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 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.714774/-104.040842 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) EC01 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) El Upward ❑ Horizontal ❑ Downward El Other (describe): Indicate the stack opening and size: (check one) El Circular El Square/rectangle El Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 54 Interior stack width (inches): Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 �� COLORADO 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. Vapor D Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: Type: Enclosed Combustors Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: n/a MMBtu/hr Make/Model: GOO 2000 95 98 Waste Gas Heat Content: Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: 1496 0.042 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (EEtP 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 two 3 -phase horizontal heated separators. From the separators, fluids are directed to two 3 -phase vertical heater treaters for further separation and pressure reduction. Produced water at the horizontal separators and heater treaters is directed to the storage tanks. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 41 LTV COLORADO EruW n'm N Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95 NOx CO HAPs Enclosed Combustor 95 Other: Projected From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 0.262 lb/bbl CDPHE 19.65 0.98 23.58 1.18 NOx 0.0037 lb/bbl Calculated 0.27 0.27 0.33 0.33 CO 0.017 lb/bbl Calculated 1.25 1.25 1.50 1.50 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service(CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions 7 (Pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 1,050.00 52.50 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 lb/bbl CDPHE 3,300.00 165.00 2,2,4- Trimethylpentane 540841 a Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 VN,COLORADO :ne= Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. g ature of Legal y A prized Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: ❑ 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 $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Small Business Assistance Program Environment (303) 692-3175 or (303) 692-3148 Air Pollution Control Division APCD-SS-B1 43O0 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 AV -COLORADO 6 a.wnn:m Huth Ein RECEIVED APCD Stationary Hydrocarbon Liquid Loading APEN - Form APCD-> ces Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: cpcp AIRS ID Number: 1z3 //61r07 /603 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: TL01 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Site Location: Verdad Resources LLC Peggy 2501 Pad Site Location SESW Sec 25 T9N R6OW County: Weld 40.714774/-104.040842 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 E -Mail Address2: bganong@verdadoil.com NAICS or SIC Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 4.0244 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 1 AV COLORADO 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 0 Request coverage under construction permit If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. ❑ Request coverage under General Permit GP07 -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR • APEN submittal for update only (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 Ft Notes: Initial Application 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Hydrocarbon Truck Loadout For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 08/ 28 /201.9 Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? ❑ Yes 2 No ❑ Yes 0 No ❑ Yes No ❑ Yes ❑ No ❑ Yes E No ❑ Yes ❑ No ❑ Yes ❑ No Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 �®'@' COLORADO 2 I y�y Leg V enta Y LL'a� -V 9ca1!h b£nolrnnmoni 0 other: Permit Number: AIRS ID Number: nk unless APCD has already assigned a permit # and MRS ID] [Leave bla Process Equipment Information Section 4 - 0 Crude Oil Product Loaded: Condensate If this APEN is being • laced from cargo carrier, complete the following: filed for vapors d1sP Actual Volume ,��o BbUyr 2Go'000 Bbl/yr Loaded: process growth Requested Volume V 4 Requested permit limitations. Requested limit(s) should consider future p a Requested values will become This product is loaded at this facility into: trucks tanks ,"rail tank cars" or "tank trucks") fissions, complete the following: Average temperature If site specific emission factor is used to calculate em of bulk liquid loading: Molecular weight of displaced vapors If this APEN is being filed for vapors displace d from pressurized loading lines, complete the Bbl/yr following: Requested Volume Loadeds: permit limitations• 4 Requested values will become p Lb/ft3 Product Density: Load Line Volume: Actual Volume Bbl/yr Loaded: growth Requested limit(s) should consider future process Form A PCD-20B -Hydrocarbon Liquid Loading APEN - Rev 02/2017 ft3 / truckload COLORADO 3 ��.: Permit Number: AIRS ID Number: ave blank unless APCD has already assigned a permit # and AIRS ID] [Le Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) Discharge Height Bove Ground Level. (Feet) O Upward with obstructing raincap Indicate the direction of the stack outlet: (check one) 0Downward � upward O Other (describe): O Horizontal Indicate the stack opening and size: (check one) Interior stack diameter (inches): Circular O Other (describe): Section 6 - Control Device Information Other: 54 COLORADO pn wwc 41 e Pollutants Controlled: VOC, HAPS Rating: Type: Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: Constant Pilot Light: pollutants Controlled: Description: Control Efficiency Requested MMBtu / hr Make/Model: GCO 2000 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 Waste a Gas Heat Content Btu/ scf MMBtu / hr 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 emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No ioment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOx CO VOC vapor balance /combustor 100 / 95 HAPs vapor balance / combustor 100 / 95 Other: (] Using State Emission Factors (Required for GP07) VOC ❑ Condensate 0.236 Lbs/BBL ✓❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions �_ ;� r; Requested Annual Permit, q= s Emission Limits) Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year). PM SOx NOx 0.00015 lb/bbl Ap-42/Calc 0.015 0.015 0.020 0.020 VOC 0.104 lb/bbl CDPHE 10.40 0.52 13.52 0.68 CO 0.00069 lb/bbl Ap-42/Calc 0.069 0.069 0.090 0.090 Benzene 0.00018 lb/bbl CDPHE 0.018 0.00090 0.023 0.0012 Toluene Ethylbenzene Xylenes n -Hexane 0.0016 lb/bbl CDPHE 0.16 0.0080 0.21 0.010 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 5 M� COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of L- • all utho irit zed Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: ❑ 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 $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd COLORADO Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 SU P R .C6 A6 Sep AP61 lIcideAdvAt Received of/36/iozo Gas Venting APEN - Form APCD-21 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: / 9 vv 49 72 AIRS ID Number: 123 440y7 /mg, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: Verdad Resources LLC Peggy 2501 Pad SESW Sec 25 T9N R60W 40.714774/-104.040842 (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Site Location Weld County: NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Brad Ganong 720-845-6918 bganong@verdadoil.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued py the APCD via e-mail to the address provided. 420247 Form APCD-211 - Gas Venting APEN - Revision 3/2019 / COLORADO 1 I .iV Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ 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 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ 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: compressor downtime Heater Treater venting during VRU Company equipment Identification No. (optional): HT-VENTO1 For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 08/28/2019 O 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? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Yes Yes Yes Form APCD-211 - Gas Venting APEN - Revision 3/2019 2 ❑✓ No No ❑ No AV COLORADO 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 O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑✓ Other Description: Heater Treater Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event 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 Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 9,600 bbl/year Actual: 8,000 bbl/year Molecular Weight: 41.18 VOC (Weight %) 74.51 Benzene (Weight %) 0.195 Toluene (Weight %) 0.167 Ethylbenzene (Weight %) 0.029 Xylene (Weight %) 0.042 n -Hexane (Weight %) 1.269 2,2,4-Trimethylpentane (Weight %) 0.0066 Additional Required Information: O Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX ft n -Hexane, temperature, and pressure) 0 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 3 I AVCOLORADO Z ;, r`.,.;' Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and MRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.714774/-104.040842 Operator Stack ID No . Discharge Height Above Ground Level '- (Feet) Temp (°f7 Flow Rate ( ACFM) Velocity (ft/sec ) EC01 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Circular O Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 54 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. O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: GCO ECD 2000 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 2,342.19 0.042 Btu/scf MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 3/2019 4 I AVCOLORADO w7 dry" "'m, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the ned control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested - - Control Efficiency : (% reduction in emissions) PM SOx NOx CO VOC Enclosed Combustor 95 HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit s Emission Limit(s) Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NOx 0.0093 lb/bbl Calc / AP -42 0.037 0.037 0.045 0.045 CO 0.042 lb/bbl Calc / AP -42 0.17 0.17 0.20 0.20 VOC 4.71 lb/bbl Site Specific 18.83 0.94 22.60 1.13 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS ( ) ) Number Emission Factor Actual Annual Emissions. Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled 6 Emissions (pounds/year) Benzene 71432 0.012 lb/bbl Site Specific 98.79 4.94 Toluene 108883 0.011 lb/bbl Site Specific 84.54 4.23 Ethylbenzene 100414 0.0018 lb/bbl Site Specific 14.41 0.72 Xylene 1330207 0.0026 lb/bbl Site Specific 21.02 1.05 n -Hexane 110543 0.080 lb/bbl Site Specific 641.43 32.07 2,2,4- Trimethylpentane 540841 0.00042 lb/bbl Site Specific 3.33 0.17 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2019 51 AV Lkaparamare K.. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature bf Legall/Authorized Person (not a vendor or consultant) Michael Cugnetti /07 77/7 Date EH&S Manager Name (please print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance E✓ 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: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.Rov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 6I AV COLORADO �ec,G; vec;P 7�,1.3o, 2020 Gas Venting APEN - Form APCD-211 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 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: 19W E0972 AIRS ID Number: 123 / A097 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Peggy 2501 Pad Site Location: SESW Sec 25 T9N R60W 40.714774/-104.040842 Mailing Address: 1125 17th Street, Suite 550 (Include, Zip Code) Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Brad Ganong Phone Number: 720-845-6918 E -Mail Address2: bganong@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. Form APCD-211 - Gas Venting APEN - Revision 12/2019 1 I as COLORADO DepsonentafPoale Hmllh 6 Environment Permit Number: 19WE0972 AIRS ID Number: 123 / Ao97 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑✓ Other Description: Heater Treater Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event 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? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ Yes ❑✓ No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 10,400 bbl/year Actual: 8,000 bbl/year Molecular Weight: 41.18 VOC (Weight %) 74.51 Benzene (Weight %) 0.195 Toluene (Weight %) 0.167 Ethylbenzene (Weight %) 0.029 Xylene (Weight %) 0.042 n -Hexane (Weight %) 1.269 2,2,4-Trimethylpentane (Weight %) 0.0066 Additional Required Documentation: ❑ Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis (including BTEX Et 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. Form APCD-211 - Gas Venting APEN - Revision 12/2019 3l as COLORADO Depatament of Public Health Environment Permit Number: 19 W E 0972 AIRS ID Number: 123 iA097/004 [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. a 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 ues if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) PM SO, NO, CO VOC Enclosed Combustor 100 95 HAPs Enclosed Combustor 100 95 Other: From what year is the following reported actual annual emissions data? projected report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled (tons/year) Controlled •Emissions Emissions6 (tons/year) Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions tons/ ear (tons/year) ) PM SOx NO, 0.0093 lb/bbl Calc/AP-42 0.037 0.037 0.049 0.049 CO 0.043 lb/bbl Calc/AP-42 0.17 0.17 0.22 0/2 VOC 4.74 lb/bbl site -specific 18.95 0.95 24.63 1.23 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 pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ✓❑ Yes ❑ No lowitable to report the non -criteria pollutant (HAP) emissions from source: ng Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (lbs/year) y ) Controlled Emissions6 (lbs/year) Benzene 71432 0.012 lb/bbl site -specific 99.39 4.97 Toluene 108883 0.011 lb/bbl site -specific 85.04 4.25 Ethylbenzene 100414 0.0018 lb/bbl site -specific 14.50 0.72 Xylene 1330207 0.0026 lb/bbl site -specific 21.15 1.06 n -Hexane 110543 0.081 lb/bbl site -specific 645.29 32.26 2,2,4-Trimethylpentane 540841 0.00042 lb/bbl site -specific 3.35 0.17 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Form APCD-211 - Gas Venting APEN - Revision 12/2019 5,ge COLORADO Daparonent al Public Hualth & Environment 2/4/2020 State.co.us Executive Branch Mail - Peggy 2501 Pad Questions STATE OF COLORADO Fischbach - CDPHE, Ben <ben.fischbach@state.co.us> Peggy 2501 Pad Questions Brad Ganong <BGanong@verdadresources.com> To: "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us> Hi Ben, Thu, Jan 30, 2020 at 1:04 PM Please find attached APENs for redlining the crude oil storage tanks (Pt 001) and Separator Venting (Pt 004) APENs. The APENs were updated based on the requested changes to the Promax model. In particular, the storage tank temperature was updated from 50.23 deg F to 61.08 deg F. Additionally, the working & breathing emissions were updated using the latest Promax W&B stencil. These updates resulted in changes to the emissions for both the oil tanks and separator venting. I also increased the requested separator venting process throughput. Let me know if you have any questions or need any additional information. [Quoted text hidden] 6 attachments B04 APCD 210, Crude Oil APEN - Peggy Addendum, Rev1.pdf 305K ▪ B05_APCD 211, Venting APEN - Peggy Addendum.pdf 284K C01_Emission Calcs - Peggy Addendum.pdf • 226K ▪ C03_W&B Losses & GOR_Peggy 2501 Pad_v2.pdf 67K ▪ C02_ProMax Report_Peggy 2501 Pad_v2.pdf 149K ▪ F01_AP_Form-APCD-102-Facility-Wide - Peggy Addendum.pdf • 107K _minw4r r,Ana n(1/2Anf4A/2(10.10..:......1—....... $O/7 A.1 CC740A.1.1QA Hello