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Address Info: 1150 O Street, P.O. Box 758, Greeley, CO 80632 | Phone:
(970) 400-4225
| Fax: (970) 336-7233 | Email:
egesick@weld.gov
| Official: Esther Gesick -
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20201595.tiff
-r....., COLORADO 'V Department of Public `°P E Health b Environment RECEIVED MAY 0 4 2020 WELD COUNTY Weld County - Clerk to the Board COMMISSIONERS 1150O St PO Box 758 Greeley, CO 80632 April 29, 2020 Dear Sir or Madam: On April 30, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Enerplus Resources (USA) Corporation - Colorado Lakes Well Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 44.4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe a4 \, Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director I , $ -*y PubI c Rev;et,J cc:PL0P),NL-(us),Pw(sn/Ia/cu/cif), 2020-1595 OG(aM 6/ / .o s/2.9%o — Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Enerplus Resources (USA) Corporation - Colorado Lakes Well Pad - Weld County Notice Period Begins: April 30, 2020 Notice is hereby given that an application for a proposed projector activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Enerplus Resources (USA) Corporation Facility: Colorado Lakes Well Pad Exploration Ex Production Well Pad SWSW SEC 28 T8N R67W Weld County The proposed project or activity is as follows: The applicant proposes the removal of the existing NGL skid, addition of pipeline takeaway for separator gas, updated permit and emission limits, the use of an open flare as an emergency/back-up control device for times of pipeline downtime, and new synthetic minor facility limits with respect to current NANSR thresholds. 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 18WE1218 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 1 Department of Public Health 6 Environment e a P�i E Produced Water Storage Tank(s) APEN - Form APCD-207 CO 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 wilt be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks,condensate storage tanks,hydrocarbon liquid loading,etc.). In addition,the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at:www.colorado.govipacific/cdptie/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: 18WE1218 AIRS ID Number: 123 /9FDA/005 [Leave blank unless APCD has already assigned a permit C and AIRS ID] Section 1 -Administrative Information Company Name': Enerplus Resources(USA)Corporation Site Name: Colorado Lakes Well Pad Site Location Site Location: SWSW Sec. 28,T8N, R67W County: Weld NAICS or SIC Code: 1311 Mailing(Include Address. (IMlude Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 Contact Person: Kristin Van Hees Phone Number: 720-279-5515 E-Mail Address2: KVanHees@enerplus.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. 4's°af 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the addrefriyided. 472694 Ay COLORADO Form APCD-207 Produced Water Storage Tank(s)APEN Revision 3/2019 1 I �i :� ' Permit Number: 18WE 1218 MRS ID Number: 123 /9FDA/005 [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 2 - Requested Action O NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP05 ❑ GP08 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 O Change permit limit O Transfer of ownership's O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDMONAL PERMIT Acnoms- ▪ APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 -General information General description of equipment and purpose: Two 400 bbl produced water tanks Company equipment Identification No. (optional): PRD-WTR For existing sources,operation began on: 7/29/2018 For new or reconstructed sources,the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration&Production(E&P)site ❑ Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes 0 No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? ❑✓ Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes 0 No 805 series rules?If so, submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual Yes ❑ No emissions a 6 ton/yr(per storage tank)? COLORADO Form APCD-2137 Produced Water Storage Tank(s)APEN - Revision 3/2019 2 1 � �""°" Permit Number: 18WE1218 AIRS ID Number: 123 /9FDA/0Q5 (Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 4-Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bWyear) (bbl/year) Produced Water Throughput: 80000 From what year is the actual annual amount? 2019 Tank design: Q Fixed roof O Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in production (bbl) Storage Tank(month/year) (month/year) PRO Wi'R 2 800 7/2018 7/2018 Wells Serviced by this Storage Tank or Tank Battery'(ESP Sites Only) API Number Name of Well Newly Reported Well 05 -123 -46456 Barton Mills 8-67-29-30C O 05 -123 •44598 Cherry Creek 8-67-28-27N O O - O - O s Requested values will become permit limitations.Requested limit(s)should consider future growth. 6 The EDP 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/Lonpitade or UTM) 40.628235/-104.90483 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No, Ground Level(feet) f ) (ACFM) (ft/sec) Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet:(check one) Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size:(check one) 0 Circular Interior stack diameter(Inches): 48 ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): pp� COLORADO Form APCD-207 Produced Water Storage Tank(s)APEN - Revision 3/2019 3 I �� "" Permit Number: 18WE1218 AIRS ID Number: 123 I 9FDA 005 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6-Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOCs and HAPs Rating: MMBtu/hr Type: Enclosed Combustors Make/Model:Three Cimmaron 48" Q Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98+ Minimum Temperature: NA Waste Gas Heat Content: 2112 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —40-50 psig Describe the separation process between the well and the storage tanks: Gas and liquids from each well are sent to a 2-phase separator,gas goes to pipeline, liquids go to 3-phase heated separator, oil goes to oil tanks and water goes to water tanks. p AD COIO# O Form APCD-207. Produced Water Storage Tank(s)APEN •Revision 3/2019 4 1 ® < Permit Number: 18WE 1218 AIRS ID Number: 123 /9FDA/005 [Leave blank unless APCD has already assigned a permit#and AIRS lD Section 8 -Emissions Inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Methods) Efficiency (X reduction in emissions) VOC - Combustors 95%NOx CO MAPS Combustors 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor7 Actual Annual Emissions Emission Limit(s)S Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-s2, Emissions Emissions8 Emissions Emissions Basis Mfg.,etc.) (tans/yam) (tons/year) (tons/year) (tans/year) VOC 0.262 lb/bbl State 10.48 0.52 NOx CO Non-Criteria Reportable Pollutant Emissions inventory Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service( ) uncontrolled Units (AP-42, Emissions Ernisslonse Number Basis A4fg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.007 lb/bbl State 560 28 Toluene 108883 Ethylbenzene 100414 Xytene 1330207 n-Hexane 110543 0.022 lb/bbl State 1760 88 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 1403. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APC0.207 Produced Water Storage Tank(s)APEN -Revision 3/2019 5 Permit Number: 18WE1218 AIRS ID Number: 123 /9FDA/005 [Leave blank unless APCD has already assigned a permit?t and AIRS IDS 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. 12 I to ! t°I Signatt of Legally Authorized Person(not a vendor or consultant) Date Kristin Van Flees Sr. Environmental Specialist Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692.3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/aped AV COLORADO Form APCD-207 Produced Water Storage Tank(s)APEN -Revision 3/2019 6 I - 1=7:17,r,. CDPHE P H E Crude Oil Storage Tank(s) APEN �► Form APCD-210 CO Air Pollutant Emission Notice(APEN) and Application for Construction Permit AR 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 o 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/cdphefair-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: 18WE1219 AIRS ID Number. 123 / 9FDA/006 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name: Enerplus Resources(USA)Corporation Site Name: Colorado Lakes Well Pad Site Location Site Location: SWSW Sec. 28, T8N, R67W County: Weld NAICS or SIC Code: 1311 Mailing Address: (include zip code) 950 17th Street, Suite 2200 Denver, CO 80202 Contact Person: Kristin Van Hees Phone Number: 720-279-5515 E-Mail Address2: KVanHees@enerpius.com I the the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on ail 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 addrlitiirovided. yw ' 422 ,96 my COLORADO Form APCD-21O Crude Oil Storage Tank(s)APEN Revision 3/2019 1 I A Permit Number. 18WE 1219 AIRS ID Number: 123 /9FOA/006 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action O NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit • Request coverage under General Permit GPO8 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be . submitted along with the APEN filing fee. -OR- Q MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 Q Change permit limit O Transfer of ownership4 O Other(describe below) -OR- ▪ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 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: Six, 400 bbl Crude Oil Tanks Company equipment Identification No. (optional): TANKS For existing sources,operation began on: 7/29/2018 For new or reconstructed sources,the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration&Production(E&P)site ❑ Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? Q Yes O No Are Flash Emissions anticipated from these storage tanks? []i Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes Q No 805 series rules?If so,submit Form APCD-105. Are you requesting t 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual 0 Yes ❑ No emissions a 6 ton/yr(per storage tank)? pp COLORADO Form AFCD-21O Crude Oil Storage Tank(s)APEN - Revision 3/2019 2 I m ,° t; Permit Number: 18WE1219 AIRS ID Number: 123 /9FDA/006 [Leave blank unless APCD has already assigned a permit Y and AIRS ID] Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbi/year) (bbl/year) I Crude Oil Throughput: 120000 From what year is the actual annual amount? 2019 Average API gravity of sales oil: —36 degrees RVP of sales oil: ^•2.5 Tank design: Q Fixed roof O Internal floating roof O External floating roof Storage #of Uquid Manifold Storage Total Volume of installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) TANKS 6 2400 7/2018 7/2018 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 • 123 •46456 Barton Mills 8-67-29-30C ❑ 05 - 123 -4459e Cherry Creek 8-67-28-27N ❑ - - ❑ - - O - O 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) 40.628235/-104.90483 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet:(check one) GI Upward O Downward O Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size:(check one) Q Circular Interior stack diameter(inches): 48 ❑Square/rectangle Interior stack width(inches): Interior stack depth (inches): ❑Other(describe): Er COLORADO Form APCD-210 Crude Oil Storage Tank(s)APEN - Revision 3/2019 3 I m COLORADO Permit Number: 18WE 1219 AIRS ID Number: 123 /9FDA/006 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6-Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Type: Endosed combustors Make/Model:Three Cimarron 48" Q Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98+ Minimum Temperature: NA Waste Gas Heat Content: 2112 Btu/scf Constant Pilot Light: Q Yes O No Pilot Burner Rating: MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7- Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —40-50 Psig Describe the separation process between the well and the storage tanks: Gas and liquids from each well are sent to a 2-phase separator,gas goes to pipeline, liquids go to 3-phase heated separator, oil goes to oil tanks and water goes to water tanks. Q CO1.O R ADO Form APCD-21O Crude Oil Storage Tank(s)APEN - Revision 3/2019 4 [ " .� Permit Number: 18WE1219 AIRS ID Number: 123 /9FDA/006 [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(14 reduction): Overall Requested Control Pollutant Description of Control Methods) Efficiency (%reduction in emissions) VOC cars as% NOx CO HAPs Combustors 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor7 Actual Annual Emissions Emission Urnib(s)S Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled units (AP-42, Emissions Emissions Emissions Emissions Basis Ng.,etc.) (tons/fear) (tons/year) (tom/year) (tons/year) VOC 9.12 lb/bbl E&P Tanks 546.91 27.35 NOx 0.068 Ib/MMBtu AP-42 deminimis CO 0.31 Ib/MMBtu AP-42 deminimis Non-Criteria Reportable Pollutant Emissions inventory Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) k Units (AP-42, Emissions Emissions8 Number Basis etc.) (p ! ear) (pounds/year) Benzene 71432 1.41E-2 Ib/bbi E&P Tanks 1692 85 Toluene 108883 9.08E-3 lb/bbl E&P Tanks 1090 55 Ethylbenzene 100414 1.26E-3 Ib/bbi E&P Tanks Xylene 1330207 5.37E-3 lb/bbl E&P Tanks 644 32 n-Hexane 110543 7.95E-2 lb/bbl E&P Tanks 9539 477 2,2,4- 540841 Trimethyipentane 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. 7 Attach crude oil laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 1403. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APCD 210 Crude Oil Storage Tank(s)APEN Revision 3/2(}14 5 I :u Permit Number: 18WE 1219 AIRS ID Number: 123 /9FDA/406 [Leave blank unless APCD has already assigned a permit A 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 wilt be operated in full compliance with each condition of General Permit GP08. LACA. l Z 12 1 / I q Signature of Legally Authorized Person(not a vendor or consultant) Date Kristin Van Flees Sr. Environmental Specialist Name(print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance Q Draft permit prior to public notice _ (Checking any of these boxes may result in an increased fee andtor processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3,Part A, U.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https:ifwww.cotorado.gov/cdphhefapcd AV COLORADO Form APCD-210 Crude Oil Storage Tank(s)APEN-Revision 3/2019 6 I A '°7-71`°`"x",IsytlRp fn.am+es�+i P H E Hydrocarbon Liquid Loading APEN 'F'' Form APCD-208 CO , Air Pollutant Emission Notice(APEN) and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or locks payment for the filing fee. The re-submittal will require payment fora new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g.amine sweetening unit,glycol dehydration unit, condensate storage tanks,etc.). In addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.calorado.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: 18WE1220 AIRS ID Number: 123 /9FDA/ 007 [Leave blank unless APCD has already assigned a permit#and AIRS 101 Section 1 -Administrative Information Company Name': Enerplus Resources(USA)Corporation Site Name: Colorado Lakes Well Pad Site Location Site Location: SWSW Sec. 28, TBN, R67W County: Weld NAICS or SIC Code: 1311 Mailing Address: (include Zfp code) 950 17th Street, Suite 2200 Denver, CO 80202 Contact Person: Kristin Van Nees Phone Number: 720-279-5515 E-Mail Address2: KVanHees@enerpius.com Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes wilt require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. T 'Git' Acot*aApo Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019 1 I Permit Number: 18WE1220 MRS iD Number: 123 /9FDA/007 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 -Requested Action O NEW permit OR newly-reported emission source O Request coverage under construction permit O Request coverage under General Permit GP07 if General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- • MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 Q Change permit limit ❑ Transfer of ownership4 O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDMONAL PERMIT ACTIONS- • Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 3 For company name change,a completed Company Name Change Certification Form(Form AAPCCD-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: Truck Loadout of Crude Oil Company equipment Identification No. (optional): LOAD1 For existing sources,operation began on: 7/29/2018 For new or reconstructed sources, the projected start-up date is: Wilt this equipment be operated in any NAAQS nonattainment area? ❑ Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes E No emissions? Does this source load gasoline into transport vehicles? O Yes Q No Is this source located at an oil and gas exploration and production site? Q Yes ❑ No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes Q No average? Does this source splash fill less than 6750 bbl of condensate per year? O Yes ❑ No Does this source submerge fill less than 16308 bbt of condensate per year? ❑ Yes O No COLORAoo Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 2 1 AN, " Permit Number: 18VVE1220 AIRS ID Number: 123 / 9FDA / 007 (Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 4 - Process Equipment Information Product Loaded: O Condensate El Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loadeds: 120000 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: Tank trucks (e.g. "rail tank cars" or "tank trucks") bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 70 °F True Vapor Pressure: 3.4 ©70F' Psia ® 60 °F Molecular weight of displaced vapors: G 50 lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft; Load Line Volume: ft'/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. AW COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 3 I Permit Number: 18WE1220 AIRS ID Number: 123 /9FDA 1007 [weave thank untess APCD has already assigned a permit it and AIRS IDa Section 5 -Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.628235/-104.90483 ratm ttFl liihtatl Tem low Rate fife Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet: (check one) 0✓ Upward O Downward O Upward with obstructing raincap Horizontal ❑Other(describe): indicate the stack opening and size:(check one) [✓ Circular Interior stack diameter(inches): 48 O Other(describe): Section 6 -Control Device Information Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. ✓j Loading occurs using a vapor balance system: Requested Control Efficiency: 7O% Used for control of: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Combustors Make/Model" Cimarron 48" ri Combustion Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98+ Minimum Temperature: NA F Waste Gas Heat Content: 2112 Btu/scf Constant Pilot Light: ✓0 Yes O No Pilot Burner Rating: MMBtu/hr Pollutants Controlled: ID Other: Description: Requested Control Efficiency: essxo aDO Form APCD.208 Hydrocarbon Liquid Loading APEN Revision 3/2019 1 .' ^, Permit Number: 18WE1220 AIRS ID Number: 123 I 9FDA/0Q7 [Leave blank ursiess 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 overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Methods) Control Efficiency (X reduction in emissions) PM SOX NOX CO VOC Vapor Balance and Combustors 66.5% HAPs Vapor Balance and Combustors 66.5% Other: ❑ Using State Emission Factors(Required for GP07) V0C Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42. Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/yam) (tors/year) (tors/year) (toes/yearl PM sox NOx CO VOC 2.4 lb/1000 gal AP-42 6.04 2.02 Non-Criteria Reportable Pollutant Emissions inventory Chemical Emission Factor Actual Annual Emissions Chemical NameSource Service r (CAS) A Uncontrolled units (AP-42, Emissions Emissions6 Number Basis Mfg.,etc.) (Pounds/yam) (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 2,2,4- 540841 Trimethylpentane Other: _ 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emissions fees wilt be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 5 I �� « Permit Number: 18WE1220 AIRS ID Number: 123 /9FDA/007 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct.if this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. .. -� t2 !CI /PI Signature of Legally Authorized Person(not a vendor or consultant) Date Kristin Van Flees Sr. Environmental Specialist 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$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.gov/cdphe/aped p COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN Revision 3/2019 6 ► • w"` «, " "„, ►, C° E Gas Venting APEN - Form APCD-211 CO Air Pollutant Emission Notice(APEN)and ' Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities,including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment 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,btowdown 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 wilt not satisfy your reporting needs.A list of alt 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: 18WE1222 AIRS ID Number: 1213/9FDA//010 [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 1 -Administrative Information Company Name': Enerplus Resources(USA)Corporation site Name: Colorado Lakes Well Pad Site Location Site Location: SWSW Sec. 28, T8N, R67W Weld County: NAICS or SIC Code: 1311 Mailing Address: 950 17th Street, Suite 2200 (Include Yip Cade) Denver, CO 80202 Contact Person: Kristin Van Hees Phone Number: 720-279-5515 E-Mail Address2: KVanHees@enerplus.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. 422 ",9 i Mr COLORADO Form APCD-211 Gas Venting APEN - Revision 3/2019 1 I °:a ` Permit Number: 18WE1222 AIRS ID Number: 1213 / 9FDA / 010 (Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source -OR- []{ MODIFICATION to existing permit (check each box below that applies) Change fuel or equipment 0 Change company name3 0 Add point to existing permit 0 Change permit limit ❑ Transfer of ownership' O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) 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: Flaring of Separator Gas when pipeline is unavailable Company equipment Identification No. (optional): For existing sources, operation began on: Separator 7/29/2018 For new, modified, or reconstructed sources, the projected start-up date is: 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any'NAAQS nonattainment area? hours/day 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? Form APCD-211 Gas Venting APEN - Revision 3/2019 days/week weeks/year Q Yes ❑ Yes ❑✓ Yes ❑ No a NO ❑ No AYCOLORADO 2 I at, Permit Number: 18WE1222 MRS ID Number: 1213/9FDA/010 tleave blank unless APCD has already assigned a permit#and AIRS ID] Section 4-Process Equipment information ❑✓ Gas/Liquid Separator ❑ Well Head Casing o Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event [] Other Description: 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? Q Yes ❑ No Vent Gas .�510 BTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: 19.9 MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5• Molecular Weight: 26.73 VOC(Weight%) 43.18 Benzene(Weight%) 0.0020 Vented Gas Toluene(Weight%) 0.0017 Properties: Ethylbenzene(Weight%) 0.0001 Xylene(Weight%) 0.0003 n-Hexane(Weight%) 0.0074 2,2,4-Trimethylpentane(Weight%) 0.0004 Additional Required Information: Attach a representative gas analysis(including BTEX&n-Hexane,temperature,and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX Ft n-Hexane,temperature,and pressure) 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. per/ COLORADO Form APCD-211 Gas Venting APEN - Revision 312019 3 lam` ""' Permit Number: 18WE1222 AIRS ID Number: 1213/9FDA 1010 { I eave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (tat itudelLongitude or UTM) 40.628235/-104.90483 ss Flare -10 1000 Variable Variable Indicate the direction of the stack outlet: (check one) Upward O Downward O Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size:(check one) ❑Circular Interior stack diameter(inches): 4 ❑Other(describe): Section 6- Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Size: Make/Model: O VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC and HAPS Rating: MMBtu/hr Type: Open Flare Make/Model: Steffes ® Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 95+ Minimum Temperature: NA Waste Gas Heat Content: 1 510 Btu/scf Constant Pilot Light: 0 Yes O No Pilot burner Rating: 0.02 MMBtu/hr Pollutants Controlled: Other: Description: Requested Control Efficiency: cotss�zADO Form APCD-211 Gas Venting APEN - Revision 312019 4 ! >' Permit Number: 18WE1222 AIRS ID Number: 1213/9FDA/010 [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 7 Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control.Efficiency (x reduction in emissions) PM Sox NOx CO VOC Open Flare 95% NNAPs Open Flare 95% Other: From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissionsb Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tonslyear) PM SOx NOx 0.068 Ib/MMBtu AP-42 1.02 1.02 CO 0.31 Ib/MMBtu AP-42 4.66 4.66 VOC 20.47 ib/MMBtu Mass Balance 307.56 15.38 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions stract Chemical Name Controlled Service vi (CAS) Uncontrolled Units (AP-4Sou2, Emissions Emisstonsb Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 149.63 Ib/MMscf Mass Balance 2979 149 Toluene 108883 130.57 Ib/MMscf Mass Balance 2599 130 Ethylbenzene 100414 12.65 Ib/MMscf Mass Balance 252 13 Xylene 1330207 25.29 Ib/MMscf Mass Balance 503 25 n-Hexane 110543 606.86 Ib/MMscf Mass Balance 12081 604 2,yip Trimethylpentane 540641 27.54 Ib/MMscf Mass Balance 548 27 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. Amy COLORADO Form APCD-211 Gas Venting APEN- Revision 3/2019 5 ► klalf Permit Number. 18WE1222 AIRS ID Number: 1213/9FDA/010 (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. tA/1 �`/ � i a /(a /Pi Signature of Legally Authorized Person(not a vendor or consultant) Date Kristin Van Flees Sr. Environmental Specialist Name(please print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aped COLORADO Form APCD-211 Gas Venting APEN- Revision 3/2019 6 I �� :rn.,A' , Ait COLORADO Air Pollution Control Division CDPHE Department al Public Health fi Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1218 Issuance: 2 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Colorado Lakes Well Pad Plant AIRS ID: 123/9FDA Physical Location: SWSW SEC 28 T8N R67W County: Weld County ,Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Two (2) 400 barrel fixed roof storage PRD-WTR 005 Enclosed Flare vessels used to store produced water This permit$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. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. 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 Page 1 of 9 COLORADO Air Pollution Control Division CDPHE Department of Publac Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III II.F.4.) ) 3. 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.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility AIRS Tons per Year =Emission Equipment ID Point PM2.5 NO VOC CO Type PRD-WTR 005 -- --- 0.5 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted 'emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Page 2 of 9 isH... . COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID PRD-WTR 005 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS u. 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 mailable to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point' PRD-WTR 005 Produced Water throughput 80,000 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) • month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual Page 3 of 9 r� #�- COLORADO 7 Mr Pollution Control Division CDYHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II C2. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation°Number 7, Dart D, Section V) OPERATING &t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (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, Part D, Sections I.C, II.B.2. and II.A.23) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. All previous versions of this permit are cancelled upon issuance of this permit. Page 4 of 9 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the ast APEN submitted; or For any non -criteria reportable pollutant:. If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to, the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified;, or No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation 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, V.A.7.B). GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 5 of 9 �,4.�- COLORADO Y Air Pollution Control Division GDFs` Department of Public Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless`specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. • 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute,a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab into. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT Ben Fischbach Permit Engineer Page 6 of 9 a COLORADO Mr Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 December 4, 2019 Issued to Enerplus Resources (USA) Corporation Issuance 2 This Issuance Issued to Enerplus Resources (USA) Corporation. NGL skid removed and throughput updated. Synthetic Minor Facility. Page 7 of 9 a .,. COLORADO -'w Air Pollution Control Division co,H€ Department of Public Health ft 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. A 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 ILEAof the Common Provisions Regulation. See "https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) Thefollowing emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions ` Emissions (lb/yr) (lb/yr) Benzene 71432 560 28 005.. n-Hexane 110543 1,760 88 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 5.17 * 10 3 5.17 * 10 3 AP-42: Ch. 13.5 CO 2.36 * 10"2 2.36 * 10-2 VOC 0.262 1.31 * 10-2 71432 Benzene 0.007 3.50 * 10.4 CDPHE 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 8 of 9 M. 1- COLORADO Air Pollution Control Division .. CDPH€ Department of Public 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, NOx, n-Hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACTIHH 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: httc*//www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A= Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 COLORADO 44,0 Mr Pollution Control Division C6AHE Department of Pub tc Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1219 Issuance: 2 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Colorado Lakes Well Pad Plant AIRS ID: 123/9FDA Physical Location: SWSW SEC 28 T8N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID TANKS 006 Six (6) 400 barrel fixed roof storage_vessels Enclosed Flare used to store crude oil This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 1O COLORADO Air Pollution Control Division CD?NE Department of Public Health$Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 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.) .A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment iD Point PM2.5 NOX VOC CO Type TANKS 006 - - - 27.4 3.2 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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 owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the Page 2 of 10 rµ,a. COLORADO 411."11 Air Pollution Control Division CDPNE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of V0C 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TANKS 006 Enclosed Flare V0C and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following',maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point TANKS 006 Crude Oil throughput 120,000 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 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. 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 Publac Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of RegulationNumber 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available tothe Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual femissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Tart D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,owners or perators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section I1I.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator must complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis must be submitted to Page 4 of 10 . . COLORADO Air Pollution Control Division CDPMf Department al Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 19. 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, Part D, Sections I.C, II.B.2. and II.A.23) Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. All previous versions of this permit are cancelled upon issuance of this permit. 22. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C. f*, • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year,a change in annual actual emissions of one (1) ton per year or more or five percent,°-whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 23. 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 Page 5of10 r. 7. COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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, V.A.7.B). GENERAL TERMS AND CONDITIONS 24. 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. 25. 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. 26. 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. 27. 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. . 28. 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. 29. 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. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. Page 6 of 10 r• � COLORADO 1 Mr Pollution Control Division a. carne Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado By: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 December 4, Issued to Enerplus Resources (USA) Corporation 2019 Issuance 2 This Issuance Issued to Enerplus Resources (USA) Corporation. Updated throughput and removed NGL skid. Synthetic Minor Facility. Page 7 of 10 ar•~7,- COLORADO ' 0- - Air Pollution Control Division DP Department of PuW9c Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled, Point Pollutant CAS # Emissions Emissions (lb/yr) (ib/yr) Benzene 71432 1,692 85 Toluene 108883 1,090 54 Ethylbenzene 100414 151 8 006 Xylenes 1330207 644 32 n-Hexane 110543 9,539 477 2,2,4- 540841 0 0 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0116 0.0116 AP 42 Ch. 13.5 CO 0.0530 0.0530 VOC 9.115 0.4558 71432 Benzene 0.0141 0.0007 EEtP Tanks Page 8 of 10 . COLORADO Air Pollution Control Division CD? Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl 108883 Toluene 0.0091 0.0005 100414 Ethylbenzene 0.0013 0.0001 1330207 Xylene 0.0054 0.0003 110543 n-Hexane 0.0795 0.0040 540841 2,2,4- 0.0000 0.0000 Trimethylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call.the Division at (303)-692-3150. 7) This permit fulfills the requirement to,hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, NOx, n-Hexane {a. PSD = Synthetic Minor Source of: VOC. NANSR Synthetic Minor Source of: VOC, NOx 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.Rov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD Page 9 of 10 rx" COLORADO a . - `% [Air Pollution Control Division � Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 - - COLORADO `j'"✓ Air Pollution Control Division CDPHE Department of Pubhc Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1220 Issuance: 2 Date issued: Issued to: Enerplus Resource (USA) Corporation Facility Name: Colorado Lakes Well Pad Plant AIRS ID: 123/9FDA Physical Location: SWSW SEC 28 T8N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description Truck loadout of crude oil by LOAD1 007 submerged fill using vapor balance 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 (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 11 jeitr.L,x- COLORADO `- Air Pollution Control Division . -.0., Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Tons per Year Emission Point PM2.5 NO, VOC CO Type LOAD1 007 --- --- . 2.0 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria pollutants OR for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month anew 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 owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: Page 2 of 11 COLORADO Mr Pollution Control Division Department of Pubhc Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 50 tons per year of VOC 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants Controlled ID Point LOAD1 007 Enclosed Flare and Vapor VOC and HAP Balance 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 rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit ID Point LOAD1 007 Crude Oil Loaded 120,000 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) Page 3 of 11 . .a- COLORADO Air Pollution Control Division XI: CDPHf Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 13. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 14. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. , • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, 15. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. Page 4 of 11 i Yir 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 16. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 17. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B , be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency!of 95%. (Regulation Number 7, Part D, Section II C5.-a.(vi)) 18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes-actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 19. 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 your 0£tM 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 20. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 21. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 5 of 11 .»,M. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 22. All previous versions of this permit are cancelled upon issuance of this permit. 23. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,r 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 actualsemissions 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. 24. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 25. 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. Page 6 of 11 .,..1 COLORADO GOLORADQ `.4 Mr Pollution Control Division jii: COPHE Department of public Health FS Environment Dedicated to protecting and improving the health and environment of the people of Colorado 26. 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. 27. 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,,—: 28. 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. 29. 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 nta� and upon such occurrence, this permit must b.e 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 erm,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. 30. 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. 31. 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 Page 7 of 11 ...1 COLORADO Air Pollution Control Division CDPHE Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 December 4, Issued to Enerplus Resources (USA) Corporation 2019 Issuance 2 This Issuance Issued to Enerplus Resources (USA) Corporation Updated throughput. Page 8 of 11 at #- co�.oRano Y Air Pollution Control Division CDAH€ Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as-soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of,the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Rolnt _. Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 19 6 Toluene 108883 12 4 007 Ethylbenzene 100414 2 1 Xylenes 1330207 7 2 n-Hexane 110543 105 35 224 TMP 540841 0 0 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 11 . .1- COLORADO 7- Air Pollution Control Division EDAHE a Department of Public Health 8 Envirorrnent Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl NOx 1.10 * 10-4 10-4 1.10 * 10-4 10-4 AP-42 Ch. 13.5 CO 5.00 * 10-4 5.00 * 10' VOC 0.101 3.37 * 10-2 Benzene 71432 1.56 * 10-4 5.22 * 10-5 Toluene 108883 1.00 * 10-4 3.36 * 10-5 Ethylbenzene 100414 1.39 * 10-5 4.66 * 10 6 AP-42 Ch. 5.2, Egn 1 , Xylene 1330207 5.93 * 10-5 1.99 * 10-5 n-Hexane 110543 8.78 * 10-4 =2.94 * 10-4 224 TMP 540841 0.0 0.0 The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T -- S---=0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 3.4 psia M (vapor molecular weight) = 50 lb/lb-mot T (temperature of liquid loaded) = 530 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the ratio of each NCRP emission factor to the VOC emission factor from point 006 (Crude oil tanks) by the VOC emission factor for this point 007. Controlled emission factors are based on an overall control efficiency of 66.5% (which itself is based on a flare efficiency of 95% and a collection efficiency of 70%). 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 10 of 11 M�. COLORADO = Air Pollution Control Division DPW Department of Public 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC, NOx, n-Hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: httpx/ivANiecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A- Subpart UUUU NSPS Part 60, Appendixes Appendix A- Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z .; MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 -r.-z- COLORADO .I.4- Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE1222 Issuance: 2 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Colorado Lakes Well Pad Plant AIRS ID: 123/9FDA Physical Location: SWSW Section 28 T8N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID' Point Description Separator 010 Two 2-phase and two 3-phase separators Open flare during pipeline downtime This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 11 -- - COLORADO a "j Air Pollution Control Division ® Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type Separator 010 --- 1.0 15.4 4.7 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 11 i COLORADO 411 •Air Pollution Control Division cop HE Department of Pubitc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC _ 9. 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.) I.E.) ,`' Equipment „ AIRS Pollutants Control Device ID Point Controlled Emissions from the separators are routed to Separator 010 an open flare during times of pipeline VOC and HAP n" unavailability PROCESS,,LIMITATIONS AND RECORDS 10. 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 Process Parameter Annual Limit Point Separator 010 Natural Gas Venting 19.9 MMSCF 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. Page 3 of 11 a - COLORADO 440. Alp Mr Pollution Control Division COE' E Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 11. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described 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.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The ipenflare covered by this permit has been approved as an alternative emissions control device under,Regulation Number 7, Part D, Section II.B.2.e. The open flare must have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23, and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto- -igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 15. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must!;either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&tM) 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.) Page 4 of 11 .,,x. COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4- trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 19. 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, Part D, Sections 11.8.2. and II.A.23) Periodic Testing Requirements 20. On a semi-annual basis, the owner/operator must complete a site-specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 21. All previous versions of this permit are cancelled upon issuance of this permit. Page 5 of 11 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. 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or r 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 activity; or owner or operator of any facility, process, or enever 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. 23. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 24. 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. Page 6 of 11 raM COLORADO .Mr Pollution Control Division CDAHE Department of PubItc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. 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. 26. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 27. 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. 28. ,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. 29. 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. 30. 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 Page 7 of 11 * ..' - I COLORADO r Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 December 4, Issued to Enerplus Resources (USA) Corporation 2019 Issued to Enerplus Resources (USA) Corporation. Updated throughput, removed GTUIT NGL skid Issuance 2 This Issuance unit (point 009), open flare added as back- up/emergency control device for pipeline downtime. P t , Page 8 of 11 a - . COLORADO Air Pollution Control Division carne Department of Public Health b 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 wilt 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 jimit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice;to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Uncontrolled Controlled Equipment AIRS Pollutant CAS # Emissions Emissions ID ti 'Point (lb/yr) (lb/yr) Benzene 71432 2,979 149 Toluene 108883 2,599 130 Ethylbenzene 100414 252 13 Separator 010 Xylenes 1330207 503 25 n-Hexane 110543 12,081 604 2,2,4- 540841 548 27 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 11 COLORADO a4~0. y.1.. Air Pollution Control Division COAHt Department of Public Health ft Envirorrnent Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MM scf) (lb/MM scf) NOx 102.68 102.68 AP-42 Ch. 13.5 CO 468.01 468.01 VOC 30,909 1,545.45 71432 Benzene 149.63 7.48 108883 Toluene 130.57 6.53 100414 Ethylbenzene 12.65 0.63 1330207 Xylene 25.29 1.26 Mass Balance 110543 n-Hexane 606.86 30.34 2,2,4- 540841 27.54 1.38 Trimethylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on the worst-case gas parameters (VOC%, HAP%, Heat Content, MW, and Individual HAP:HAP% ratios) from the results of extended gas analyses for gases sampled from the Barton Mills and Cherry Creek Welts. The Barton Mills gas was sampled on 9/7/2018 at a pressure of 78 psig and a temperature of 104.7°F, and was analyzed on,9/12/2018 by Zedi US Inc. The Cherry Creek Well gas was sampled on 9/7/2018 at a pressure of 82 psig and a temperature of 99.1°F, and was analyzed on 9/12/2018 by Zedi US Inc. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, NOx, n-Hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx Page 10 of 11 R»,1. COLORADO 410,,, All .Air Pollution Control Division CDPHE. Department of Pubic Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 6-3.8980-End Subpart NNNNN -Subpart XXXXXX tE.ff,' Page 11 of 11 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: _yen Fischbach Package #: X22899 Received Date: 2/10/2019 Review Start Date: 3/17/2020 Section 01 - Facility Information Company Name: Enerplus Resources (USA) Corporation Quadrant Section Township Range County AIRS ID: 123 SWSW 28 8N 67 Plant AIRS ID: 9FDA Facility Name: Colorado Lakes Well Pad Physical Address/Location: SWSW quadrant of Section 28, Township 8N, Range 67W County: Weld County Type of Facility: Exploration & Production Welt Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use On y 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 # Required? Remarks has already assigned) assigned) Permit NOS areviousiy Produced Water Tank PRD-WTR 18WE1218 Modification subrritted Permit 006 Crude Oil Tank TANKS Yes 18WE1219 Modification No NOS on file Permit 007 Liquid Loading LOAD1 Yes 18WE1220 Modification No NOS on file Permit 010 Separator Ventin - SEPARATOR Y`5: 18WE1222 Modificatio No NOS on file Section 03 - Description of Project Applicant proposes the removal of NGL skid, updating of permitted throughputs, and addition of an open flare for emergency control of separator gas durirg pipeline downtime. Self-certification of original permit issuances not yet completed, so self-cert and initial compliance testing conditions will carry over into second issuances. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis 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? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) J-' ► `� . Non-Attainment New Source Review (NANSR) J I Is this stationary source a major source? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR) Produced Water Storage Tank(s) Emissions Inventory Section 01 - Administrative Information Facility AIRS ID: 1 045 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Two (2) 400 bbl Produced Water Tanks Description: Emission Control Device ECD Description: Requested Overall VOC & HAP Control Efficiency %: 0- Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Barrels (bbl) per year Requested Permit Limit Throughput = 80,000 Barrels (bbl) per year Requested Monthly Throughput = 6795 Barrels (bbl) per mcnth Potential to Emit (PTE) Produced Water Throughput = 80,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2112.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 36.0 scf/bbl Actual heat content of waste gas routed to combustion device = 0.0 MMBTU per year Requested heat content of waste gas routed to combustion device = 6082.6 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 6082.6 MMBTU per year Control Device Pilot Fuel Use Rate: scfh 0.00 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) VOC 0.2620 1.31E-02 Benzene 0.0070 3.50E-04 E'a,.;;, c.N.: vs, .. x ,.... ,...w,: ,) ,i. :.., Toluene 0.0000 , . SS' e . c !A•��A '�!(4. O � .fA �t,al\4 J 3f W • k• 0 k;. Ethylbenzene 0.0(100 ,L: . , • ,c ° °'• �' ' '§ n,,.- o 431 Xylene 0.0000waeF � . ' O ' n-Hexane 1.10E-03 -,--,-4°:•-r,:01 i41 d .rt 14 ! r tZ j,. n:1-13,1 s . 224 TMP 0.0000 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 0.00000 PM2.5 0.00000 NOx 0.06800 5.17E-03 .AP-42 Chapter 133 is t#ustnai flares 7NOx) CO 0.31000 2.36E-02 . • ' r ' r, Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 PM2.5 0.0000 N O x 0.0680 0.0000 CO 0.3100 0.0000 Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 10.5 0.0 0.0 10.5 0.5 89.0 _ 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 0.2 0.0 0.0 0.21 0.21 35.1 _ CO 0.9 0.0 0.0 0.94 0.94 160.1 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 560.0 0.0 0.0 560.0 28.0 Toluene 0.0 0.0 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 1760.0 0.0 0.0 1760.0 88.0 224 TMP 0.0 0.0 0.0 _ 0.0 0.0 2 of 6 K:\PA\2018\18WE1218.CP2 Produced Water Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage Tank is not subject to MPS 0000a (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes NGL skid (from initial issuance) has been removed from facility, and all tank emissions are now routed directly to flare. While state default emission factor and GOR are used, operator chose to use site-specific heat content. This results in more conservative calculations and is acceptable. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # 5CC Code Pollutant Factor Control % Units 005 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses PM10 0.0000 0.0 lb/1,000 gallons liquid throughput PM2.5 0.0000 0.0 lb/1,000 gallons liquid throughput NOx 0.1231 0.0 lb/1,000 gallons liquid throughput VOC 6.2381 '35.0 lb/1,000 gallons liquid throughput CO 0.5612 0.0 lb/1,000 gallons liquid throughput Benzene 0.1667 95.0 lb/1,000 gallons liquid throughput Toluene 0.0000 95.0 lb/1,000 gallons liquid throughput Ethylbenzene 0.0000 '35.0 lb/1,000 gallons liquid throughput Xylene 0.0000 95.0 lb/1,000 gallons liquid throughput n-Hexane 0.5238 95.0 Ib/1,000 gallons liquid throughput 224 TMP 0.0000 95.0 lb/1,000 gallons liquid throughput 3 of 6 K:\PA\2018\18WE1218.CP2 Produced Water Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Requires an AP 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) No Go to next question 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Source Requires a perr Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? No Continue - You have in 2. Is this produced water storage tank` located at an oil and gas exploration and production operation , well production facility', natural gas compressor station'or natural gas processing plant? Yes Continue - You have in 3. Is this produced water storage tank a fixed roof storage tank? Yea Go to the next questio 4. Are uncontrolled actual emissions`of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to pa Storage tank is subject to Regulation 7, Section XVII, B. C.1 & 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 XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. }i. Source is subject to all Storage tank is subject to Regulation 7, Section XVII.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 Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) [-472 BBLs]? Storage Tank is not sul 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 [-10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.11lb? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"5 as defined in 60.111b? 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 [^'29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 O950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 ['472 BBL] but less than 151 m3 (-950 BBL] and stores a liquid with a maximum true vapor pressure6 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 greater than or equal to 151 m3 ("950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. The design capacity is greater than or equal to 75 M3 [^'472 BBL] but less than 151 m3 [-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 subject to NSPS Kb 40 CFR, Part 60, Subpart OOOO/O000a, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Continue You have in 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? Storage Tank is not sul 3. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? _ Go to the next questio 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? Storage Tank is not sul 5. Does this produced water 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 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS 0000a [Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO/OOOOa per RACT Review RAG review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the Language of this document and the language of the Clean Ar 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 "recomrr end, " "may, " "should,"and scan, "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 Enerplus Resources (USA) Corporation County AIRS ID 123 History File Edit Date 4/2/2020 Plant AIRS ID 9FDA Ozone Status Non-Attainment Facility Name Colorado Lakes Well 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 0.7 0.7 0.0 0.6 109.3 875.9 0.2 102.5 18.1 0.7 0.7 0.0 0.7 8.7 50.2 0 2 23.6 1 .9 Previous Totals from November 2019 Tab Previous Permitted Facility total 0.7 0.7 0.0 0.6 109.0 875.9 0.0 102.3 18.1 0.7 0.7 0.0 0.7 8.4 50.2 0.0 27.4 1.9 001 18WE1214 RICE 106 HP 0.1 0.1 0.0 13.1 0.7 22.0 0.0 0.1 0.1 0.1 1 .0 0 7 2.1 0.0 Point updated on 02/13/2020. Data NOT reviewed 002 18WE1215 RICE 203 HP 0.2 0.2 0.2 31 .0 1 .4 20.6 0.4 0.2 0.2 0.2 2.0 1 4 3.9 0.4 Point updated on 02/13/2020. Data NOT reviewed 003 18WE1216 RICE 106 HP 0.2 0.2 0.2 32.5 1 .4 32.5 0.5 0.2 0.2 0.2 2.0 1 .4 3.9 0.2 Point updated on 02/13/2020. Data NOT revie'A'ed 004 18WE1217.CN RICE 550 HP 0.0 0.0 005 18W E1218 Two 400 barrel produced water tanks 0.2 10.5 1 .0 1 .2 0.2 0.5 1 .0 0.1 Point updated and reviewed on 04/02/2020 006 18WE1219 Six 400 barrel crude oil tanks 0.7 546.9 3.1 6.6 0.7 27.4 3.1 0.3 Point updated and reviewed on 04/02/2020 007 18WE1220 Loadout 6.0 0.1 2.0 0.0 Point updated and reviewed on 04/02/2020 008 18WE1221.CN NGL plant fugitives 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 009 18WE1222.CN NGL 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 010 18WE1222 Separators 1 .0 307.60 4.7 9 2 1 .0 15.40 4.7 0.5 Point updated and reviewed on 04/02/2020 011 18WE1223.CN RICE 550 HP 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 012 GP02.CN Caterpillar 4SRB 203 hp, Model 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. G3306TA, SN G6X02571 XP H T Rs-TRTs 0.000 0.000 0.3 0.0 0.2 0.0 0.000 0.000 0.3 0.0 0.2 0.0 XP Loadout 0.00 0.0 0.00 0.0 XP Fugitives 0.2 0.0 0.2 0.0 FACILITY TOTAL 0.5 0.5 0.0 0.4 78.8 874.5 0.2 84.1 17.8 0.5 0.5 0.0 0.5 7.2 48.8 0.2 18.9 1.5 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: Syn Minor n-Hexane HH: Area 7777: Area Permitted Facility Total 0.5 0.5 0.0 0.4 78.5 874.5 0.0 83.9 17.8 0.5 0.5 0.0 0.5 6.9 48.8 0.0 18.7 1.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.2 -0.2 0.0 -0.2 -1.5 -1.4 0.0 -1.7 Pubcom required as this permitting project requests new synthetic minor permit limits wrt to re-designation thresholds Total VOC Facility Emissions (point and fugitive) 49.0 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) -1.4 Project emissions less than 25/50 tpy Note 1 'pints 001 , 002. and 003 we-e previously updated using form APCD-102 provided by operator. Data has not yet been reviewed by an engineer. Note 2 Page S of 6 Printed 4/23/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Enerplus Resources (USA) Corporation County AIRS ID 123 Plant AIRS ID 9FDA Facility Name Colorado Lakes Well Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description ronna:denyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL (tny) (Previous FACILITY TOTAL 1.7 0.0 0.0 6.2 4.2 0.4 1.2 26.5 0.0 0.6 0 0 40.8 001 18WE1214 RICE 106 HP 0.0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 980 0.5 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 560 1760 1 .2 006 18WE1219 Six 400 barrel crude oil tanks 1692 1090 644 9540 6.6 007 18WE1220 Loadout 0.1 008 18WE1221 .CN NGL plant fugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 2979 2599 252 503 12081 9.2 011 18WE1223.CN RICE 550 HP 0.0 012 GP02.CN Caterpillar 4SRB 203 hp, Model G3306TA, 0.0 SN G6X02571 XP HTRs-TRTs 0.0 XP Loadout 0.0 XP Fugitives 0.0 TOTAL (tpy) 0.8 0.0 0.0 2.6 1.9 0.2 0.6 11.7 0.0 0.0 0.0 0.0 17.8 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description FornaWdehyhe Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) (Previous FACILITY TOTAL 0.9 0.0 0.0 0.4 0.3 0.0 0.1 1.7 0.0 0.0 0 0 3.4 001 18WE1214 RICE 106 HP 0.0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 490 0.2 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 28 88 0.1 006 18WE1219 Six 400 barrel crude oil tanks I 85 54 32 477 0.3 007 18WE1220 Loadout . ' 0.0 008 18WE1221 .CN NGL plant fugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 149 130 13 25 604 0.5 011 18WE1223.CN RICE 550 HP 0.0 012 GP02.CN Caterpillar 4SRB 203 hp, Model G3306TA, 0.0 SN G6X02571 XP HTRs-TRTs 0.0 XP Loadout 0.0 XP Fugitives 0.0 TOTAL (tpy) 0.6 0.0 0.0 0.1 0.1 0.0 0.0 0.6 0.0 0.0 0.0 0.0 1.5 6 18WE1218.CP2 4/23/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: _sen Fischbach Package 44: 122899 Received Date: 12/10/2019 Review Start Date: 3/17/2020 Section 01 - Facility Information Company Name: Enerplus Resources (USA) Corporation Quadrant Section Township Range County AIRS ID: 123 SWSWL. Plant AIRS ID: 9FDA Facility Name: Colorado Lakes Well Pad Physical Address/Location: SWSW quadrant of Section 28, Township 8N, Range 67W County: Weld County Type of Facility: Exploration & Production 's .teii Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only 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 # Required? F.emarks has already assigned) assigned) Permit NOS orevious: Produced Water Tank PRD-WTR 18WE1218 Modificatie subrritted Permit Crude Oil Tank TANKS 18WE1219 Modification No NOS on file Permit Liquid Loading LOAD1 18WE1220 Modification No NOS on file Permit Separator Venting SEPARATOR. • 18WE1222 Modification No NOS on file Section 03 - Description of Project Applicant proposes the removal of NGL skid, updating of permitted throughputs, and addition of an open flare for emergency control of separator gas durirg pipeline downtime. Self-certification of original permit issuances not yet completed, so self-cert and initial compliance testing conditions will carry over into second issuances. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? • Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) �_-.. ✓ Title V Operating Permits (OP) Jwaw . • . D Non-Attainment New Source Review (NANSR) J J Is this stationary source a major source? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) • . Non-Attainment New Source Review (NANSR) Crude Oil Storage Tank(s) Emissions Inventory Section 01 - Administrative Irformation ., z " 006 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit T Six (6) 400 bbl Crude Oil Tanks Description: Emission Control Device ECD Description: Requested Overall VOC & HAP Control Efficiency %: 95.0 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = Barrels (bbl) per year Requested Permit Limit Throughput = 12000'0.C Barrels (bbl) per year Requested Monthly Throughput = 10191.8 Barrels (bbl) per month Potential to Emit (PTE) Throughput = 120000.0 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2112.0 Btu/scf Weighted Average of well-specific Efs (see Technical Analysis notes below). Volume of waste gas emitted per BBL of liquids produced = 79.2 scf/bbl Weighted Average of well-specific Efs (see Technical Analysis notes below). Actual heat content of waste gas routed to combustion device = 0.0 MMBTU per year Requested heat content of waste gas routed to combustion device = 20,067.4 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 20,067.4 MMBTU per year Control Device Pilot Fuel Use Rate: 33 scfh 0.3 MMscf/yr Pilot Fuel Gas Heating Value: 1510 Btu/scf 136.5 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? _rs Emission Factors Crude Oil Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Crude Oil (Crude Oil Throughput) Throughput) VOC 9.1150 0.455S e. .?pa iffc E , l ileldt A- h ' Verified Benzene 0.0141 0.0007 to Specific €.Fc {er:cluci '') ftc,,.:,) Verified Toluene 0.0091 0.0005 "ate Sped"s. E.F. (fru:ft:4es flash) Verified Ethylbenzene 0.0013 0.0001 . e Specific E,-_ (includes flasf t Verified Xylene 0.0054 0 0003 Sate Specifi E.F.'(inc odes ffai. ` := Verified n-Hexane 0.0795 0.0040 Site -dfi: E.F. rirch°dectb..; . Verified 224 TMP 0.0000 0.0000 Verified Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Waste Heat (Crude Oil Combusted) Throughput) PM10 0.0000 PM2.5 0.0000 Combined Pilot + Emissions Combustion Factors NOx 0.0680 0.0114 0.0116 CO 0.3100 0.0518 -F:2'4tt'i_airter.3.U4 i adt tri0i.i Ares (c ; ; 0.0530 Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) PM10 0.0000 PM2.5 0.0000 NOx 0.0680 102.6800 CO 0.3100 468.1000 'CO. Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 546.9 0.0 0.0 546.90 27.35 4644.9 _ 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 0.7 0.0 0.0 0.70 0.70 118.4 CO 3.2 0.1 0.1 3.18 3.18 539.8 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 1691.5 0.0 0.0 1692 85 Toluene 1089.6 0.0 0.0 1090 54 Ethylbenzene 150.9 0.0 0.0 151 8 Xylene 643.9 0.0 0.0 644 32 n-Hexane 9538.8 0.0 0.0 9539 477 224 TMP 0.0 0.0 0.0 0 0 2 of 6 K:\PA\2018\18WE1219.CP2 Crude Oil Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? ."zt', ', If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes - e > _ ..,awr w..'e-k " Y•,a•.•, ."&wY•.vu.rr_.v.•!u. Kee-naYPHH.n nr .'% are•w••,a.a&*C.0 t—.N•.Rx+v.<+•#e•w .. .•••.:.. •.•,C,••••••••«.y.•.n... -... - _.,.n ..rGw,eve.t _.•y+N!•!Nr5+w{r•F•r.& !r+•• •nn.p•Cwc+n..o•RNs••,••..w-yv.••:+e!N,w•'rehP—t'e*...s...... ...... ... ,.. .., tea . _ .. . Site-specific emission factors carried over from previous issuance of this permit. Original emission factors are based on a weighted average of two well-specific emission factors developed for the two wells which feed into this facility. Well-specific factors were based on E&P Tanks models which were specified based on pressurized liquid samples from each well, and initial production/throughput data. Throughput data and ratio between wells was also used in weighted average calculation, which averaged the respective emission factors based on the initial throughput of each well. At time of this modification, initial testing condition has not been met, and this condition will be retained in the next issuance. NGL skid (from initial issuance) has been removed from facility, and all tank emissions are now routed directly to flare. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 01 Fis4ti Roof 1'' ; ,� ; PM10 0.00 0 lb/1,000 gallons crude oil throughput PM2.5 0.00 0 lb/1,000 gallons crude oil throughput NOx 0/8 0 lb/1,000 gallons crude oil throughput VOC 217.0 95 lb/1,000 gallons crude oil throughput CO 1.26 0 Ib/1,000 gallons crude oil throughput Benzene 0.34 95 lb/1,000 gallons crude oil throughput Toluene 0.22 95 lb/1,000 gallons crude oil throughput Ethylbenzene 0.03 95 lb/1,000 gallons crude oil throughput Xylene 0.13 95 lb/1,000 gallons crude oil throughput n-Hexane 1.89 95 lb/1,000 gallons crude oil throughput 224 TMP 0.00 95 lb/1,000 gallons crude oil throughput 3 of 6 K:\PA\2018\18WE1219.CP2 Crude Oil Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 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 to #2 is yes, is the crude oil storage tank capacity less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yee, have indicated that source is in the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? t';=5 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 next question 2a. If answer to $12 is yes, is the crude oil storage tank capacity less than 40,000 gallons per year? No Go to next question 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? YL-s Source Requires a pert Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? No Continue - You have in 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station) or natural gas processing plant? ,Y:,s Continue - You have in 3. Is this crude oil storage tank a fixed roof storage tank? Y_:> Go to the next questio 4. Are uncontrolled actual emissions'of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to pa Storage tank is subject to Regulation 7, Section XVII, B, C.1 & 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 XVII.C.3 - Recordkeeping Requirements 5. Does the crude ail storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Source is subject to all Storage tank is subject to Regulation 7, Section XVII.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 Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) [^'472 BBLs]? No Storage Tank is not sut 2. Does the storage vessel meet the following exemption in 60.11lb(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer'' as defined in 60.11_b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b? 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 ["'29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 [-950 BBL] and stores a liquid with a maximum true vapor pressure& less than 3.5 kPa (60.11ob(b))?; or c. The design capacity is greater than or equal to 75 M3 [-472 BBL] but less than 151 m3 ( 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 greater than or equal to 151 m3 ["'950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or �^ b. The design capacity is greater than or equal to 75 M3 ["472 BBL] but less than 151 m3 ("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? Stc:rage Tank is not subject to NSPS Kb 40 CFR, Part 60, Subpart OOOO/OOOOa, 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? Y -s Continue - You have in 2. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? No Storage Tank is not sut 3. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? Yes Go to the next questio 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not sun 5. Does 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 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Link is not subject to NSPS 0000a [Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO/OOOOa per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: Continue - You have in a. A facility that processes, upgrades or stores hydrocarbon liquids (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.260(a)(3))? 1. Is the tank located at a facility that is major3 for HAPs? No Storage Tank is not sui 3. Does the tank meet the definition of "storage vessel"' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Storage Tank is not subject to P.A ACT 1-i Et Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act., its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend. " "may. " "should,''and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requrements 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 Enerplus Resources (USA) Corporation County AIRS ID 123 History File Edit Date 4/2/2020 Plant AIRS ID 9FDA Ozone Status Non-Attainment Facility Name Colorado Lakes Well 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 S02 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.7 0.7 0.0 0.6 109.3 875.9 0.2 , 102.5 18.1 0.7 0.7 0.0 0.7 8.7 50.2 0.2 216 1 .9 Previous Totals from November 2019 Tab Previous Permitted Facility total 0.7 0.7 0.0 0.6 109.0 875.9 0.0 102.3 18. 1 0.7 0.7 0.0 0.7 8.4 50.2 0.0 20.4 1.9 001 18WE1214 RICE 106 HP 0.1 0.1 0.0 13.1 0.7 22.0 0.0 0.1 0.1 0.1 1 0 0.7 2.1 0.0 Point updated on 02/112020. Data NOT reviewed 002 18WE1215 RICE 203 HP 0.2 0.2 0.2 31 .0 1 .4 20.6 0.4 0.2 0.2 0.2 2.0 1 .4 3.9 0.4 Point updated on 02/13/2020. Data NOT reviewed 003 18WE1216 RICE 106 HP 0.2 0.2 0.2 32.5 1 .4 32.5 0.5 0.2 0.2 0.2 2.0 1 .4 3.9 0.2 Point updated on 02/13/2020. Data NOT reviewed 004 18WE1217.CN RICE 550 HP 0.0 0.0 005 18WE1218 Two 400 barrel produced water tanks 0.2 10.5 1 .0 1 .2 0.2 0.5 1 .0 0.1 Point updated and reviewed on 04/02/2020 006 18WE1219 Six 400 barrel crude oil tanks 0.7 546.9 3.1 6.6 0.7 27.4 3.1 0.3 Point updated and reviewed on 04/02/2020 007 18WE1220 Loadout 6.0 0.1 2.0 0.0 Point updated and reviewed on 04/02/2020 008 18WE1221.CN NGL plant fugitives 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 009 18WE1222.CN NGL 0 0 0.0 Cancellation received 12/10/2019 - no longer exists. 010 18WE1222 Separators 1 .0 307.60 4 7 9.2 1 .0 15.40 4.7 0.5 Point updated and reviewed on 04/02/2020 011 18WE1223.CN RICE 550 HP 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 012 GP02.CN Caterpillar 4SRB 203 hp, Model 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. G3306TA, SN G6X02571 XP HTRs-TRTs 0.000 0.000 0.3 0.0 0.2 0.0 0.000_ 0.000 0.3 0.0 0.2 0.0 XP Loadout 0.00 0.0 0.00 0.0 XP Fugitives 0.2 0.0 0.2 0.0 FACILITY TOTAL 0.5 0.5 0.0 0.4 78.8 874.5 0.2 84.1 17.8 0.5 0.5 0.0 0.5 7.2 48.8 0.2 18.9 1.5 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: Syn Minor n-Hexane HH: Area 7777: Area Permitted Facility Total 0.5 0.5 0.0 0.4 78.5 874.5 0.0 83.9 17.8 0.5 0.5 0.0 0.5 6.9 48.8 0.0 18.7 1.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.2 -0.2 0.0 -0.2 -1.5 -1.4 0.0 -1.7 Pubcom required as this permitting project requests new synthetic minor permit limits wrt to re-designation thresholds Total VOC Facility Emissions (point and fugitive) 49.0 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) -1.4 Project emissions less than 25/50 tpv Note 1 ",Joints 001, 002, and 003 were previously updated using form APCD-102 provided by operator. Data has not vet been reviewed by an engineer. Note 2 Page 5 of 6 Printed 4/23/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Enerplus Resources (USA) Corporation County AIRS ID 123 Plant AIRS ID 9FDA Facility Name Colorado Lakes Well 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 1.7 0.0 0.0 6.2 4.2 0.4 1.2 26.5 0.0 0.6 0 0 40.8 001 18WE1214 RICE 106 HP 0.0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 980 0.5 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 560 1760 1 .2 006 18WE1219 Six 400 barrel crude oil tanks 1692 1090 644 9540 6.6 007 18WE1220 Loadout 0.1 008 18WE1221 .CN NGL plant fugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 2979 2599 252 503 12081 9.2 011 18WE1223.CN RICE 550 HP 0.0 012 GP02.CN Caterpillar 4SRB 203 hp, Model G3306TA, 0.0 SN G6X02571 XP HTRs-TRTs 0.0 XP Loadout 0.0 XP Fugitives 0.0 TOTAL (tpy) 0.8 0.0 0.0 2.6 1.9 0.2 0.6 11.7 0.0 0.0 0.0 0.0 17.8 `Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text uncontrolled emissions < de minimus Emissions with controls lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethyibenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) (Previous FACILITY TOTAL 0.9 0.0 0.0 0.4 0.3 0.0 0.1 1.7 0.0 0.0 0 0 3.4 001 18WE1214 RICE 106 HP 0.0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 490 i 0.2 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 28 88 0. 1 006 18WE1219 Six 400 barrel crude oil tanks 85 54 • 32 477 0.3 007 18WE1220 Loadout 0.0 008 18WE1221.CN NGL plant fugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 149 130 13 25 604 0.5 011 18WE1223.CN RICE 55C HP 0.0 012 GP02.CN Caterpillar 4SRB 203 hp, Model G3306TA, 0.0 SN G6X02571 XP HTRs-TRTs 0.0 XP Loadout 0.0 XP Fugitives 0.0 TOTAL (tpy) 0.6 0.0 0.0 0.1 0.1 0.0 0.0 0.6 0.0 0.0 0.0 0.0 1 .5 6 18WE1219.CP2 4/23/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: 3en Fischbach Package U: 422899 Received Date: 12/10/2019 Review Start Date: 3/17/2020 Section 01 - Facility Information Company Name: Enerplus Resources (USA) Corporation Quadrant Section Township Range County AIRS ID: 123 " `. _ 67 Plant AIRS ID: 9FDA Facility Name: Colorado Lakes Well Pad Physical Address/Location: SWSW quadrant of Section 28, Township 8N, Range 67W County: Weld County Type of Facility: Expior: t on & Production Well Pao What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only 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 # Required? Remarks has already assigned) assigned) Permit NOS previously 005 Produced W: ter Tank PRD-WTR 18WE1218 Modificatic' submitted Permit 006 Crude Oil Tank TANKS 18WE1219 Modificatic: No NOS on file Permit 007 Liquid Loading LOAD.1 18WE1220 Modification No NOS on file Permit 010 Separator Ve nt ng SEPARATOR 18WE1222 Modification No NOS on file Section 03 - Description of Project Applicant proposes the removal of NGL skid, updating of permitted throughputs, and addition of an open flare for emergency control of separator gas during pipeline downtime. Self-certification of original permit issuances not yet completed, so self-cert and initial compliance testing conditions will carry over into second issuances. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Ye If yes, why? Requesting Synthetic Minor Permit 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? ': Is this stationary source a synthetic minor? : If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ►�. J . J Non-Attainment New Source Review (NANSR) J Is this stationary source a major source? If yes, indicate programs End which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) I ■ . . Non-Attainment New Source Review (NANSR) Hydrocarbon Loadout Emissions Inventory Section 01 - Administrative Information Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Truck loadout of crude oil Description: Emission Control Device Vapor Balance and ECG Description: • Is this loadout controlled? Requested Overall VOC & HAP Control Efficiency %: 66.5 70% Collection efficiency claimed Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Barrels (bbl) per year Requested Permit Limit Throughput = 120,000 Barrels (bbl) per year Requested Monthly Throughput = 1:11 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 120,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2112 Btu/scf Actual Volume of waste gas emitted per year = 0 scf/year Requested Volume of waste gas emitted per year = 91610 scf/year Actual heat content of waste gas routed to combustion device = 0 MMBTU per year Requested heat content of waste gas routed to combustion device = 193 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 193 MMBTU per year Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? No Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Akt.i..54,X41,as The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Loading Loss Equation L = 12.46*S*P*M/T Factor Meaning Value Units Source 5 Saturation Factor 0.6 "����' %g,, "j; AP-42 Chapter 5,2 Table 5.24 Submerged Loading:g: Dedicated Normal Service (St-4_f; • P True Vapor Pressure 3.4 psia AP-42 Chapter 7 Table 7.1-2 (Crude Oil RVP = 5 @ 70F) M Molecular Weight of Vapors 50 Ib/Ib-mol AP-42 Chapter 7 Table 7.1-2 [Crude Oil RVP = 5 @ 70F) Stabilized oil samples from each well show RVP values below T Liquid Temperature 530 Rankine AP-42 Chapter 7 Table 7.1-2 (Crude Oil RVP = S @ 70F) 3, making RVP = 5 a conservative and acceptable basis for L Loading Losses 2.397962264 lb/1000 gallons loading loss calculations. 0.100714415 lb/bbl Crude Oil Tank Factors Component Mass Fraction Emission Factor Units Source VOC 9.115 Benzene 0.001546901 0.000155795 lb/bbl Ratio of Bz:VOC Emission Factors Benzene 0.0141 Toluene 0.00099616 0.000100328 ,lb/bbl Ratio of Tol:VOC Emission Factors Toluene 0.00908 Ethylbenzene 0.000138234 1.39221E-05 lb/bbl Ratio of EB:VOC Emission Factors Ethylbenzene 0.00126 Xylene 0.000589139 5.93348E-05 lb/bbl Ratio of X:VOC Emission Factors Xylene 0.00537 n-Hexane 0.008721887 0.000878.42 lb/bbl Ratio of n-Hex:VOC Emission Factors n-Hexane 0.0795 224 TMP 0 0 lb/bbl Ratio of 224:VOC Emission Factors 224 TMP 0 Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 1.01E-01 3.37E-02 Site .:> , ::. ; : - .,M' 42: Chat s 5.2, Equation Benzene 1.56E-04 5.22E-OS SUS+ SoSpedirit - AP s2: Chapter 5.2, Equation 1 Toluene 1.00E-04 3.36E-0S {,tr 5 ecThc _\P-42, Chapter 5,2, Equation I Ethylbenzene 1.39E-05 4.66E-06 Sfty ; ec f c AP-z2: Chapter Si, Equation 1 Xylene 5.93E-05 1.99E-0S Site. S :<o r ;_ - ,AP -2; Chanter 5.2, Eq:mticn 1 n-Hexane 3.78E-04 2.94E-04 S t ? Specific: - Chapter 5.2,. Equation i. 224 TMP 0.00E-00 0.00E+00 S a" :. : ; .c - AP-42:2:. iaprer 51, E gidattwm b Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.00E+00 PM2.5 0.00E+00 SOx 0.00E+00 NOx 0.0630 1.10E-04 AP-4.2 Chapter 133 lodtts to Flares [I"+lOxf CO 0.3100 5.00E-04 >"P-42'C 3oferr13,5Indlsstx # Ffarses CO( r Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM 10 0.0000 PM2.5 0.0000 SOx 0.0000 NOx 0.0000 CO 0.0000 2 of 6 K:\PA\2018\18WE1220.CP2 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.00 0.00 0.00 0.00 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 0.01 0.00 0.00 0.01 0.01 1 VOC 6.04 0.00 0.00 6.04 2.02 344 CO 0.03 0.00 0.00 0.03 0.03 5 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (Ib≤/year) (lbs/year) Benzene 19 0 0 19 6 Toluene 12 0 0 12 4 Ethylbenzene 2 0 0 2 1 Xylene 7 0 0 7 2 n-Hexane 105 0 0 105 35 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must be operated with submerged fill to satisfy RACT. (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 Stabilized oil samples from each well show RVP values below 3, making RVP = 5 a conservative and acceptable basis for loading loss calculations. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process #i SCC Code Pollutant Factor Control % Units 007 01 4.06-001 -32 Crude Oil: Submerged Loading Normal Service (5=0.6) PM10 0.00 0 lb/1,00J gallons transferred PM2.5 0.00 0 Ib/1,00J gallons transferred SOx 0.00 0 lb/1,00J gallons transferred NOx 0.00 0 lb/1,00J gallons transferred VOC 2.4 67 lb/1,00J gallons transferred CO 0.01 0 lb/1,003 gallons transferred Benzene 0.00 67 Ib/1,00J gallons transferred Toluene 0.00 67 lb/1,00J gallons transferred Ethylbenzene 0.00 67 lb/1,00J gallons transferred Xylene 0.00 67 lb/1,00J gallons transferred n-Hexane 0.02 67 lb/1,00J gallons transferred 224 TMP 0.00 67 lb/1,00J gallons transferred 3 of 6 K:\PA\2018\18WE1220.CP2 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 Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.O.1.1)? 11 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section Il.D.1.a)? Yes Go to next 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.O.1.1)? Yes Go to the n 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No Go to next • 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next S. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Pan B, Section II.D.2)? Yes The loadou Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulatior 3, Part B, Section III.D.2.a)? No The loadou The loadout must be operated with submerged fill to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change Dr substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend. " "may," "should."and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Enerplus Resources (USA) Corporation County AIRS ID 123 History File Edit Date 4i2/2020 Plant AIRS ID 9FDA Ozone Status Non-Attainment Facility Name Colorado Lakes Well 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 0.7 0.7 0.0 0.6 109.3 875.9 0.2 102.5 18.1 0.7 0.7 0.0 0.7 8.7 50.2 0.2 20.6 1.9 Previous Totals from November 2019 Tat. Previous Permitted Facility total 0.7 0.7 0.0 0.6 109.0 875.9 0.0 , 102.3 18. 1 0.7 0.7 0.0 0.7 8 4 50.2 0.0 20.4 1.9 001 18WE1214 RICE 106 HP 0.1 0 1 0.0 13.1 C .7 i 22.0 0.0 0 1 0 1 0.1 1 0 0.7 2.1 0.0 Point updated on 02/112020. Data NOT reviewed _ 002 18W E1215 RICE 203 HP 0.2 0.2 0.2 31 .0 1 .4 20 6 0 4 0.2 0 2 0 2 2 0 1 4 3.9 0.4 Point updated on 02/13/2020. Data NOT reviewed 003 18WE1216 RICE 106 HP 0.2 0.2 0.2 32.5 1.4 32.5 0.5 0 2 0 2 0.2 2 0 1.4 3.9 0.2 Point updated on 02/132020. Data NOT rev1/2 tied 004 18WE1217.CN RICE 550 HP 0.0 0.0 005 18WE1218 Two 400 barrel produced water tanks 0.2 1C.5 1 .0 1.2 0.2 0.5 1 .0 0.1 Point updated and reviewed on 04/02/2020 006 18WE1219 Six 400 barrel crude oil tanks 0.7 54E.9 3.1 6.6 0.7 27.4 3.1 0.3 Point updated and reviewed on 04/02/2020 007 18WE1220 Loadout E.0 0.1 2.0 0.0 Point updated and reviewed on 04/02/2020 008 18WE1221.CN NGL plant fugitives 0.0 , 0.0 Cancellation received 12/10/2019 - no longer exists. 009 18WE1222.CN NGL 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 010 18WE1222 Separators 1 .0 307.60 4.7 9.2 1 0 15 40 4.7 0.5 Point updated and reviewed on 04/02/2020 011 18WE1223.CN RICE 550 HP _ 0.0 0.0 Cancellation received 12/10/2019 - no lonq_er exists. 012 GP02.CN Caterpillar 4SRB 203 hp. Model 0.0 0.0 Cancellation received 12/10/2019 - no longer exists G3306TA. SN G6X02571 XP F-ifRs-TRTs 0.000 0.000 0.3 C.0 0.2 0 0_ 0 000 0 000 0.3 0.0 0.2 0.0 XP Loadout 0.00 0 0 - 0 00 0.0 XP Fugitives 0 2 0.0 0 2 0.0 FACILITY TOTAL 0.5 0.5 0.0 0.4 78.8 874.5 0.2 84.1 17.8 0.5 0.5 0.0 0.5 7.2 48.8 0.2 18.9 1.5 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: Syn Minor n-Hexane HH: Area 7777: Area Permitted Facility Total 0.5 0.5 0.0 0.4 78.5 874.5 0.0 83.9 , 17.8 0.5 0.5 0.0 0.5 6.9 48.8 0.0 18 7 1 5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.2 -0.2 0.0 -0.2 -1.5 -1.4 0.0 -1 7 Pubcom required as this permitting project requests new synthetic minor permit limits wrt to re-designation thresholds Total VOC Facility Emissions (point and fugitive) 49.0 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) - 1 4 _Project emissions less than 25/50 tpy Note 1 points 001, 002, and 003 were previously updated using form APCD-102 provided by operator. Data has not yet been reviewed by an engineer Note 2 Page S of 6 Printed 4/23/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Enerplus Resources (USA) Corporation County AIRS ID 123 Plant AIRS ID 9FDA Facility Name Coloradc Lakes Well 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 1.7 0.0 0.0 6.2 4.2 0.4 1.2 26.5 0.0 0.6 0 0 40.8 001 18WE1214 RICE 106 HP 0.0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 980 0 5 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 560 1760 1 .2 006 18WE1219 Six 400 barrel crude oil tanks 1692 1090 ._ 644 9540 6.6 007 18WE1220 Loadout 1 .;: '.2 7 0.1 008 18WE1221 .CN NGL plant fugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 2979 2599 252 503 12081 9.2 011 18WE1223.CN RICE 550 HP 0.0 012 GP02.CN Caterpillar 4SRB 203 hp, Model G3306TA, 0.0 SN G6X02571 XP HTRs-TRTs 0.0 XP Loadout 0.0 XP Fugitives 0.0 TOTAL (tpy) 0.8 0.0 0.0 2.6 1.9 0.2 0.6 11.7 0.0 0.0 0.0 0.0 17.8 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0.9 0.0 0.0 0.4 0.3 0.0 0.1 1.7 0.0 0.0 0 0 3.4 001 18WE1214 RICE 106 HP 0 0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 490 0.2 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 28 88 0 1 006 18WE1219 Six 400 barrel crude oil tanks 85 54 32 477 0.3 007 18WE1220 Loadout - 0.0 008 18WE1221 .CN NGL plant fugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 149 130 13 25 604 0.5 011 18WE1223.CN RICE 550 HP 0.0 012 GP02.CN Caterpillar 4SR8 203 hp, Model G3306TA, 0.0 SN G6X02571 XP HTRs-TRTs 0.0 XP Loadout 0 0 XP Fugitives 0.0 TOTAL (tpy) 0.6 0.0 0.0 0.1 0.1 0.0 0.0 0.6 0.0 0.0 0.0 0.0 1 .5 6 18WE1220.CP2 4/23/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fischbach Package #: 422899 Received Date: 12/10/2019 Review Start Date: 3/17/2020 Section 01 - Facility Information Company Name: Enerplus Resources (USA) Corporation Quadrant Section Township Range County AIRS ID: 123 67 Plant AIRS ID: 9FDA Facility Name: Colorado Lakes Well Pad Physical Address/Location: SkiVSW quadrant of Section 28, Township 8N, Range 67W County: Weld County Type of Facility: p or cicn & Production L'r'Lii Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use On y 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 # Required? Remarks has already assigned) assigned) Permit NOS previously Produced Water Tank PRD-WTR 18WE1218 Modification submitted Permit Crude Oil Tank TANKS 18WE1219 Modificatie• No NDS on file Permit Liquid Loading L0AD1 18WE1220 Modificatic- No NDS on file Permit Separator VeritH.Ic SEPARATOR 18WE1222 Modification No NDS on file Section 03 - Description of Project Applicant proposes the removal of NGL skid, updating of permitted throughputs, and addition of an open flare for emergency control of separator gas during pipeline downtime. Self-certification of original permit issuances not yet completed, so self-cert and initial compliance testing conditions will carry over into second issuances. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis 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? No Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: S02 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) .1 Title V Operating Permits (OP) Ha D Non-Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: S02 NOx CO VOC PM2.S PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ❑ . Non-Attainment New Source Review (NANSR) Separator Venting Emissions Inventory Section 01 - Administrative Information 10 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Emergency Flaring of Separator Gas when pipeline is unavailable Detailed Emissions Unit Description: Open Flare Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency °o: 95 Limited Process Parameter r`'at,.x=,i w., _ ,: ,t c Gas meter y.l N[ rr -ter ,to td :.li a Vt;oria4 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator 19.9069 Actual Throughput = MMscf per year Requested Permit Limit Throughput = 19.9 MMscf per year Requestec Monthly Throughput = 1.7 MMscf per month Potential to Emit (PTE) Throughput = 19.9 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 1510.0 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: 1510 Btu/scf WitrejlW Section 04 - Emissions Factors & Methodologies Description Emission factors are based on "worst-case scenarios" and gas analyses for each well associated with this facility (e.g. most conservative MW, VOC%, HAP'%s, etc.). This method results in emission factors that are more conservative than the highest individual emission factors for either gas analysis, and is acceptable (see calc sheets within permit application from initial permit issuance in records manager for more info). MW 2i6. ' Ib/Ib-mol Displacement Equation Ex = Q * IVW * Xx / C Weight % Helium CO2 2.8 N2 0.9 methane 37.3 ethane 15.4 propane 21.3 isobutane 3.0 n-butane 9.7 isopentane 2.3 n-pentane 2.6 cyclopentane 0.2 n-Hexane 0.7 cyclohexane 0.4 Other hexanes 1.0 heptanes 1.3 methylcyclohexane 0.3 224-TMP 0.0 Benzene 0.2 Toluene 0.2 Ethylbenzene 0.0 Xylenes 0.0 C8+ Heavies 0.5 Total 100 VOC Wt % 43.6S 2 of 7 K:\PA\2018\18WE1222.CP2 Separator Venting Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled PA Calculated emission factors using operator method Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) Uncontrolled Controlled (Gas Throughput) (Gas Throughput) lb/MMBtu lb/MMscf lb/MMscf VOC 30909.00 1545.45 _ . .ended gas analysis 20.470 30784.84931 1539.242466 Benzene 149.63 7.48 Extended gas. analysis 140.9848813 7.049244063 Toluene 130.57 6.53 Extendedgas'analysis 123.0003166 6.150015831 Ethylbenzene 12.65 0.63 Extended gas analysts 8.886490765 0.444324538 Xylene 25.29 1.26 _ Extended gas analysis 17.84350923 0.892175462 n-Hexane 606.86 30.34 Extended gas analysis 368.9304222 18.44652111 224 IMP 27.54 1 .38 70525.09496 3526.254748 Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0000 PM2.5 0.0000 SOx _ 0.0000 __ NOx - 0.0680 102.6800 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 468.1000 -42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 PM2.5 0.0000 SOx 0.0000 NOx 0.0000 CO 0.0000 Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.0 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 1.0 0.0 0.0 1.02 1.02 174 VOC 307.6 0.0 0.0 307.56 15.4 2612 CO 0.0 0.0 0.0 4.66 4.66 791 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) APEN Reported/Operator Calculated Emissions Benzene 2978 0 0 2978 149 2979 149 Toluene 2598 0 0 2598 130 2599 13O Operator calculated values Ethylbenzene 252 0 0 252 13 252 13 within acceptable rounding Xylene 503 0 0 503 25 503 25 error, and will be used in n-Hexane 12077 0 0 12077 604 12081 604 notes to permit holder. 224 TMP 548 0 0 548 27 548 2-' Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) 3 of 7 K:\PA\2018\18WE1222.CP2 Separator Venting Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit wit: contain an "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted 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. Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? Yes If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted 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. -A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to :he emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughpu: using the liquid throughput until the meter is installed and operational (not to, exceed 183 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bhl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? No If yes, the permit wi l contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. .4 - Section 08 - Technical Analysis Notes Emission factors are based on "worst-case scenarios" and gas analyses for each well associated with this facility (e.g. most conservative MW, VOC%, HAP%s, etc.). This method results in emission factors that are more conservative than the highest individual emission factors for either gas analysis, and is acceptable (see calc sheets within permit application from initial permit issuance in records manager for more info). NGL Skid has been removed from facility, and pipeline gas takeaway added. Per the Alternative Emissions Control Equipment Request Form: "Enerplus now has access to a pipeline for gas takeaway and would like to keep an open flare in place as a backup for pipeline downtime or emergency situations." "An engineered Steffes 60.18 compliant open flare with design of greater than 98% destruction efficiency will be utilized during the operations listed above." "This open flare will be used as a backup to pipeline downtime or emergency use only." Normal (daily average) voumetric flow rate device will need to control = 338 MSCFD Potential Surge (max) volumetric flow rate device will need to control = 338 MSCFD PTE of VOC device will need to be capable of controlling = 308 tpy Device is located approximately 2457 ft from a single family residential home. This control device has a design guarantee of at least 98%, and will meet the 95% hydrocarbon control efficiency required in R7, Part D, Section II. The flare will operate with no visible emissions during normal operation, will be adequately designed and sized to achieve the rated control efficiency and handle reasonable forseeable fluctuations in emissions of OVC and hydrocarbons during normal operations, will be designed such thta an observer can determine whether it is operating properly by visual observation from outside the flare, and will be equipped with an auto-igniter by the dates required in Reg &, Part D, Section II.B.2.d. "When vapors are routed to the faire the operator will ensure the pilot is lit, the auro-ignitor is operatio ial and conduct a smoke/no-smoke reading to insure no visible emissions. Records will be maintained and available upon request by the division." Control via ECD is infeasible at this facility because "operation of multiple combustor requires more fuel i gas and operating costs than on open flare. Flare will only be used during pipeline downtime and emergency events." Upon further discussion with operator, I was informed that controlling this point via ECD would require installation of three additional ECDs at this facility, and associated pilot gas. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code Pollutant Uncontrolled Emissions Factor Control % Units 10 01 3-10-001 -60 Flares PM10 0.G C Ib/MMSCF C SCC coding withpilot light nei PM2.5 0.0 Ib/MMSCF emissions in lbs divided by th SOx 0.0 C Ib/MMSCF NOx 102.7 C Ib/MMSCF VOC 30909.0 95 lb/MMSCF CO 468.1 C lb/MMSCF 2640 Benzene 149.6 95 Ib/MMSCF Toluene 130.6 95 Ib/MMSCF Ethylbenzene 12.7 95 lb/MMSCF Xylene 25.3 95 Ib/MMSCF n-Hexane 606.9 95 Ib/MMSCF 224 TMP 27.5 95 Ib/MMSCF • 4 of 7 K:\PA\2018\18WE1222.CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater t"an 2 TPY (Regulation 3, Part A, Section II.D.t.a)? 2. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Re 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Source Re Scurce requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? Yes The contra The control device for this separator is subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend, " 'may," "should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Enerplus Resources (USA) Corporation County AIRS ID 123 History File Edit Date 4/2/2020 Plant AIRS ID 9FDA Ozone Status Non-Attainment Facility Name Colorado Lakes Well Pad EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S S02 NOx VOC Fug CO Total PM10 PM2.5 H2S S02 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.7 0.7 0.0 0.6 109.3 875.9 0.2 102.5 18.1 0.7 0.7 0.0 0.7 8.7 50.2 0.2 20.6 1 .9 re,rious Totals from November 2019 Tab Previous Permitted Facility total 0.7 0.7 0.0 0.6 109.0 875.9 0.0 102.3 18.1 0.7 0.7 0.0 0.7 8.4 50.2 C.0 20.4 1.9 001 18WE1214 RICE 106 HP 0.1 0 1 0 0 13.1 0.7 22.0 0.0 0 1 0 1 0.1 1 .0 0 7 2.1 0.0 Point updated on 02/112020. Data NOT reviewed 002 18WE1215 RICE 203 HP 0.2 0.2 0 2 31 .0 1 .4 20.6 0.4 0.2 0 2 0.2 2.0 1 4 3.9 0.4 Point updated on 02/13/2020. Data NOT reviewed 003 18WE1216 RICE 106 HP 0.2 0.2 0.2 32.5 1.4 32.5 0.5 0.2 0.2 0.2 2.0 1 .4 3.9 0.2 Point updated on 02/112020. Data NOT reviewed 004 18WE1217.CN RICE 550 HP 0.0 0.0 005 18WE1218 Two 400 barrel produced water tanks 0.2 10.5 1 .0 1.2 0.2 0.5 1.0 0.1 Point updated and reviewed on 04/02/2020 006 18WE1219 Six 400 barrel crude oil tanks 0.7 546.9 3.1 6.6 0.7 27.4, 3.1 0.3 Point updated and reviewed on 04/02/2020 007 18WE1220 Loadout 6.0 0.1 2.0 0.0 Point updated and reviewed on 04/02/2020 008 18WE1221.CN NGL plant fugitives , 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 009 , 18WE1222.CN NGL 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. 010 18WE1222 Separators 1 0 307.60 4.7 9 2 1 .0 15.40 4.7 0.5 Point updated and reviewed on 04/02/2020 011 18WE1223.CN RICE 550 HP 0.0 0 0 Cancellation received 12/10/2019 - no longer exists. 012 GP02.CN Caterpillar 4SRB 203 hp, Model 0.0 0.0 Cancellation received 12/10/2019 - no longer exists. G3306TA, SN G6X02571 XP HTRs-TRTs 0.000 0.000 0.3 0.0 0.2 0.0 0 000 0 000 0.3 0.0 0.2 0.0 XP Loadout 0.00 0.0 0.00 0.0 XP , Fugitives 0.2 0.0 0.2 0.0- FACILITY TOTAL 0.5 0.5 0.0 0.4 78.8 874.5 0.2 84.1 17.8 0.5 0.5 0.0 0.5 7.2 48.8 0.2 18.9 1.5 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: Syn Minor n-Hexane HH: Area 7777: Area Permitted Facility Total 0.5 0.5 0.0 0.4 78.5 874.5 0.0 83.9_ 17.8 0.5 0.5 0.0 0.5 6.9 48.8 0.0 18.7 1.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions -0.2 -0.2 0.0 -0.2 -1.5 -1.4 0.0 -1.7 Pubcom required as this permitting project requests new synthetic minor permit limits wrt to re-designation thresholds Total VOC Facility Emissions (point and fugitive) 49.0 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) -1 4 Project emissions less than 25/50 tpy Note 1 H;:ints 001, 002. and 003 were previously updated using form APCD-102 provided by operator. Data has not yet been reviewed by an engineer. Note 2 Page 6 of 7 Printed 4/23/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Enerplus Resources (USA) Corporation County AIRS ID 123 Plant AIRS ID 9FDA Facility Name Colorado Lakes Well 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 1.7 0.0 0.0 6.2 4.2 0.4 1.2 26.5 0.0 0.6 0 0 40.8 001 18WE1214 RICE 106 HP 0.0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 980 0.5 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 560 i 1760 1 .2 006 18WE1219 Six 400 barrel crude oil tanks 1692 1090 644 9540 6.6 007 18WE1220 Loadout 0.1 008 18WE1221 .CN NGL plant =ugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 2979 2599 252 503 12081 9.2 011 18WE1223.CN RICE 55C HP 0.0 012 GP02.CN Caterpillar 4SRB 203 hp, Model G3306TA, 0.0 SN G6X02571 , XP HTRs-TRTs 0.0 XP Loadout 0.0 XP Fugitives 0.0 TOTAL (tpy) 0.8 0.0 0.0 2.6 1.9 0.2 0.6 11.7 0.0 0.0 0.0 0.0 17.8 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0.9 0.0 0.0 0.4 0.3 0.0 0.1 1.7 0.0 0.0 0 0 3.4 001 18WE1214 RICE 106 HP 0.0 002 18WE1215 RICE 203 HP 706 0.4 003 18WE1216 RICE 106 HP 490 0.2 004 18WE1217.CN RICE 550 HP 0.0 005 18WE1218 Two 400 barrel produced water tanks 28 88 0.1 006 18WE1219 Six 400 barrel crude oil tanks 85 54 32 477 0.3 007 18WE1220 Loadout 0.0 008 18WE1221 .CN NGL plant fugitives 0.0 009 18WE1222.CN NGL 0.0 010 18WE1222 Separators 149 130 13 25 604 0.5 011 18WE1223.CN RICE 550 HP 0.0 012 GP02.CN Caterpillar 4SRB 203 hp, Model G3306TA, 0.0 SN G6X02571 , XP HTRs-TRTs 0.0 XP Loadout 0.0 XP Fugitives 0.0 TOTAL (tpy) 0.6 0.0 0.0 0.1 0.1 0.0 0.0 0.6 0.0 0.0 0.0 0.0 1.5 7 18WE1222.CP2 4/23/2020
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