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Home My WebLink About20192274.tiffCOLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 June 10, 2019 Dear Sir or Madam: RECEIVED ;: Z 11 4 2U19 WELD COUNTY COf iMISSIONERS On June 13, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for SRC Energy, Inc. - Ag 26-32 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. Regards, Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Lai Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe P,,ulc'P,ev‘esk) (.olkq/Iq Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director c C .AL(Ip) \1L(3 -O, ' (dM 1 E.RICtilc ri) CnIWltct 2019-2274 a Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: SRC Energy, Inc. - Ag 26-32 Pad - Weld County Notice Period Begins: June 13, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: SRC Energy, Inc. Facility: Ag 26-32 Pad EEL!) Well Pad Site NENE Sec 32 T6N R66W Weld County The proposed project or activity is as follows: The applicant proposes to permit one (1) natural gas internal compression engine to be used as a vapor recovery unit (VRU), two (2) natural gas internal combustion engines used for the generation of electricity, a battery of six (6) x 400 -bbl condensate storage tanks, and the loadout of liquid hydrocarbons at a new synthetic minor oil and gas production facility located in the eight -hour (8 -hr) Ozone Control Area of Weld County. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0825 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: 1 I Ate g•ICOLORADO HYith @ Etivlto�taxat Daniel Williams Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-61 Denver, Colorado 80246-1530 (COLORADO 2 Department of Public Health 6 Environment STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303 692-3150 PERMIT NO: 18WE0825 CO STRUCTION PERMIT Issuance 1 DATE ISSUED: ISSUED TO: SRC Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Ag 26-32 Pad, located in NENE Section 32, Township 6N, Range 66W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description ENG-1 001 One (1) Caterpillar, Model G3406TA/JGA4, Serial Number 4FD04835, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 276 horsepower. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3406TA/JGA4 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.ciov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9FE0/001 Page 1 of 15 NGEngine Version 2014-1 nt f Public Health and Environment Air Pollution Control Division 2. Within one hund . eig a ""• d) •` "'" - -r of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permince: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the own or operator of the source for which this permit was issued: (i) does not commence con - uction/modification or operation of this source within 18 months after either, the date of ' _ - nce 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO. VOC CO ENG-1 001 2.7 1.9 5.3 Point 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 shall be less than 8.0 tpy. AIRS ID: 123/9FE0/001 Page 2 of 15 oradrA epart -nt f Public Health and Environment Air Pollution Control Division Facility -wide emi of to `:°tea `: • a ' I is shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rollin• twelve (12) month total. By the end of each month a new twelve-month total shall ted based on the previous twelve months' data. The permit holder shall calculate e sions each month and keep a compliance record on site or at a local field office with e responsibility, for Division review. This rolling twelve-month total shall apply to a -rmitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of VOC 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) . Facility Equipment ID AIRS Point Control Device Pollutants Controlled ENG-01 001 Non -selective catalytic reduction (NSCR) system and air/fuel ratio controller NOx and CO PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit ENG-1 001 Consumption of natural gas as a fuel 9.78 MMscf/yr Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9FE0/001 Page 3 of 15 f Public Health and Environment Air Pollution Control Division Compliance with - - `" nualdetermined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATOR'`'' REQUIREMENTS 11. The permit number and AIRS ID p• _ umber (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. A source initial compliance test shall be conducted on emissions point 001 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. Periodic Testing Requirements 16. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. AIRS ID: 123/9FE0/001 Page 4 of 15 ADDITIONAL REQUI oradfi depart -nt if Public Health and Environment Air Pollution Control Division 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th follows: For any criteria pollutant: a significant increase in emissions occurs as For sources emitting less i: 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 18. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9FE0/001 Page 5 of 15 f Public Health and Environment Air Pollution Control Division 20. If this permit sa ly - - - alation 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 -, and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot •e a `'ed 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 :zI points has been reviewed and approved by the Division, it will provide written d i entation 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. 21. 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. 22. 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. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. 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. 25. 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. AIRS ID: 123/9FE0/001 Page 6 of 15 By: Daniel Williams Permit Engineer f Public Health and Environment Air Pollution Control Division Permit Histo Issuance Date Description Issuance 1 This Issuan `- ' Issued to SRC Energy, Inc. AIRS ID: 123/9FE0/001 Page 7 of 15 Notes to Permit Holder at t of t f Public Health and Environment Air Pollution Control Division 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B. 2) The production or raw material processing I:. its and emission limits contained in this permit are based on the consumption rates requested in th permit application. These limits may be revised upon request of the owner or operator providin•here is no exceedance of any specific emission control regulation or any ambient air quality sta "'. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.c ov/pacific/cdphe/aacc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 001 Formaldehyde 50000 A 1,439 Yes 1,439 Methanol 67561 C 61 No 61 Acetaldehyde 75070 A 56 No 56 Acrolein 107028 A 52 No 52 Benzene 71432 A 31 No 31 1,3 -Butadiene 106990 A 13 No 13 Toluene 108883 C 11 No 11 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled lb/MMBtu Factors — g/bhp-hr NOx 4.1290 15.41 0.2679 1.00 CO 4.1290 15.41 0.5359 2.00 VOC 0.1876 0.70 0.1876 0.70 50000 Formaldehyde 0.0723 0.27 0.0723 0.27 67561 Methanol 0.0031 0.01 0.0031 0.01 75070 Acetaldehyde 0.0028 0.01 0.0028 0.01 107028 Acrolein 0.0026 0.01 0.0026 0.01 71432 Benzene 0.0016 0.01 0.0016 0.01 106990 1,3 -Butadiene 0.0007 0.00 0.0007 0.00 108883 Toluene 0.0006 0.00 0.0006 0.00 AIRS ID: 123/9FE0/001 Page 8 of 15 Emission factors a • `- on ke- mption Factor of 8228 Btu/hp-hr, a site - rated horsepower value of 276, and a fuel heat value of 2034 Btu/scf. f Public Health and Environment Air Pollution Control Division Emission Factor Sources: CAS Pollutant Uncontrolled EF Source Controlled EF Source NOx Ma . - . NSPS JJJJ CO Ma of ur-r NSPS JJJJ VOC NSPS JJ NSPS JJJJ 50000 Formaldehyde Manuf- urer Manufacturer 67561 Methanol AP -4 , • le 3.2-3 (7/2000); Natural Gas No Control 75070 Acetaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 71432 Benzene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 106990 1,3 -Butadiene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 108883 Toluene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 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 shall 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.dov/ttn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs PSD or NANSR Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs MACT ZZZZ Area Source Requirements: Applicable AIRS ID: 123/9FE0/001 Page 9 of 15 loradaepart -nt f Public Health and Environment Air Pollution Control Division 10) Full text of the Title 40, ion o ' irEl at the website listed below: http://ecfr.gpoaccess.gov/ de of Federal Regulations can be found Part 60: Standards of Performanc fo e Stationary Sources NSPS 60.1 -End Sub rt A — Subpart KKKK NSPS Part 60, Appendixes Api ix 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 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9FE0/001 Page 10 of 15 lorad epart nt f Public Health and Environment Air Pollution Control Division ALTERNATIVE OPERATING SCENARIOS RECIPROCATING IN 2. Alternative Operating Scenarios L COMBUSTION ENGINES Oct_ber12, 2012 The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9FE0/001 Page 11 of 15 f Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applica ements for the replacement engine. Measurement of emissions from the permanent replacement n ,,e .; d compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that i '; ludes the specific manufacturer, model and serial number and horsepower of the permanent replacem = gine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: www.colorado.qov/cdphe/portable-analvzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement AIRS ID: 123/9FE0/001 Page 12 of 15 lorad apart -nt sf Public Health and Environment Air Pollution Control Division engine will be subject to, ts of -s•e `N'a`to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contra rce may certify that the engine is in compliance with both the NOX and CO emission limitations vant time period. Subject to the provisions of C.R.S. 25-7-123.1 the portable analyzer results fail to demonstrate the engine will be considered to be out of c portable analyzer test indicates compliance with engine is taken offline. d in the absence of credible evidence to the contrary, if mpliance with either the NOX or CO emission limitations, nce from the date of the portable analyzer test until a both the NOX and CO emission limitations or until the 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. AIRS ID: 123/9FE0/001 Page 13 of 15 tf Public Health and Environment Air Pollution Control Division The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constr after the date listed in the table below sh manufacturer's written instructions or procedure limitations and good engineering and mainten achieves the emission standards required in t located to the state of Colorado from another state, operate and maintain each engine according to the o the extent practicable and consistent with technological ce practices over the entire life of the engine so that it le below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § LB (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, AIRS ID: 123/9FE0/001 Page 14 of 15 if approved in advance by tion, in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with new emissions unit, not "routine replacement' advanced construction permit review. The AO site; an engine that is being installed as an entir replacement of an existing onsite engine permitting process prior to installation. epart -nt if Public Health and Environment Air Pollution Control Division nducted within the time frame specified gine is viewed by the Division as the installation of a f an existing unit. The AOS is therefore essentially an annot be used for additional new emission points for any new emission point and not as part of an AOS-approved go through the appropriate Construction/Operating AIRS ID: 123/9FE0/001 Page 15 of 15 Division Information Engineer: Daniel Williams Control Engineer: Stephanie Spector Review Date: 01/15/2019 Application Date: 07/05/2018 Facility Identifiers Permit No. 18WE0825 AIRs County # 123 Weld Facility # 9FE0 Point # 001 Facility Equipment ID ENG-1 Section 01: Administrative Information Attainment Status PM10 Attainment PM2.5 Attainment SOx Attainment NOx Nonattainment VOC Nonattainment CO Attainment Potentially Located within EAC - determine attainment status of NOx and VOC Company Name: SRC Energy, Inc. Source Name: Ag 26-32 Pad Source Location: NENE Section 32, Township 6N, Range 66W SIC: 1311 Elevation (feet) Mailing Address Address 1: Address 2: City, State Zip: SRC Energy. Inc. 5400 W 11th St, Suite C Greeley, CO, 80634 Contact Name: Brad Rogers Section 02: Requested Action '� New permit/newly reported emission Request MOD - Change fuel/equipment ✓ Request MOD - Change permit limit ✓ Request MOD - Change company name ✓ Request MOD - Transfer of ownership ✓ Request MOD - Other Issuance Number: Request portable source permit If this is an exemption. enter XA or XP here Add'I Info SRC Energy is applying to permit six points at a new synthetic minor facility in and notes: the NAAQS nonattainment area. Section 03: General Facility Information General description of equipment purpose:_This emission unit is used for natural gas compression. Date the engine was ordered: Date engine construction commenced: 3/1/2018 Date engine relocated into Colorado: Date of any reconstruction/modification: Will this equipment be operated in any nonattainment area? Yes Section 04: Engine Information Engine Info Engine date of mfg 10/1/2014 Engine Displacement 2.44 L/cyl Manufacturer: Caterpillar Model Number: G3406TA/JGA4 Serial Number: 4FD04835 Engine Function Compression berating Mfg's Max. Rated Horsepower @ sea level: 276 Derate Based on Altitude: Derate by a factor of: Use Site -Specific Rating: 3 % for every 500 feet over 3000 feet of altitude 0.5 1000 hp ( No Deration Horsepower used for calcuations: 276 BSCF @ 100% Load (btu/hp-hr): 8228 Site - Rated BSCF @ 100% load (btu/hp-hr): 8228 BSCF: Site -Rated value will be used when available Other Parameters Engine Type 4SRB Aspiration turbo -charged Electrical Generator Max Site Rating (kw) Annual hours for PTE 8760 Annual hours for permit 8760 <-Optional: Use generator rating to estimate horsepower instead of derating and mfg value above Assumed efficiency: 75.0% Section 06: Fuel Consumption Information Fuel Use Rate @ 100% Load 1116.4 scf/hr ACTUAL Annual Fuel Consumption 9.780 MMscf/yr MAX POTENTIAL Annual Fuel Consumption 9.780 MMscf/yr REQUESTED Annual Fuel Consumption 9.780 MMscf/yr Fuel Heating Value 2034.15 btu/scf <-Optional: Use default fuel heating values <-Optional: Use BSCF & FHV to estimate Max potential Annual Fuel Consumption Section 07: Emission Control Information Primary Control Device Description CHOOSE ONE and delete the others This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. Uncontrolled Emission Factors - Criteria & HCHO Pollutant Value - lb/MMBtu Value - g/bhp-hr Source/Comments NOx 4.129 15.410 Manufacturer CO 4.129 15.410 Manufacturer VOC 0.188 0.700 NSPS JJJJ Formaldehyde 0.072 0.270 Manufacturer Use ? Button to find a default set of values. Use ! Button to enter value in one set of units and have the program find the other one NOTE: the program needs to have values in both unit sets entered, please Control Efficiency/Controlled Emission Factors - Criteria & HCHO Pollutant Value - lb/MMBtu Value - g/bhp-hr Control (%) Source/Comments Calculate NOx 0.268 1.000 93.5% NSPS JJJJ CO 0.536 2.000 87.0% NSPS JJJJ VOC 0.188 0.700 0.0% NSPS JJJJ Formaldehyde 0.072 0.270 0.0% Manufacturer For each controlled pollutant. enter one of the following: b/mmbtu, g/bhp-hr or %. Then press button to calculate the rest. NOTE: the program needs to have all values entered, please Other Pollutants - Emission Factors and Controls Step 1 Choose a set of uncontrolled emission factors for SO2, PM, PM 10, PM2.5 and NCRPs Option A: Choose one set for everything (i.e. AP -42) Option B: Choose the highest value for each pollutant (i.e., some will be AP -42, some will be HAPCaIc. etc.) Option C: Write in a value for each pollutant yourself Option D: Run option A or B for all pollutants, and then Run Option C to overwrite a few values that aren't default. Step 2 Enter a control efficiencies (if applicable) for SO2, PM, PM10, PM2.5 and NCRPs Ignore step 2 if the engine is uncontrolled. MACT ZZZZ Facility HAP Status Area Source Is the engine an emergency RICE under ZZZZ definitions? No Is the engine a limited use RICE under ZZZZ definitions? No Is the engine a landfill/digester gas RICE under ZZZZ definitions? No MACT ZZZZ Category: New/Recon 4SRB less than or equal to 500 HP The permit document will include guidance about what MACT ZZZZ conditions to include based on the MACT ZZZZ category NSPS JJJJ Currently this rule is not adopted into Reg No. 6. the permit only addresses NSPS JJJJ in the notes to permit holder. Regulation No. 7 - Section XVII.E (Statewide Standards) Based on the dates and horsepowers listed above, the following standards apply: HP Con/Relocate Date NOx CO VOC 100<HP<=50 January 1, 2011 1.0 2.0 0.7 Engine meets stds preconrol? No No Yes Engine meets stds postcontrol? Yes Yes Yes Final Calculations Click this button AFTER all entries on this page are complete to finalize calculations on the "Emission Calculations" Tab. Summary of Preliminary Analysis - NG RICE Company Name SRC Energy, Inc Facility Name Ag 26-32 Pad Facility Location NENE Section 32, Township 6N, Range 66W Facility Equipment ID ENG-1 Permit No AIRS Review Date Permit Engineer ' 18WE0825 123/9FE0/001 01/15/2019 Daniel Williams Requested Action New permit/newly reported emission Issuance No 1 Emission Point Description One (1) Caterpillar, Model G3406TA/JGA4, Serial Number 4FD04835, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 276 horsepower This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control This emission unit is used for natural gas compression Natural Gas Consumption Requested (mmscf/yr) 9 78 Requested (mmscf/m) 0 83 Fuel Heat Value (btu/scf) 2034 15 BSCF (Btu/hp-hr) 8228 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 8760 I Uncontrolled Controlled NOx Manufacturer NSPS JJJJ VOC NSPS JJJJ NSPS JJJJ CO Manufacturer NSPS JJJJ Formaldehyde Manufacturer Manufacturer SOX AP -42 Table 3 2-3 (7/2000), Natural Gas No Control TSP AP -42, Table 3 2-3 (7/2000), Natural Gas No Control PM10 AP -42, Table 3 2-3 (7/2000), Natural Gas No Control i PM2 5 AP -42, Table 3 2-3 (7/2000), Natural Gas No Control Other Pollutants AP -42, Table 3 2-3 (7/2000), Natural Gas No Control Point Summary of Criteria Emissions (t Uncontrolled , Requested Controlled Requested ` PTE Proposed Control Efficiency NOx 41 1 2 7 41 1 - 93 5% VOC 1 9 1 9 1 9 0 0% CO 411 53 411 870% SOx 00 00 00 00% TSP 02 '02 02 00% PM10 02 02 02 00% PM25 02 02 02 00% Total HAPs* 0 7 0 7 0 8 0 0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds PTE includes all HAPs calculated, even those below de m►nimus ) Point Summary of Hazardous Air Pollutants (Ib/yr) HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Efficiency Control Formaldehyde 1439 1439 1439 0.0% Methanol 61 0.0% Acetaldehyde * * 56 0.0% Acrolein * * 52 0.0% Benzene * * 31 0.0% 1,3 -Butadiene * * 13 0.0% Toluene * * 11 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source Reg Standards 7 XVII.E . (g/hp-hr) E NOx: 1.0 CO: 2.0 VOC: 0.7 Reg requirements) 7 XVI.B (Ozone applies? NAA No MACT ZZZZ (area source) Is this source engine requirements? subject to MACT ZZZZ area Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: been JJJJ adopted requriements into Reg are not 6. currently included as permit conditions because the reg has not Comments/Notes SRC Energy is applying to permit six points at a new synthetic minor facility in the NAAQS nonattainment area. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FE0 Facility Name Aq 26-32 Pad History File Edit Date 4/24/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facilit ✓ total 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE0825 RICE Caterpillar G3406TA/JGA4 0.2 0.2 41.1 1.9 41.1 0.8 0.2 0.2 2.7 1.9 5.3 0.8 Cancelled 4/19/19 Cancelled 4/19/19 004 18WE0828 Condensate Tanks (6) x 400 -bbl 0.1 0.1 1.3 690.2 5.8 20.0 0.1 0.1 1.3 34.5 5.8 1.0 005 18WE0829 Condensate Loadout 3.8 0.1 0.2 0.0 006 GP08 Water Tanks (2) x 400 -bbl 0.7 51.5 3.3 5.7 0.7 5.9 3.3 0.3 0.0 0.0 0.0 0.0 Insignificant Sources 0.0 0.0 Fugitives 0.3 0.0 0.3 0.0 NG Heaters (12) 0.5 0.5 6.4 0.4 5.4 0.1 0.5 0.5 6.4 0.4 5.4 0.1 0.0 , 0.0 FACILITY TOTAL 0.8 0.8 0.0 0.0 49.5 747.8 0.3 55.6 26.7 0.8 0.8 0.0 0.0 11.1 42.9 0.3 19.8 2.2 VOC: Syn Minor NOx: Syn Minor (NANSR CO: Syn Minor (OP) HAPS: Syn Minor HH: Area 7777' Area (NANSR and OP) and OP) B, C6. & Total Permitted Facility Total 0.3 0.3 0.0 0.0 43.1 747 4 0.0 50.2 26.6 0.3 0.3 0.0 0.0 l 4 7 42.5 0.0 14.4 2.1 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions _ _ _ 0.3 _ 0.3 0.0 0.0 4.7 42.5 0.0 14.4 Pubcom required based on new syn minor (A) Total VOC Facility Emissions (point and fugitive) Change in Total Permitted VOC emissions (point and fugitive) 43.2 Facility is not eligible for GP02 because > 90 tpy Project emissions greater than 25 tpy 42.5 Note 1 Prior to issuance points 002 & 003 and provided a new pressurized liquid sample and Promax model, which lowered the calculated emissions from the condensate storage tanks. of July 2018 permits, SRC cancelled Note 2 Page 7 of 8 Printed 4/25/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name SRC Energy, Inc. 123 9FE0 Ag 26-32 Pad Emissions - uncontrolled Obis per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 1 0.8 l .n 004 18WE0828 Condensate Tanks (6) x 400 -bbl 3732 3388 167 1236 31377 20.0 005 18WE0829 Condensate Loadout 1 1 '. 0.1 006 GP08 Water Tanks (2) x 400 -bbl 2749 8640 5.7 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 233 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 3.3 1.7 0.1 0.6 20.2 0.0 0.0 0.0 0.0 26.7 *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 TOTAL (tPY) 224 TMP H2S !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 ' > ' 0.8 004 18WE0828 Condensate Tanks (6) x 400 -bbl 187 169 8 62 1569 1.0 005 18WE0829 Condensate Loadout 0 0.0 006 GP08 Water Tanks (2) x 400 -bbl 138 432 0.3 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 233 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 0.2 0.1 0.0 0.0 1.1 0.0 0.0 0.0 2.2 0.0 8 18WE0825.CP1.xlsm 4/25/2019 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303 692-3150 PERMIT NO: 18WE0826 CO STRUCTION PERMIT Issuance 1 DATE ISSUED: ISSUED TO: SRC Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Ag 26-32 Pad, located in NENE Section 32, Township 6N, Range 66W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description ENG-2 002 One (1) Doosan, Model 14.6L, Serial Number EEZOG400855, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 390 horsepower. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system. This emission unit is used for electric power generation. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Doosan 14.6L engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manaqe-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9FE0/002 Page 1 of 15 NGEngine Version 2014-1 Iorad'A depart nt f Public Health and Environment Air Pollution Control Division 2. Within one hund - •'� � • eig a 4) • - -r of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the perm'€ nce: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the own- :or operator of the source for which this permit was issued: (i) does not commence con- Suction/modification or operation of this source within 18 months after either, the date of ' - nce 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO. VOC CO ENG-2 002 3.8 2.6 7.5 Point 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 shall be less than 8.0 tpy. AIRS ID: 123/9FE0/002 Page 2 of 15 loradr, epart -ntf Public Health and Environment Air Pollution Control Division Facility -wide emiof to °a - :": I` a •I is shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rollin• twelve (12) month total. By the end of each month a new twelve-month total shall •=a c u ted based on the previous twelve months' data. The permit holder shall calculate e -sions each month and keep a compliance record on site or at a local field office with Ee responsibility, for Division review. This rolling twelve-month total shall apply to a - mitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of VOC 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled ENG-02 002 Non -selective catalytic reduction (NSCR) system NOx and CO PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit ENG-2 002 Consumption of natural gas as a fuel 24.37 MMscf/yr Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9FE0/002 Page 3 of 15 f Public Health and Environment Air Pollution Control Division Compliance with ` - : "nual . . . r'" mi _ . ' . _ determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATOR REQUIREMENTS 11. The permit number and AIRS ID p. a umber (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. A source initial compliance test shall be conducted on emissions point 002 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. Periodic Testing Requirements 16. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. AIRS ID: 123/9FE0/002 Page 4 of 15 ADDITIONAL REQUI ®� T f Public Health and Environment Air Pollution Control Division 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th follows: For any criteria pollutant: For sources emitting less 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 18. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). a significant increase in emissions occurs as GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9FE0/002 Page 5 of 15 nt f Public Health and Environment Air Pollution Control Division 20. If this permit salation 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 . and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot •e y„ a ed until the operation or activity commences and has been verified by the APCD as onforming in all respects with the conditions of the permit. Once self -certification of n i points has been reviewed and approved by the Division, it will provide written di entation 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. 21. 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. 22. 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. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. 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. 25. 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. AIRS ID: 123/9FE0/002 Page 6 of 15 By. ,. Daniel Williams Permit Engineer f Public Health and Environment Air Pollution Control Division Permit Histo Issuance Date Description Issuance 1 This Issuan - Issued to SRC Energy, Inc. AIRS ID: 123/9FE0/002 Page 7 of 15 Notes to Permit Holder at t µ &= ' - of t loradrA epart -ntf Public Health and Environment Air Pollution Control Division 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B. 2) The production or raw material processing I on the consumption rates requested in th request of the owner or operator providin regulation or any ambient air quality sta its and emission limits contained in this permit are based permit application. These limits ' may be revised upon here is no exceedance of any specific emission control . A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/Dacific/cdDhe/aacc-reqs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 002 Formaldehyde 50000 A 1,016 Yes 1,016 Methanol 67561 C 152 No 152 Acetaldehyde 75070 A 138 No 138 Acrolein 107028 A 130 No 130 Benzene 71432 A 78 No 78 1,3 -Butadiene 106990 A 33 No 33 Toluene 108883 C 28 No 28 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled lb/MMBtu Factors — g/bhp-hr NOx 2.2100 14.50 0.1519 1.00 CO 3.7200 24.50 0.3039 2.00 VOC 0.1064 0.70 0.1064 0.70 50000 Formaldehyde 0.0205 0.13 0.0205 0.13 67561 Methanol 0.0031 0.02 0.0031 0.02 75070 Acetaldehyde 0.0028 0.02 0.0028 0.02 107028 Acrolein 0.0026 0.02 0.0026 0.02 71432 Benzene 0.0016 0.01 0.0016 0.01 106990 1,3 -Butadiene 0.0007 0.00 0.0007 0.00 108883 Toluene 0.0006 0.00 0.0006 0.00 AIRS ID: 123/9FE0/002 Page 8 of 15 Ioradepart -nt f Public Health and Environment Air Pollution Control Division Emission factors a `. - -d o a =' ifi . ` sumption Factor of 14509 Btu/hp-hr, a site -rated horsepower value of 390, and a fuel heat value of 2034 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EF Source Controlled EF Source NOx AP �o . 3.2-3 (7/2000); Na"'ra:.a NSPS JJJJ CO AP -42; , able 3.2-3 (7/2000); Natura as NSPS JJJJ VOC NSP NSPS JJJJ 50000 Formaldehy de AP -42; Table 3.2-3 (7/2000); Natural Gas AP -42; Table 3.2-3 (7/2000); Natural Gas 67561 Methanol AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 75070 Acetaldehyd e AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 71432 Benzene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 106990 1,3- Butadiene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 108883 Toluene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 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 shall 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.govittn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs PSD or NANSR Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs AIRS ID: 123/9FE0/002 Page 9 of 15 MACT ZZZZ f Public Health and Environment Air Pollution Control Division Area Source Requirements: Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance fo ew Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart )OOOOO( 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9FE0/002 Page 10 of 15 T lorad epart - nt f Public Health and Environment Air Pollution Control Division ALTERNATIVE OPERATING SCENARIOS RECIPROCATING IN 2. Alternative Operating Scenarios L COMBUSTION ENGINES The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9FE0/002 Page 11 of 15 lorad. epart -ntf Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operate ;' per . =nt g engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement . • • - - d compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that i ludes the specific manufacturer, model and serial number and horsepower of the permanent replacemen'-ngine shall be filed with the Division for the permanent replacement engine within 14 calendar days •mmencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: www.colorado.gov/cdphe/portable-analyzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement AIRS ID: 123/9FE0/002 Page 12 of 15 orad Aa epart ent f Public Health and Environment Air Pollution Control Division engine will be subject to, t s ofto the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contras- • rce may certify that the engine is in compliance with both the NOX and CO emission limitations r r: -vent time period. Subject to the provisions of C.R.S. 25-7-123.1 ' = d in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate E • mpliance with either the NOX or CO emission limitations, the engine will be considered to be out of cr "+°°"`nce from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10. if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. AIRS ID: 123/9FE0/002 Page 13 of 15 f Public Health and Environment Air Pollution Control Division The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constr after the date listed in the table below sh manufacturer's written instructions or procedure limitations and good engineering and mainten achieves the emission standards required in t ocated to the state of Colorado from another state, operate and maintain each engine according to the o the extent practicable and consistent with technological ce practices over the entire life of the engine so that it le below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, AIRS ID: 123/9FE0/002 Page 14 of 15 if approved in advance by t in Condition 2.2. 2.4 Additional Sources f Public Health and Environment Air Pollution Control Division on, : " de• uc W Inducted within the time frame specified The replacement of an existing engine with new emissions unit, not "routine replacement' advanced construction permit review. The AO site; an engine that is being installed as an entir replacement of an existing onsite engine permitting process prior to installation. gine is viewed by the Division as the installation of a f an existing unit. The AOS is therefore essentially an annot be used for additional new emission points for any new emission point and not as part of an AOS-approved go through the appropriate Construction/Operating AIRS ID: 123/9FE0/002 Page 15 of 15 Division Information Engineer: Daniel Williams Control Engineer: Stephanie Spector Review Date: 01/15/2019 Application Date: 07/05/2018 Facility Identifiers Permit No. 18WE0826 AIRs County # 123 Weld Facility # 9FE0 Point # 002 Facility Equipment ID ENG-2 Section 01: Administrative Information Attainment Status PM10 Attainment PM2.5 Attainment SOx Attainment NOx Nonattainment VOC Nonattainment CO Attainment Potentially Located within EAC - determine attainment status of NOx and VOC Company Name: SRC Energy, Inc. Source Name: Ag 26-32 Pad Source Location: NENE Section 32, Township 6N, Range 66W SIC: 1311 Elevation feet) Mailing Address Address 1: Address 2: City, State Zip: SRC Energy, 5400 W 11th Greeley, CO, Inc. St, Suite C 80634 Contact Name: _Brad Rogers Section 02: Requested Action New permit/newly reported emission ✓ Request MOD - Change fuel/equipment ✓ Request MOD - Change permit limit • Request MOD - Change company name ✓ Request MOD - Transfer of ownership r- Request MOD - Other Issuance Number: Request portable source permit If this is an exemption. enter XA or XP here Add'I Info SRC Energy is applying to permit six points at a new synthetic minor facility in and notes: the NAAQS nonattainment area. Section 03: General Facility Information General description of equipment purpose: This emission unit is used for electric power generation. Date the engine was ordered: Date engine construction commenced: 3/1/2018 Date engine relocated into Colorado: Date of any reconstruction/modification: Will this equipment be operated in any nonattainment area? Yes Section 04: Engine Information Engine Info Engine date of mfg 6/26/2014 Engine Displacement 1.83 L/cyl Manufacturer: Doosan Model Number: 14.6L Serial Number: EEZOG400855 Engine Function Primary and/or peaking power Derating Mfg's Max. Rated Horsepower @ sea level: 390 Derate Based Derate by Use Site • No Deration on Altitude: a factor of: -Specific Rating: 3 % for every 500 feet over 3000 feet of altitude 0.5 1000 hp Horsepower used for calcuations: 390 BSCF @ 100% Load (btu/hp-hr): 14509 Site - Rated BSCF @ 100% load (btu/hp-hr): 14509 BSCF: Site -Rated value will be used when available Other Parameters Engine Type 4SRB Aspiration turbo -charged Electrical Generator Max Site Rating (kw) 291 Annual hours for PTE 8760 Annual hours for permit 8760 <-Optional: Use generator rating to estimate horsepower instead of derating and mfg value above Assumed efficiency: 75.0% Section 06: Fuel Consumption Information Fuel Use Rate @ 100% Load 2782.0 scf/hr ACTUAL Annual Fuel Consumption 24.37 MMscf/yr MAX POTENTIAL Annual Fuel Consumption 24.370 MMscf/yr REQUESTED Annual Fuel Consumption 24.370 MMscf/yr Fuel Heating Value 2034 btu/scf <-Optional: Use default fuel heating values <-Optional: Use BSCF & FHV to estimate Max potential Annual Fuel Consumption Section 07: Emission Control Information Primary Control Device Description CHOOSE ONE and delete the others This engine shall be equipped with a non -selective catalytic reduction (NSCR) system. Uncontrolled Emission Factors - Criteria & HCHO Pollutant Value - lb/MMBtu Value - g/bhp-hr Source/Comments NOx 2.210 14.500 AP -42; Table 3.2-3 (7/2000); Natur1 CO 3.720 24.500 AP -42; Table 3.2-3 (7/2000); Natur; VOC 0.106 0.700 NSPS JJJJ Formaldehyde 0.021 0.135 AP -42; Table 3.2-3 (7/2000); Natur; Use ? Button to find a default set of values. Use ! Button to enter value in one set of units and have the program find the other one NOTE: the program needs to have values in both unit sets entered, please Control Efficiency/Controlled Emission Factors - Criteria & HCHO Note: Caterpillar spec sheets (and (VOC) excluding aldehydes. If this and acrolein should be added to tr also that NSPS JJJJ only exclude: Pollutant Value - lb/MMBtu Value - g/bhp-hr Control (%) Source/Comments Calculate NOx 0.152 1.000 93.1% NSPS JJJJ CO 0.304 2.000 91.8% NSPS JJJJ VOC 0.106 0.700 0.0% NSPS JJJJ Formaldehyde 0.021 0.135 0.0% AP -42; Table 3.2-3 (7/2000); Nate. For each controlled pollutant. enter one of the following: b/mmbtu, g/bhp-hr or °o. Then press button to calculate the rest. NOTE: the program needs to have all values entered, please Other Pollutants - Emission Factors and Controls Step 1 Choose a set of uncontrolled emission factors for SO2, PM, PM 10, PM2.5 and NCRPs Option A: Choose one set for everything (i.e. AP -42) Option B: Choose the highest value for each pollutant (i.e., some will be AP -42, some will be HAPCalc, etc.) Option C: Write in a value for each pollutant yourself Option D: Run option A or B for all pollutants, and then Run Option C to overwrite a few values that aren't default. Step 2 Enter a control efficiencies (if applicable) for SO2, PM, PM 10, PM2.5 and NCRPs Ignore step 2 if the engine is uncontrolled. MACT ZZZZ Facility HAP Status Area Source Is the engine an emergency RICE under ZZZZ definitions? No Is the engine a limited use RICE under ZZZZ definitions? No Is the engine a landfill/digester gas RICE under ZZZZ definitions? No MACT ZZZZ Category: New/Recon 4SRB less than or equal to 500 HP The permit document will include guidance about what MACT ZZZZ conditions to include based on the MACT ZZZZ category NSPS JJJJ CLrrently this rule is not adopted into Reg No. 6. the permit only addresses NSPS JJJJ in the notes to permit holder. Regulation No. 7 - Section XVII.E (Statewide Standards) Based on the dates and horsepowers listed above, the following standards apply: HP Con/Relocate Date NOx CO VOC 10J<HP<=50 January 1, 2011 1.0 2.0 0.7 Engine meets stds preconrol? No No Yes Engine meets stds postcontrol? Yes Yes Yes Final Calculations Click this button AFTER all entries on this page are complete to finalize calculations on the "Emission Calculations" Tab. Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID SRC Energy, Inc Ag 26-32 Pad NENE Section 32, Township 6N, Range 66W ENG-2 Permit No AIRS Review Date Permit Engineer 18WE0826 123/9FE0/002 01/15/2019 Daniel Williams Requested Action Issuance No New permit/newly reported emission 1 Emission Point Description One (1) Doosan, Model 14 6L, Serial Number EEZOG400855, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 390 horsepower This engine shall be equipped with a non -selective catalytic reduction (NSCR) system This emission unit is used for electric power generation Natural Gas Consumption Requested (mmscf/yr) 24 37 Requested (mniscf/m) 2 07 Fuel Heat Value (btu/scf) 2034 BSCF (Btu/hp-hr) 14509 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 8760 Uncontrolled Controlled NOx AP -42, Table 3 2-3 (7/2000), Natural Gas NSPS JJJJ VOC / NSPS JJJJ NSPS JJJJ CO AP -42, Table 3 2-3 (7/2000), Natural Gas NSPS JJJJ Formaldehyde AP -42, Table 3 2-3 (7/2000), Natural Gas AP -42, Table 3 2-3 (7/2000), Natural Gas SOX AP -42, Table 3 2-3 (7/2000), Natural Gas No Control TSP AP -42, Table 3 2-3 (7/2000), Natural Gas No Control PM10 AP -42, Table 3 2-3 (7/2000), Natural Gas No Control PM2 5 AP -42, Table 3 2-3 (7/2000), NaturaKGas No Control Other Pollutants AP -42, Table 3 2-3 (7/2000), Natural Gas No Control Point Summary of Criteria Emissions (tpy) Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx - 54 8 3 8 54 8 93 1% VOC 26 26 26 00% CO 922 75 922 918% SOx _00 / 00 00 00% TSP 05 05 05 00% PM10 ' 05 05 05 00% PM25 05 05 05 1 00% Total HAPs* 0 5 0 5 0 8 0 0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de m►nimus thresholds PTE ►ncludes all HAPs calculated, even those below de minim us Point Summary Hazardous Air Pollutants (Ib/yr) of HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Efficiency Control Formaldehyde 1016 1016 1016 0.0% Methanol * 152 0.0% Acetaldehyde * * 138 0.0% Acrolein * * 130 0.0% Benzene * * 78 0.0% 1,3 -Butadiene * * 33 0.0% Toluene * * 28 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source Reg Standards 7 XVII.E . (g/hp-hr) E NOx: 1.0 CO: 2.0 VOC: 0.7 Reg 7 XVI.B requirements) (Ozone applies? NAA No MACT ZZZZ (area source) Is this source engine requirements? subject to MACT ZZZZ area Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: been JJJJ adopted requriements into Reg are not 6. currently included as permit conditions because the reg has not Comments/Notes SRC Energy is applying to permit six points at a new synthetic minor facility in the NAAQS nonattainment area. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FE0 Facility Name Aq 26-32 Pad History File Edit Date 4/24/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Fug VOC Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Fac/lit/ total 0.0 0 0 0.0 0.0 0.0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 0.2 0.2 41.1 1.9 41.1 0.8 0.2 0.2 n 7 1.9 5.3 0.8 Cancelled 4/19/19 Cancelled 4/19/19 004 18WE0828 Condensate Tanks (6) x 400 -bbl 0.1 0.1 1.3 690.2 5.8 20.0 0.1 0.1 1.3 34.5 5.8 1.0 005 18WE0829 Condensate Loadout 3.8 0.1 0.2 0.0 006 GP08 Water Tanks (2) x 400 -bbl 0.7 51.5 3.3 5.7 0.7 5.9 3.3 0.3 0.0 0.0 0.0 0.0 Insignificant Sources 0.0 0.0 Fugitives 0.3 0.0 0.3 0.0 NG Heaters (12) 0.5 0.5 6.4 0.4 5.4 0.1 0.5 0.5 6.4 0.4 5.4 0.1 0.0 0.0 FACILITY TOTAL 0.8 0.8 0.0 0.0 49.5 747.8 0.3 55.6 26.7 0.8 0.8 0.0 0.0 11.1 42.9 0.3 19.8 2.2 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor B, C6, & Total HH: Area 7777: Area Permitted Facility Total 0.3 0 3 0.0 0.0 43.1 747 4 0 0 50.2 26_6 0.3, 0.3 0.01 0 0 i 4.71 42.51 0.01 14.4i 2.1 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.3 0.3 0.0 0.0 4 7 42.5 0.0 14.4 Pubcom required based on new syn minor Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 43.2 Facility is not eligible for GP02 because > 90 tpy Protect emissions greater than 25 tpy 42.5 Prior to issuance of July 2018 permits, SRC cancelled points 002 & 003 and provided a new pressurized liquid sample and Promax model, which lowered the calculated emissions from the condensate storage tanks. Note 2 Page 7 of 8 Printed 4/25/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name SRC Energy, Inc. 123 9FE0 Ag 26-32 Pad Emissions - uncontrolled (Ibs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 11 0.8 004 18WE0828 Condensate Tanks (6) x 400 -bbl 3732 3388 167 1236 31377 59 20.0 005 18WE0829 Condensate Loadout 13 1 148 0.1 006 GP08 Water Tanks (2) x 400 -bbl 2749 8640 5.7 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 233 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 3.3 1.7 0.1 0.6 20.2 0.0 0.0 0.0 0.0 26.7 *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 TMP H2S TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0.0 0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 2,1 0.8 004 18WE0828 Condensate Tanks (6) x 400 -bbl 187 169 8 62 1569 1.0 005 18WE0829 Condensate Loadout i 0 0 7" 0.0 006 GP08 Water Tanks (2) x 400 -bbl 138 432 0.3 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 233 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 0.2 0.1 0.0 0.0 1.1 0.0 0.0 2.2 0.0 0.0 8 18WE0826.CP1.xlsm 4/25/2019 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303692-3150 PERMIT NO: 18WE0827 CO STRUCTION PERMIT Issuance 1 DATE ISSUED: ISSUED TO: SRC Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Ag 26-32 Pad, located in NENE Sec 32 T6N R66W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description ENG-3 003 One (1) Doosan, Model 11.1L, Serial Number EEIOH403746, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 268 horsepower. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system. This emission unit is used for electric power generation. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Doosan 11.1L engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9FE0/003 Page 1 of 15 NGEngine Version 2014-1 bored ent f Public Health and Environment Air Pollution Control Division 2. Within one hund - e • eig . a . ) o r of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permince: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the ownor operator of the source for which this permit was issued: (i) does not commence con-uction/modification or operation of this source within 18 months after either, the date of ' nce 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO. VOC CO ENG-3 003 2.6 1.8 5.2 Point 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 shall be less than 8.0 tpy. AIRS ID: 123/9FE0/003 Page 2 of 15 Iorad rA epart -nt = f Public Health and Environment Air Pollution Control Division Facility -wide emi • of to - `a = • •i a • •I . is shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rollin• twelve (12) month total. By the end of each month a new twelve-month total shall • c u ted based on the previous twelve months' data. The permit holder shall calculate e z-sions each month and keep a compliance record on site or at a local field office with a responsibility, for Division review. This rolling twelve-month total shall apply to a miffed emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of VOC 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled ENG-03 003 Non -selective catalytic reduction (NSCR) system NOx and CO PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit ENG-3 003 Consumption of natural gas as a fuel 18.53 MMscf/yr Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9FE0/003 Page 3 of 15 epart o ent f Public Health and Environment Air Pollution Control Division Compliance with -`. "nual mi ' -" •- determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATOR ° REQUIREMENTS 11. The permit number and AIRS ID p• ' umber (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. A source initial compliance test shall be conducted on emissions point 003 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. Periodic Testing Requirements 16. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. AIRS ID: 123/9FE0/003 Page 4 of 15 ADDITIONAL REQUI orad'Aepart entf Public Health and Environment Air Pollution Control Division 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th follows: For any criteria pollutant: For sources emitting less 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 18. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). a significant increase in emissions occurs as GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9FE0/003 Page 5 of 15 epart -nt f Public Health and Environment Air Pollution Control Division 20. If this permit s•- - ly al ation 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 and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot •e a, a 'ed until the operation or activity commences and has been verified by the APCD as { onforming in all respects with the conditions of the permit. Once self -certification of ,1 points has been reviewed and approved by the Division, it will provide written d• =. entation 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. 21. 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. 22. 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. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. 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. 25. 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. AIRS ID: 123/9FE0/003 Page 6 of 15 Daniel Williams Permit Engineer Public Health and Environment Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuan - Issued to SRC Energy, Inc. AIRS ID: 123/9FE0/003 Page 7 of 15 Notes to Permit Holder at t of t r lorad'A depart ent of Public Health and Environment Air Pollution Control Division 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B. 2) The production or raw material processing I, : its and emission limits contained in this permit are based on the consumption rates requested in th permit application. These limits may be revised upon request of the owner or operator providin• here is no exceedance of any specific emission control regulation or any ambient air quality sta • - A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado. aov/pacific/cdohe/aacc-reas 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 003 Formaldehyde 50000 A 773 Yes 773 Methanol 67561 C 115 No 115 Acetaldehyde 75070 A 105 No 105 Acrolein 107028 A 99 No 99 Benzene 71432 A 60 No 60 1,3 -Butadiene 106990 A 25 No 25 Toluene 108883 C 21 No 21 5) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS Pollutant Emission Uncontrolled Ib/MMBtu Factors - g/bhp-hr Emission Controlled Ib/MMBtu Factors — g/bhp-hr NOx 2.2100 16.10 0.1373 1.00 CO 3.7200 27.10 0.2747 2.00 VOC 0.0961 0.70 0.0961 0.70 50000 Formaldehyde 0.0205 0.15 0.0205 0.15 67561 Methanol 0.0031 0.02 0.0031 0.02 75070 Acetaldehyde 0.0028 0.02 0.0028 0.02 107028 Acrolein 0.0026 0.02 0.0026 0.02 71432 Benzene 0.0016 0.01 0.0016 0.01 106990 1,3 -Butadiene 0.0007 0.00 0.0007 0.00 108883 Toluene 0.0006 0.00 0.0006 0.00 AIRS ID: 123/9FEO/003 Page 8 of 15 lured epart �-nt f Public Health and Environment Air Pollution Control Division Emission factors a d o - = a - ifi W` .'" sumption Factor of 16052 Btu/hp-hr, a site -rated horsepower value of 268, and a fuel heat value of 2034 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EF Source Controlled EF Source NOx AP '' , - . 3.2-3 (7/2000); Na'` ra a NSPS JJJJ CO AP -42; w, able 3.2-3 (7/2000); Natura as NSPS JJJJ VOC NSP ,.a...r=r NSPS JJJJ 50000 Formaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas AP -42; Table 3.2-3 (7/2000); Natural Gas 67561 Methanol AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 75070 Acetaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 71432 Benzene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 106990 1,3 -Butadiene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 108883 Toluene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control g) 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 shall 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.povittn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines ≤ 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.ciov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.00vittn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs PSD or NANSR Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs AIRS ID: 123/9FE0/003 Page 9 of 15 lorad epart ent f Public Health and Environment Air Pollution Control Division MACT ZZZZ Area Source Requirements: Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance fo ew Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXX( 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9FE0/003 Page 10 of 15 ALTERNATIVE OPERATING SCENARIOS RECIPROCATING IN 2. Alternative Operating Scenarios f Public Health and Environment Air Pollution Control Division L COMBUSTION ENGINES Oc ber 12, 2012 The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9FE0/003 Page 11 of 15 loradr epart dent +f Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operate - c per . nt a -ce g engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement - - - d compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that i ludes the specific manufacturer, model and serial number and horsepower of the permanent replacemen .-ngine shall be filed with the Division for the permanent replacement engine within 14 calendar days • ""'.mmencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: www.colorado.qov/cdphe/portable-analyzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement AIRS ID: 123/9FE0/003 Page 12 of 15 f Public Health and Environment Air Pollution Control Division engine will be subject to, t s of to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contra . - : rce may certify that the engine is in compliance with both the NOX and CO emission limitations r r vant time period. Subject to the provisions of C.R.S. 25-7-123.1 : d in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate E • mpliance with either the NOX or CO emission limitations, the engine will be considered to be out of c• `• ' nce from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. AIRS ID: 123/9FE0/003 Page 13 of 15 f Public Health and Environment Air Pollution Control Division The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII. E — State -only requirements Any permanent engine that is either constr after the date listed in the table below sh manufacturer's written instructions or procedure limitations and good engineering and mainten achieves the emission standards required in t ocated to the state of Colorado from another state, operate and maintain each engine according to the o the extent practicable and consistent with technological ce practices over the entire life of the engine so that it le below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent .engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, AIRS ID: 123/9FE0/003 Page 14 of 15 if approved in advance by t "'`' ° ion, in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with new emissions unit, not "routine replacement' advanced construction permit review. The AO site; an engine that is being installed as an entir replacement of an existing onsite engine permitting process prior to installation. ent f Public Health and Environment Air Pollution Control Division nducted within the time frame specified gine is viewed by the Division as the installation of a f an existing unit. The AOS is therefore essentially an annot be used for additional new emission points for any new emission point and not as part of an AOS-approved go through the appropriate Construction/Operating AIRS ID: 123/9FE0/003 Page 15 of 15 Division Information Engineer: Daniel Williams Control Engineer: Stephanie Spector Review Date: 01/16/2019 Application Date: 07/05/2018 Facility Identifiers Permit No. 18WE0827 AIRs County # 123 Weld Facility # 9FE0 Point # 003 Facility Equipment ID ENG-3 Section 01: Administrative Information Attainment Status PM10 Attainment PM2.5 Attainment SOx Attainment NOx Nonattainment VOC Nonattainment CO Attainment Potentially Located within EAC - determine attainment status of NOx and VOC Company Name: SRC Energy, Inc. Source Name: Ag 26-32 Pad Source Location: NENE Sec 32 T6N R66W SIC: 1311 Elevation (feet) Mailing Address Address Address City, State Zip: 1: 2: SRC Energy, Inc. 5400 W 11th St Suite C Greeley, CO 80634 Contact Name: Brad Rogers Section 02: Requested Action ;i New permit/newly reported emission F Request MOD - Change fuel/equipment {- i Request MOD - Change permit limit Request MOD - Change company name Request MOD - Transfer of ownership Request MOD - Other Issuance Number: F Request portable source permit If this is an exemption, enter XA or XP here Add! Info SRC Energy is applying to permit six points at a new synthetic minor facility and notes: in the NAAQS nonattainment area. Section 03: General Facility Information General description of equipment purpose:_This emission unit is used for electric power generation. Date the engine was ordered: Date engine construction commenced: 3/1/2018 Date engine relocated into Colorado: Date of any reconstruction/modification: Will this equipment be operated in any nonattainment area? Yes Section 04: Engine Information Engine Info Engine date of mfg 8/12/2014 Engine Displacement 1.85 L/cyl Manufacturer: Doosan Model Number: 11.1L Serial Number: EEIOH403746 Engine Function Primary and/or peaking power berating Mfg's Max. Rated Horsepower @ sea level: 268 1' Derate Based Derate by a factor f Use Site -Specific S` No Deration on Altitude: of: Rating: 3 % for every 500 feet over 3000 feet of altitude 0.5 1000 hp Horsepower used for calcuations: 268 BSCF @ 100% Load (btu/hp-hr;: 16052 Site - Rated BSCF @ 100% load (btu/hp-hr): 16052 BSCF: Site -Rated value will be used when available Other Parameters Engine Type 4SRB _ Aspiration turbo -charged Electrical Generator Max Site Rating (kw) 200 Annual hours for PTE 8760 Annual hours for permit 8760 <-Optional. Use generator rating to estimate horsepower instead of derating and mfg value above Assumed efficiency: 75.0% Section 06: Fuel Consumption Information Fuel Use Rate @ 100% Load 2115 scf/hr ACTUAL Annual Consumption Fuel 18.526 MMscf/yr MAX POTENTIAL Annual Consumption Fuel 18.526 MMscf/yr REQUESTED Annual Consumption Fuel 18.526 MMscf/yr Fuel Heating Value 2034.15 btu/scf <-Optional: Use default fuel heating values <-Optional: Use BSCF & FHV to estimate Max potential Annual Fuel Consumption Section 07: Emission Control Information Primary Control Device Description CHOOSE ONE and delete the others This engine shall be equipped with a non -selective catalytic reduction (NSCR) system. Uncontrolled Emission Factors - Criteria & HCHO Pollutant Value - lb/MMBtu Value - g/bhp-hr Source/Comments NOx 2.210 16.100 AP -42; Table 3.2-3 (7/2000); Natuu CO 3.720 27.100 AP -42; Table 3.2-3 (7/2000); Natuc VOC 0.096 0.700 NSPS JJJJ Formaldehyde 0.021 0.149 AP -42; Table 3.2-3 (7/2000); Natuw Use ? Button to find a default set of values. Use ! Button to enter value in one set of units and have the program find the other one NOTE: the program needs to have values in both unit sets entered, please Control Efficiency/Controlled Emission Factors - Criteria & HCHO Pollutant Value - lb/MMBtu Value - g/bhp-hr Control ;%; Source/Comments Calculate NOx 0.137 1.000 93.8% NSPS JJJJ CO 0.275 2.000 92.6% NSPS JJJJ VOC 0.096 0.700 0.0% NSPS JJJJ Formaldehyde 0.021 0.149 0.0% AP -42; Table 3.2-3 (7/2000); Nat For each controlled pollutant, enter one of the following: b/mmbtu, g/bhp-hr or %. Then press button to calculate the rest. NOTE: the program needs to have all values entered, please Other Pollutants - Emission Factors and Controls Step 1 Choose a set of uncontrolled emission factors for SO2, PM, PM 10, PM2.5 and NCRPs Option A: Choose one set for everything (i.e. AP -42) Option B: Choose the highest value for each pollutant (i.e., some will be AP -42, some will be HAPCalc, etc.) Option C: Write in a value for each pollutant yourself Option D: Run option A or B for all pollutants, and then Run Option C to overwrite a few values that aren't default. Step 2 Enter a control efficiencies (if applicable) for SO2, PM, PM10, PM2.5 and NCRPs Ignore step 2 if the engine is uncontrolled. MACT 7777 Facility HAP Status Area Source Is the engine an emergency RICE under ZZZZ definitions? No Is the engine a limited use RICE under 77ZZ definitions? No Is the engine a landfill/digester gas RICE under ZZZZ definitions? No MACT ZZZZ Category: New/Recon 4SRB less than or equal to 500 HP The permit document will include guidance about what MACT ZZZZ conditions to include based on the MACT 7777 category NSPS JJJJ Currently this rule is not adopted into Reg No. 6. the permit only addresses NSPS JJJJ in the notes to permit holder. Regulation No. 7 - Section XVII.E (Statewide Standards) Based on the dates and horsepowers listed above. the following standards apply: HP Con/Relocate Date NOx CO VOC 100<HP<=50 January 1, 2011 1.0 2 0 0.7 Engine meets stds preconrol? No No Yes Engine meets stds postcontrol? Yes Yes Yes Final Calculations Click this button AFTER all entries on this page are complete to finalize calculations on the "Emission Calculations" Tab. i Summary of Preliminary Analysis = NG RICE ( Company Name Facility Name Facility Location Facility Equipment ID SRC Energy, Inc Ag 26-32 Pad NENE Sec 32 T6N R66W ENG-3 Permit No AIRS Review Date Permit Engineer 18WE0827 123/9FE0/003 01/16/2019 Daniel Williams Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One (1) Doosan, Model 11 1L, Serial Number EEIOH403746, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 268 horsepower This engine shall be equipped with a non -selective catalytic reduction (NSCR) system This emission unit is used for electric power generation 1 Natural Gas Consumption Requested (mmscf/yr) 18 53 Requested (mmscf/m) 1 57 Fuel Heat Value (btu/scf) 2034 15 BSCF (Btu/hp-hr) 16051 9 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 8760 Uncontrolled Controlled NOx AP -42, Table 3 2-3 (7/2000), Natural Gas NSPS JJJJ VOC NSPS JJJJ NSPS JJJJ CO AP -42, Table 3 2-3 (7/2000), Natural Gas NSPS JJJJ Formaldehyde AP -42, Table 3 2-3 (7/2000), Natural Gas AP -42, Table 3 2-3 (7/2000), Natural Gas SOX AP -42, Table 3 2-3 (7/2000), Natural Gas No Control TSP AP -42, Table 3 2-3 (7/2000), Natural Gas No Control PM10 AP -42, Table -3 2-3 (7/2000), Natural Gas No Control PM2 5 AP -42, Table 3 2-3 (7/2000), Natural Gas No Control Other Pollutants AP -42 Table 3 2-3 (7/2000), Natural Gas No Control Point Summary of Criteria Emissions (t Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 41 6 2 6 41 6 93 8% VOC 1 8 1 8 1 8 0 0% CO 70 1 5 2 70 1 92 6% SOx 00 00 00 00% TSP `" 04 04 04 00% PM10 04 04 04 00% PM25 04 04 04 00% Total HAPs* 0 4 0 4 0 6 0 0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minims thresholds PTE includes all HAPs calculated, even those below de m►nimus Point Summary of Hazardous Air Pollutants (lb/yr) HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Efficiency Control Formaldehyde 773 773 773 0.0% Methanol 115 0.0% Acetaldehyde * * 105 0.0% Acrolein * * 99 0.0% Benzene * * 60 0.0% 1,3 -Butadiene * * 25 0.0% Toluene * * 21 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source Reg Standards 7 XVII.E (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg requirements) 7 XVI.B (Ozone applies? NAA No MACT ZZZZ (area source) Is this source engine requirements? subject to MACT ZZZZ area NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: been JJJJ adopted requriements into Reg are not 6. currently included as permit conditions because the reg has not Comments/Notes SRC Energy is applying to permit six points at a new synthetic minor facility in the NAAQS nonattainment area. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FE0 Facility Name Aq 26-32 Pad History File Edit Date 4/24/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facilit v total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 r 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 0.2 0.2 41.1 1.9 41.1 0.8 0.2 0.2 2.7 1.9 5.3 0.8 Cancelled 4/19/19 Cancelled 4/19/19 004 18VVE0828 Condensate Tanks (6) x 400 -bbl 0.1 0.1 1.3 690.2 5.8 20.0 0.1 0.1 1.3 34.5 5.8 1.0 005 18WE0829 Condensate Loadout 3.8 0.1 0.2 0.0 006 GP08 Water Tanks (2) x 400 -bbl 0.7 51.5 3.3 5.7 0.7 5.9 3.3 0.3 0.0 0.0 0.0 0.0 Insignificant Sources 0.0 0.0 Fugitives 0.3 0.0 0.3 0.0 NG Heaters (12) 0.5 0.5 6.4 0.4 5.4 0.1 0.5 0.5 6.4 0.4 5.4 0.1 0.0 0.0 FACILITY TOTAL 0.8 0.8 0.0 0.0 49.5 747.8 0.3 55.6 26.7 0.8 0.8 0.0 0.0 11.1 42.9 0.3 19.8 2.2 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor B, C6. & Total HH: Area 7777: Area Permitted Facility Total 0.3 0.3 0.0 0 0 43.1 7414 0.0 50.2 26.6 0.31 0 31 0.01 0.0 4 7 42.5 0.0 14.41 2.1 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions _ _ _ 0.3 0 3 _ 0.0 0.0 4.7 42.5 0.0_, 14.4 Pubcom required based on new syn minor Note 1 Total VOC Facility Emissions (point (A) Change in Total Permitted VOC emissions (point and fugitive) and fugitive) r 43.2 _ Facility is not eligible for GP02 because > 90 tpy Project emissions greater than 25 tpy _ 42.5 Prior to issuance points 002 & 003 and provided a new pressurized liquid sample and Prornax model, which lowered the calculated emissions from the condensate storage tanks. of July 2018 permits, SRC cancelled Note 2 Page 7 of 8 Printed 4/25/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name SRC Energy, Inc. 123 9FE0 Ag 26-32 Pad Emissions - uncontrolled (Ibs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 `�� 0.8 \AL D ,2; 004 18WE0828 Condensate Tanks (6) x 400 -bbl 3732 3388 167 1236 31377 20.0 005 18WE0829 Condensate Loadout 1 1 " 0.1 006 GP08 Water Tanks (2) x 400 -bbl 2749 8640 5.7 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 233 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 3.3 1.7 0.1 0.6 20.2 0.0 0.0 0.0 0.0 26.7 *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 TOTAL (tPY) McOH 224 TMP H2S 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0.0 0 0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 0.8 0 .. . 004 18WE0828 Condensate Tanks (6) x 400 -bbl 187 169 8 62 1569 1.0 005 18WE0829 Condensate Loadout 0 fll _ 0.0 006 GP08 Water Tanks (2) x 400 -bbl 138 432 0.3 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 233 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 0.2 0.1 0.0 0.0 1.1 0.0 0.0 2.2 0.0 0.0 8 18WE0827.CP1.xlsm 4/25/2019 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE0828 Issuance: 1 SRC Energy, Inc. Facility Name: Plant AIRS ID: Physical Location: County: General Description: Equipment or activity Ag 26-32 Pad 123/9FE0 NENE SEC 32 T6N R66W Weld County Well Production Facility subject to this permit: Facility Equipment ID AIRS Point Equipment ' Description Emissions Control Description TK 1-6 004 Six (6) 400 barrel fixed roof storage vessels used to store condensate Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result AIRS ID: 123 9FE0 Page 1 of 9 COLORADO Air Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which 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 shall 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 shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation', Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO TK 1-6 004 --- 1.3 34.5 5.8 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate 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 emission points in the table below shall 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.) AIRS ID: 123 9FE0 Page 2 of 9 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 Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK 1-6 004 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point' Process Parameter Annual Limit TK 1-6 004 Condensate Throughput 1,144,677 barrels The owner or operator shall monitor monthly, process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be AIRS ID: 123 9FE0 Page 3 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to 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 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.17) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) AIRS ID: 123 9FE0 Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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 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. 19. The requirements of Colorado Regulation No. 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 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all AIRS ID: 123 9FE0 Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Daniel E Williams Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to SRC Energy, Inc. AIRS ID: 123 9FE0 Page 6 of 9 COLORADO Air Pollution Control Division Department of Public Health E 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 shall 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 shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria setforth in Part II.E.1 of the Common Provisions Regulation. See:'https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr)' 004 Benzene 71432 3,732 187 Toluene 108883 3,388 169 Ethylbenzene 100414 167 8 Xylenes 1330207 1,236 62 n -Hexane 110543 31,377 1,569 2,2,4- Trimethylpentane 540841 59 3 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. AIRS ID: 123 9FE0 Page 7 of 9 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0022166 0.0022166 AP -42 CO 0.0101049 0.0101049 AP -42 VOC 1.206 6.03E-2 ProMax 71432 Benzene 3.26E-3 1.63E-4 ProMax 108883 Toluene 2.96E-3 1.48E-4 ProMax 100414 Ethylbenzene 1.46E-4 7.30E-6 ProMax 1330207 Xylene 1.08E-3 5.40E-5 ProMax 110543 n -Hexane 2.74E-2 1.37E-3 ProMax 540841 2' 2'4 Trimethylpentane 5.14E-5 2.57E-6 ProMax Note: The controlled emissions factors for this point are based on the enclosed combustor 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 shall 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 thestorage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971 /oil -and - natural -gas -sector -emission -standards-for-new-reconstructed -and - modified -sources AIRS ID: 123 9FE0 Page 8 of 9 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 9) This facility is classified as €ollows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs PSD or NANSR Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs MACT HH Area Source Requirements: Not Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: / /ecf r.gpoaccess. gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK Appendix A - Appendix I NSPS Part 60, Appendixes Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MALT' 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX AIRS ID: 123 9FE0 Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Oaniei 'Williams Package U: 385022 Received Date: 7/5/2018 Review Start Date: 1/16/2019 Section 01 - Facility Information Company Name: SRC Energy, Inc. County AIRS ID: 123 Quadrant Section Township Range NENE 6N Plant AIRS ID: Facility Name: Physical Address/Location: County: 9FEO Ag 26-32 Pad NENE quadrant of Section 32, Township 6N, Range 66W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? n Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Condensate Tank Yes 18WE0828 Permit Initial Issuance Six (6) x 400 -bbl Section 03 - Description of Project SRC Energy is applying to permit five points at a new synthetic minor E&P oil and gas facility in the NAAQS nonattainment area, including 3 engines (2 of which were cancelled as of 4/19/19), condensate storage tanks, and hydrocarbon liquid loadout under construction permits. In addition, produced water storage tanks are being permitted under_ general permit GP08 Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Yes 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: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx Is this stationary source a major source? If yes, explain what programs and which pollutants her€ SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs CO VOC PM2.5 PM10 TSP HAPs ri i Condensate Storage Tank(s) Emissions Inventory 004 Condensate Tank Facility AIRs ID: 123 County 9FE0 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Six (6) x 400 -bbl fixed roof condensate storage tank connected via liquid manifold. Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Enclosed Combustor 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 1,040,615 Barrels (bbl) per year • Actual Condensate Throughput While Emissions Controls Operating = 1,040,515 Barrels (bbl) per year Requested Permit Limit Throughput = 1,144,677 Barrels (bbl) per year Requested Monthly Throughput = 97219 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput 1,144,677 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Pilot Gas Flowrate Heat content of pilot gas = Actual heat content of waste gas routed to combustion device = Btu/scf scf/bbl MMscf/yr Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? *Caclulated by taking the HHVs from the flash stream and working & breathing stream and calculating a weighted average based on the flowrate of each stream. 33,962 MMBTU per year 37,314 MMBTU per year 37,314 MMBTU per year Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (Ib/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 1.206 6.03E-02 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific EPA TANKS ES Working and Breathin Site Specific E.F. (includes flash) Site Spedfic E.F. (includes flash) Site Specific E.F. (includes flash) Site Sppolfic F.F. f includes flash) Benzene 3.26E-03 1.63E-04 Toluene 2.96E-03 1.48E-04 Ethylbenzene 1.46E-04 7.29E-06 Xylene 1.08E-03 5.40E-05 n -Hexane 2.74E-02 1.37E-03 224 TMP 5.14E -OS 2.57E-06 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 0.0002 AP -42 Table 1.4-2 (PMI0/PM.2.5) AP -42 Table 1.4-2 (PMI0/PtVl.2.5) AP -42 Chapter 13.5 industrial Flares (NOx) AP -42 Chapter 13.5 industrial Flares (CO) PM2.5 0.0075 0.0002 NOx 0.0680 0.0022 CO 0.3100 0.0100 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 690.2 627.5 31.4 690.2 34.5 5862 0.1 0.1 0.1 0.1 0.1 24 0.1 0.1 0.1 0.1 0.1 24 1.3 1.2 1.2 1.3 1.3 216 5.8 5.3 5.3 5.8 5.8 982 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene 3731 3392 170 3731 187 3384 3076 154 3384 169 167 152 8 167 8 1237 1124 56 1237 62 n -Hexane 31377 28524 1426 31377 1569 224 TMP 59 53 3 59 3 2 of 6 K:\PA\2018\18WE0828.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G 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 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 80 tons VOC per year? ISMII If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? Yes 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 Emission factors were developed from a ProMax model using a pressurized liquid sample analysis from the gas buster, which is where the final stage of separation occurs at this facility. On 4/19/19 SRC submitted a redlined APEN with a new pressurized liquid sample and updated Promax model, reducing emission estim ates. This allowed them to use 95% control efficiency, whereas in the original submissionSRC was requesting a 98% control efficiency. In addition, two of the engine APENs still in process were cancelled, dropping total contolled VOC emissions below 50 tpy. Note that emission factors and emissions differ slightly from APEN due to rounding differences. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # 01 SCC Code 444-003 Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons condensate throughput PM2.5 0.01 0 lb/1,000 gallons condensate throughput NOx 0.05 0 lb/1,000 gallons condensate throughput VOC 28.7 95 lb/1,000 gallons condensate throughput CO 0.24 0 lb/1,000 gallons condensate throughput Benzene 0.08 95 lb/1,000 gallons condensate throughput Toluene 0.07 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.03 95 lb/1,000 gallons condensate throughput n -Hexane 0.65 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 6 K:\PA\2018\18WE0828.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements 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 (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area Yes NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 andl.14 and Section 2 for additional guidance on grandfather applicability)? 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)? Source requires a permit No Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section XII.C-F Yes Yes Yes Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C2 - Emission Estimation Procedures Section XII.D - Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section XII.G Yes Yes No Section XII.G2 - Emissions Control Requirements Section X11.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C.2 - Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 No _ Yes Yes 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.C3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Yes No Storage tank is subject to Regulation 7. Section XVII.C.2 Section XVII.C2 - 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 BBLsj? 2. Does the storage vessel meet the following exemption in 60.111 b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m' (`10,000 BBL] used for petroleums or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 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 60.111b? 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 m' (-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 M' (`472 BBL) but less than 151 m' ("950 BBL) and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? No Source Req Go to next Source Req Continue -' Continue - Source is st Continue -' Storage Tar Continue -' Go to the n Go to the n Source is st Source is si. storage Tai Stcrage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions= from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. 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 OOOO Yes Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel Is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: 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' (63.160(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 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"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Stcrage Tank is not subject to MACT HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting Yes No Yes Yes 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 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. Continue - Storage Tar Continue Storage Tar Go to then Go to then COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FE0 Facility Name Aq 26-32 Pad History File Edit Date 4/24/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons er year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 0.2 0.2 41.1 1.9 41.1 0.8 0.2 0.2 2.7 1.9 5.3 0.8 Cancelled 4/19/19 Cancelled 4/19/19 004 18WE0828 Condensate Tanks (6) x 400 -bbl 0.1 0.1 1.3 690.2 5.8 20.0 0.1 0.1 1.3 34.5 5.8 1.0 005 18WE0829 Condensate Loadout 3.8 0.1 0.2 0.0 006 GP08 Water Tanks (2) x 400 -bbl 0.7 51.5 3.3 5.7 0.7 5.9 3.3 0.3 0.0 0.0 0.0 0.0 Insignificant Sources 0.0 0.0 Fugitives 0.3 0.0 0.3 0.0 NG Heaters (12) 0.5 0.5 6.4 0.4 5.4 0.1 0.5 0.5 6.4 0.4 5.4 0.1 0.0 0.0 FACILITY TOTAL 0.8 0.8 0.0 0.0 49.5 747.8 0.3 55.6 26.7 0.8 0.8 0.0 0.0 11.1 42.9 0.3 19.8 2.2 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor B, C6, & Total HH: Area 7777: Area Permitted Facility Total 0.3 0 3 0.0 0.0 43.1 747.4 0 0 50.2 26.6 0.3 0.3 0.0 0.0 4 7 42.5 0.0 14.4 2.1 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.3 _ 0.3 0.0 0.0 4 7 42.5 0.0 14.4 Pubcom required based on new syn minor Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 43.2 _ . Facility is not eligible for GP02 because > 90 tpy emissions greater than 25 tpy 42.5 Prior to issuance of July 2018 permits, SRC cancelled points 002 & 003 and provided a new pressurized liquid sample and Promax model, which lowered the calculated emissions from the condensate storage tanks. _Project Note 2 Page 5 of 6 Printed 4/25/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs 6 Company Name County AIRS ID Plant AIRS ID Facility Name SRC Energy, Inc. 123 9FE0 Aq 26-32 Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0.0 0 0 0 0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 56 1 1 !_,1 0.8 004 18WE0828 Condensate Tanks (6) x 400 -bbl 3732 3388 167 1236 31377 20.0 005 18WE0829 Condensate Loadout 1 1 1 1 2 1 0.1 006 GP08 Water Tanks (2) x 400 -bbl 2749 8640 5.7 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 3.3 1.7 0.1 0.6 20.2 0.0 0.0 0.0 0.0 26.7 *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 TMP TOTAL (tpy) H2S I Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0.0 0 0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 56 1 1 0.8 ;E. Uoo an '14.6L 004 18WE0828 Condensate Tanks (6) x 400 -bbl 187 169 62 1569 1.0 005 18WE0829 Condensate Loadout 1 1 0.0 006 GP08 Water Tanks (2) x 400 -bbl 138 432 0.3 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 0.2 0.1 0.0 0.0 1.1 0.0 0.0 2.2 0.0 0.0 18WE0828.CP1.xlsm 4/25/2019 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0829 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 SRC Energy, Inc. Ag 26-32 Pad 123/9FE0 NENE SEC 32 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LDG-1 005 Truck loadout of condensate by submerged fill Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on CDPNE COLORADO Air Pollution Control Division Department of Pubttc Health 6 Environment Page 1 of 10 how to self -certify compl° - . �'� eq, �•y the it m •- obtai _ d online at www.colorado. • ov/cd • he • - f it ifi Lion e u Lion Num r 3, Part B,, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO LDG-1 005 --- --- 0.2 --- 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 shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate 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 shall 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 shall 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. (Reference: Regulation 3, Part C. II.E.) COLORADO Air Pollution Control Division Department of Public Heath & Environment Page 2 of 10 Total potential emission potential to emit from all • 100 tons per year of VOC 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LDG-1 005 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LDG-1 005 Condensate Loaded 62,437 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, JII.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) COLORADO Air Pollution Control Division Department of Pu itc Hea:ih El Environment Page 3 of 10 12. All hydrocarbon liquid loa operated and maintained the atmosphere to the maximum extent practica. e. 13. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 14. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. COLORADO Air Pollution Control Division Deportment of Public Hearin & Environment Page 4 of 10 OPERATING Et MAINTENANCE REt 15. Upon startup of these p.='3 "° '"` ow sh he m ent 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 OItM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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 COLORADO Air Pollution Control Division Department of Pubic Health & Environment Page 5 of 10 • No later than 30 d 19. The requirements of Col _ pply a 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 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the tDPHE COLORADO Air Pollution Control Division Department of Public Health b Environment Page 6 of 10 Division in writing request;; g a c.ce&ti. ; of th it.o notifition, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Daniel E Williams Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to SRC Energy, Inc. COLORADO Mr Pollution Control Division Department of Public Health Er Environment Page 7 of 10 Notes to Permit Holder at the ti 1) The permit holder is requireees « he _31 sinhis pe An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (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 Duririg Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: //www.colorado.gov/ pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 005 Benzene 71432 14 1 Toluene 108883 13 1 Ethylbenzene 100414 1 0 Xylenes 1330207 8 0 n -Hexane 110543 148 7 2,2,4- Trimethylpentane 540841 1 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. CDPHE COLORADO Air Pollution Control Division Department of Public Heath & Environment Page 8 of 10 5) The emission levels contained r a base• 7:; foil i r emis n factors: Point 005: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.792E-04 1.792E-04 AP 42 CO 8.171E-04 8.171E-04 VOC 1.231E-01 6.157E-03 AP -42 Ch. 5.2 Eq. 1 Benzene 71432 2.194E-04 1.097E-05 ProMax model using pressurized liquid sample Toluene 108883 2.078E-04 1.039E-05 Ethylbenzene 100414 1.333E-05 6.663E-07 Xylene 1330207 1.208E-04 6.042E-06 n -Hexane 110543 2.373E-03 1.187E-04 2,2,4- Trimethylpentane 540841 1.372E-05 6.862E-07 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) = 4.3 psia M (vapor molecular weight) = 47.95 lb/lb-mol T (temperature of liquid loaded) = 525.67 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 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 shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs PSD or NANSR Synthetic Minor Source of: NOx, VOC, Benzene, n -Hexane, Total HAPs CDPHE COLORADO Air Pollution Control Division DeDartmera of Pubktc Health b Environment Page 9 of 10 8) Full text of the Title 40, Prot can be found at the website li http: //ecfr.gpoaccess.gov/ Regulations Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX CDPHE COLORADO Air Pollution Control Division Department or Public Health 6 Environment Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Daniel Williams Package #: 335022 Received Date: 7/5/2018 Review Start Date: 1/16/2019 Section 01 - Facility Information Company Name: SRC Energy, Inc. County AIRS ID: 123 Quadrant Section Township Range NENE S2 EN 66 Plant AIRS ID: Facility Name: Physical Address/Location: County: 9FE0 Ag 26-32 Pad NENE quadrant of Section 32, Township 6N, Range 66W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ■ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application • Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks C : Liquid Loading LDG-1 ; r.:. 18WE0829 Permit Initial Issuance Section 03 - Description of Project SRC Energy is applying to permit five points at a new synthetic minor E&P oil and gas facility in the NAAQS nonattainment area, including 3 engines (2 of which were cancelled as of 4/19/19), condensate storage tanks, and hydrocarbon liquid loadout under construction permits. In addition, produced water storage tanks are being permitted under general permit GP08. 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: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 Is this stationary source a major source? If yes, explain what programs and which pollutants hen SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes NOx CO VOC J J J N� NOx CO VOC PM2.5 PM10 TSP HAPs • PM2.5 PM10 TSP HAP, p, • Hydrocarbon Loadout Emissions Inventory 005 Liquid Loading 'Facility AIRs ID: 123 County 9FE0 Plant 005 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Loadout of condensate to tank trucks, when LACT transfer is not available. Enclosed combustor. 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 52,031 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 52,031 Barrels (bbl) per year Requested Permit Limit Throughput = 62,43 ' Barrels (bbl) per year Requested Monthly Throughput = 5303 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 62,437 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2707.63 Btu/scf Volume of waste gas emitted per year = 60779 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46*S*P*M/T 137 MMBTU per year 165 MMBTU per year 165 MMBTU per year No A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor. Factor Meaning Value Units Source S Saturation Factor 0.6 D f�%r%%- P True Vapor Pressure 4.3 psia AP -42 Table 7.1-2 (Gasoline RVP 7 @ 70 F) M Molecular Weight of Vapors 47.9448 lb/lb-mol ProMax Working & Breathing stream T Liquid Temperature 525.67 Rankine Conservative estimate L Loading Losses 2.932014185 lb/1000 gallons 0.123144596 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.001781316 0.000219359 lb/bbl ProMax Working & Breathing stream, as fraction of VOC content Toluene 0.001687595 0.000207818 lb/bbl ProMax Working & Breathing stream, as fraction of VOC content Ethylbenzene 0.000108219 1.33266E-05 lb/bbl ProMax Working & Breathing stream, as fraction of VOC content Xylene 0.000981237 0.000120834 lb/bbl ProMax Working & Breathing stream, as fraction of VOC content n -Hexane 0.019271909 0.002373231 lb/bbl ProMax Working & Breathing stream, as fraction of VOC content 224 TMP 0.000111454 1.3725E-05 lb/bbl ProMax Working & Breathing stream, as fraction of VOC content Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 1.231E-01 6.157E-03 .specific- AP -42: Chapter 5.2, Equation 1 Benzene 2.194E-04 1.097E -0S . Specific - AP -42: Chapter 5.2., Equation 1 Toluene 2.078E-04 1.039E-05 Specific - AP -42: Chapter 5.2, Equation 1 Specific - AP -42: Chapter 5.2, Equation 1 • Specific - AP -42: Chapter 5.2, Equation 1 . Specific- AP -42: Chapter 5.2, Equation 1 Specific - AP -42: Chapter 5.2, Equation 1 Ethylbenzene 1.333E-05 6.663E-07 Xylene 1.208E-04 6.042E-06 n -Hexane 2.373E-03 1.187E-04 224 TMP 1.372E-05 6.862E-07 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 1.961E-05 ' 42 Table 1.4-2 (PM1O/PM.2S) 42 Table 1.4-2 (PM10/PM.2.5) 412 Table 1.4-2 (SOx) a-,'-42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 1.964E-05 SOx 0.0006 1.550E-06 NOx 0.0680 1.792E-04 CO 0.3100 8.171E-04 2 of 6 K:\PA\2018\18WE0829.CP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/mc nth) PM10 PM2.5 SOx N O x VOC CO 0.00 0.0005 0.0005 0.0006 0.0006 0.1041 0.00 0.0005 0.0005 0.0006 0.0006 0.1041 0.00 0.0000 0.0000 0.0000 0.0000 0.0082 0.01 0.00 0.00 0.01 0.01 1.3 3.84 3.20 0.16 3.84 0.19 32.7 0.03 0.02 0.02 0.03 0.03 4.3 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) ('bs/year) Benzene 14 11 1 14 1 Toluene 13 11 1 13 1 Ethylbenzene 1 1 0 1 0 Xylene 8 6 0 8 0 n -Hexane 143 123 6 148 7 224 TMP 1 1 0 1 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 of inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Operator utilized a pressurized liquid sample to model Working and Breathing emissions properties and composition using Promax. Under normal operating conditions condensate is sent to pipeline through a LACT meter. Truck loading will be available during pipeline or L\CT downtime. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process # 01 SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 2.9 95 lb/1,000 gallons transferred CO 0.02 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.06 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 3 of 6 K:\PA\2018\18WE0829.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source us n 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 II.D.1.l)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.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)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? Yes Yes No No No Yes Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? No The Icadout 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 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 Go to next Go to the n Go to next Go to next Go to next The loadou The loadou COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FE0 Facility Name Ag 26-32 Pad History File Edit Date 4/24/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons py er ear POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 0.2 0.2 41.1 1.9 41.1 0.8 0.2 0.2 2.7 1.9 5.3 0.8 Cancelled 4/19/19 Cancelled 4/19/19 004 18WE0828 Condensate Tanks (6) x 400 -bbl 0.1 0.1 1.3 690.2 5.8 20.0 0.1 0.1 1.3 34.5 5.8 1.0 005 18WE0829 Condensate Loadout 3.8 0.1 0.2 0.0 006 GP08 Water Tanks (2) x 400 -bbl 0.7 51.5 3.3 5.7 0.7 5.9 3.3 0.3 0.0 0.0 0.0 0.0 Insignificant Sources 0.0 0.0 Fugitives 0.3 0.0 0.3 0.0 NG Heaters O2) 0.5 0.5 6.4 0.4 5.4 0.1 0.5 0.5 6.4 0.4 5.4 0.1 0.0 0.0 FACILITY TOTAL 0.8 0.8 0.0 0.0 49.5 747.8 0.3 55.6 26.7 0.8 0.8 0.0 0.0 11.1 42.9 0.3 19.8 2.2 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor B, C6. & Total HH: Area 7777: Area Permitted Facility Total 0.3 0.3 0.0 0.0 43. 1 747 4 0.0 50.2 26.6 0.3 0.3 0.0 0.0 4.7 42.5 0.0 14.4 2.1 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.3 _ 0.3 0.0 0.0 4.7 42.5 0.0 14.4 Pubcom required based on new syn minor Note 1 i Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 43.2 v Facility is not eligible for GP02 because > 90 tpy emissions greater than 25 tpy 42.5 Prior to issuance of July 2018 permits, SRC cancelled points 002 & 003 and provided a new pressurized liquid sample and Promax model, which lowered the calculated emissions from the condensate _ storage tanks. _Project Note 2 Page 5 of 6 Printed 4/25/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs 6 Company Name County AIRS ID Plant AIRS ID Facility Name SRC Energy, Inc. 123 9FE0 Ag 26-32 Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes TOTAL (tpy) n -Hexane McOH 224 TMP H2S 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0.0 0 0 0 0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 56 0.8 r, iv E�u82ta kick. Euoosan 14.€ 1 004 18WE0828 Condensate Tanks (6) x 400 -bbl 3732 3388 167 1236 31377 20.0 r9 005 18WE0829 Condensate Loadout it; ; : 1 0.1 i 1 006 GP08 Water Tanks (2) x 400 -bbl 2749 8640 5.7 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) ;,"'" 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 3.3 1.7 0.1 0.6 26.7 20.2 0.0 0.0 0.0 0.0 I `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 TOTAL (tpy) McOH 224 TMP H2S (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0.0 0 0 0 001 18WE0825 RICE: Caterpillar G3406TA/JGA4 1439 r ' 1 1 0.8 61 ICE Donsan 1 1. 1 t_ 004 18WE0828 Condensate Tanks (6) x 400 -bbl 187 169 8 62 1569 1.0 005 18WE0829 Condensate Loadout 0 0.0 006 GP08 Water Tanks (2) x 400 -bbl 138 0.3 432 0.0 0.0 Insignificant Sources 0.0 Fugitives 0.0 NG Heaters (12) 0.1 0.0 TOTAL (tpy) 0.7 0.0 0.0 0.2 0.1 0.0 0.0 1.1 2.2 0.0 0.0 0.0 0.0 I 18WE0829.CP1.xlsm 4/25/2019 Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. RECEIVED JUL 05gig APCD Stationer` This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: IS W g Off'' AIRS ID Number: (� FRY txA [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: Ag 26-32 Pad Site Location: NENE Sec. 32 T6N R66W Mailing Address: (Include Zip code) 5400 W. 11th Street, Suite C Portable Source Home Base: Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Phone Number: E -Mail Address2: Brad Rogers (970) 475-5242 brogers@srcenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 385013 'AV COLORADO Department al wauc H.allh b Enr�ro.i�nnn� l' Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑✓ STATIONARY source ❑ PORTABLE source ❑✓ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment 0 Change company name 0 Add point to existing permit O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario (AOS) permanent replacements Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes If yes, provide the Company Equipment Identification No. ENG-1 General description of equipment and purpose: VRU Compressor Engine For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.gov/cdphe/attainment) Normal Hours of Source Operation: 24 Seasonal use percentage: Dec -Feb: 25 4/6/2018 0 Yes ❑ No hours/day 7 days/week 52 weeks/year Mar -May: 25 June -Aug: 25 Sept -Nov: 25 Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 • V COLORADO 2 ==,=, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑✓ Primary and/or Peaking ❑ Pump 0 Water Pump ❑ Emergency Back-up ❑ Other: 0 Compression What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Caterpillar What is the maximum designed horsepower rating? 276 — hp What is the engine displacement? 2.44 1/cyl hours/year Engine Model: G3406TA/JGA4 Serial Number6: 4FD04835 What is the maximum manufacturer's site -rating? 276 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 8228 ' BTU/hp-hr Engine Features: Cycle Type: 0 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑ Lean Burn 0 Rich Burn Ignition Source: ❑✓ Spark ❑ Compression Aspiration: ❑ Natural ❑✓ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes ❑ No If yes, what type of AFRC is in use? ❑✓ Oz Sensor (mV) ❑NOX Sensor (ppm) Is this engine equipped with a Low-NOX design? ❑ Yes 0 No Engine Dates: What is the manufactured date of this engine? 10/1/2014 What date was this engine ordered? unknown ❑ Other: What is the date this engine was first located to Colorado? unknown What is the date this engine was first placed in service/operation? 4/6/2018 What is the date this engine commenced construction? March 2018 What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 AV COLORADO 3 ,Q]> 5=1..z. --„..c. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.449075/-104.794558 Operator _ Stack ID No. Discharge Height Above Ground Level (Feet) Temp ("F) Flow Rate (ACFM) { Velocity (ft/sec) ENG-1 8 1045 1063 129.93 Indicate the direction of the Stack outlet: (check one) O Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/Rectangle O Other (describe): Interior stack diameter (inches): 5 O Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate 0. 100% Loa ' Load.',.: _ (SCF/hour) _.; Actual Annual Fuel Use .(MMSCF/year)- _ Requested Annual Permit Limit' ". (MMSCF%year) _ 1116.40 . 9.78 9.78 From what year is the actual annual amount? 2018 Indicate the type of fuel used: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: 2034 / BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) O Landfill Gas Heating Value: BTU/scf ❑ Other (describe): Heating Value (give units): 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 4 I AAV COLORADO V ==t, Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) PM10 PM2.5 SOX NOx NSCR Catalyst 93.5 % VOC CO NSCR Catalyst 87% Other: Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2018 _Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions 9 Requested Annual Permit Emission Limit(s)7,:'.. Pollutant Uncontrolled Basis Units Source (AP -42, Mfg. etc) ' Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) TSP (PM) 1.94E-02 lb/MMBtu AP -42 1.93E-01 1.93E-01 .- 1.93E-01 1.93E-01 t PM10 9.50E-03 lb/MMBtu AP -42 9.45E-02 9.45E-02 9.45E-02 9.45E-02 PM2.5 9.50E-03 lb/MMBtu AP -42 9.45E-02 9.45E-02 9.45E-02 9.45E-02 SOX 5.88E-04 lb/MMBtu AP -42 5.85E-03 5.85E-03 5.85E-03 5.85E-03 NO 15.41 g/hp-hr Mfg. 41.03 2.66 " 41.03 c 2.66 VOC 0.70 g/hp-hr Mfg. 1.86 , 1.86 1.86 1.86 CO 15.41 g/hp-hr Mfg. 41.03 5.33 - 41.03 " 5.33 Does the emissions source have any uncontrolled actual emissions of non -criteria ❑✓ Yes pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: ❑ No Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions9 Chemical Name Abstract Service (CAS) Number Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/ year) Controlled Emissions (Pounds/year) Formaldehyde 50000 0.27 g/hp-hr Mfg. 1,437.87 - 1,437.87 Acetaldehyde 75070 2.79E-03 lb/MMBtu AP -42 55.50 i 55.50 Acrolein 107028 2.63E-03 lb/MMBtu AP -42 52.32 / 52.32 Benzene 71432 1.58E-03 lb/MMBtu AP -42 31.43 / 31.43 Other: 67561 3.06E-03 lb/MMBtu AP -42 60.87 , 60.87 , 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 5 I COLORADO ileparanant al Public Hsal:h 6 EYontunmani I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will be operated in full compliance with each condition of general permit GP02. 7) 7/3/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $1,500, if applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 6 1A7 'JepaNnmt P 4c Ha.l:l� 6 Fiv..onman. Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I'JEO2(o AIRS ID Number: Ei3 /qx 662 — [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: Ag 26-32 Pad Site Location: NENE Sec. 32 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Portable Source Home Base: Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brad Rogers Phone Number: E -Mail Address2: (970) 475-5242 brogers@srcenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 385014 COLORADO Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 1 IAVE ,:"TMt, Permit Number: AIRS ID Number: / I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source (check one below) ✓❑ STATIONARY source ❑ PORTABLE source ❑r Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name ❑ Add point to existing permit D Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario (AOS) permanent replacements Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes If yes, provide the Company Equipment Identification No. ENG-2 General description of equipment and purpose: Generation of Electricity For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.gov/cdphe/attainment) Normal Hours of Source Operation: 24 Seasonal use percentage: Dec -Feb: 25 4/6/2018 E Yes ❑ No hours/day 7 days/week 52 weeks/year Mar -May: 25 June -Aug: 25 Sept -Nov: 25 Form APCD-201 - Reciprocating Internal Combustion Engine. APEN - Revision 1/2017 COLORADO 2 IAV Naa1 6Enu xm¢v Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine ❑✓ Primary and/or Peaking ❑ Emergency Back-up ❑ Compression Function: ❑ Pump ❑ Water Pump ✓❑ Other: Generation of Electricity What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Doosan Engine Model: 14.6L hours/year Serial Number6: EEZOG400855 What is the maximum designed horsepower rating? 390 __ hp What is the engine displacement? 1.83 l/cyl What is the maximum manufacturer's site -rating? 390 i hp 291 kW What is the engine Brake Specific Fuel Consumption at 100% Load? 14,509 - BTU/hp-hr Engine Features: Cycle Type: O 2 -Stroke 0 4 -Stroke Combustion: ❑ Lean Burn 0 Rich Burn Ignition Source: 0 Spark ❑ Compression Aspiration: ❑ Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑ Yes ❑✓ No If yes, what type of AFRC is in use? O OZ Sensor (mV) ❑NOx Sensor (ppm) Is this engine equipped with a Low-NOx design? ❑ Yes 0 No Engine Dates: What is the manufactured date of this engine? 6/26/2014 What date was this engine ordered? unknown O Other: What is the date this engine was first located to Colorado? unknown What is the date this engine was first placed in service/operation? 4/6/2018 What is the date this engine commenced construction? March 2018 What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 ®V COLORADO 3 m�'�� 4uP1[11 �M1 Envvanmem (I; Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] il Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.449075/-104.794558 Operator, . Stack ID No. Discharge Height Above Ground Level (Feet) Temp ('F) Flow Rate (ACFM) Velocity (ft/sec)` ENG-2 10 1350 1895 90.5 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): 8 ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate® 100% Load •- (SCF/hour) _; Actual Annual Fuel Use (MMSCF/year) Requested Annual Permit Lima (MMSCFIyear) -- 2781.76 , 24.37 - 24.37 / From what year is the actual annual amount? 2018 Indicate the type of fuel used': ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑ Field Natural Gas Heating value: 2034 / BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑ Other (describe): Heating Value (give units): 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. $ If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 4 eiaaltfi 6� v. Tnr= Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) PM10 PM2.5 SOX NOx NSCR Catalyst 93% vOC CO NSCR Catalyst 92% - Other: Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions' Requested Annual Permit Emission Limit(s) `- Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units _ (AP -42, Mfg. etc) Emissions ` (Tons/year) Emissions (Tons/year) Emissions (Tons/year) Emissions (Tons/year) TSP (PM) 1.94E-02 lb/MMBtu AP -42 4.81E-01 4.81E-01 . 4.81E-01 4.81E-01 PM10 9.50E-03 lb/MMBtu AP -42 2.35E-01 2.35E-01 2.35E-01 2.35E-01 PM2.5 9.50E-03 lb/MMBtu AP -42 2.35E-01 2.35E-01 2.35E-01 2.35E-01 SOX 5.88E-04 lb/MMBtu AP -42 1.46E-02 1.46E-02 1.46E-02 1.46E-02 NOx 2.21 lb/MMBtu AP -42 54.77 / 3.76 54.77 — 3.76 .- VOC 0.70 g/hp-hr Regulatory Limit 2.63 / 2.63 2.63 — 2.63 CO 3.72 lb/MMBtu AP -42 92.20 -- 7.53 ' 92.20 � 7.53 ,- Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: ❑✓ Yes ❑ No Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions9 Chemical Name Abstract Service (CAS) Number Uncontrolled Basis Units source (AP -42, . Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions (Pounds/year) Formaldehyde 50000 2.05E-02 lb/MMBtu AP -42 1,016.16 - 1,016.16 Acetaldehyde 75070 2.79E-03 lb/MMBtu AP -42 138.30 i 138.30 Acrolein 107028 2.63E-03 lb/MMBtu AP -42 130.37 / 130.37 Benzene 71432 1.58E-03 lb/MMBtu AP -42 78.32 ! 78.32 Other: 67561 3.06E-03 lb/MMBtu AP -42 151.68 151.68 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO 5 I " 5� Hulery6mro n F v4onmaN Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will be operated in full compliance with each condition of general permit GP02. 7/3/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $1,500, if applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 6 I®V COLORADO Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ( UJ l AIRS ID Number: ('2j) gFEO' 0o3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: Ag 26-32 Pad Site Location: NENE Sec. 32 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Portable Source Home Base: Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Phone Number: E -Mail Address2: Brad Rogers (970) 475-5242 brogers@srcenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 385015 COLORADO 1 ��iiii Haalth Env o mnnl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source (check one below) ▪ STATIONARY source ❑ PORTABLE source ❑✓ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,500.00 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 name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario (AOS) permanent replacements Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes If yes, provide the Company Equipment Identification No. ENG-3 General description of equipment and purpose: Generation of Electricity For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.Rov/cdphe/attainment) Normal Hours of Source Operation: 24 Seasonal use percentage: Dec -Feb: 25 4/6/2018 0 Yes ❑ No hours/day 7 days/week 52 weeks/year Mar -May: 25 June -Aug: 25 Sept -Nov: 25 Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN Revision 1/2017 2 ' ®� COLORADO H.uI�TbEnu awm .0 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑✓ Primary and/or Peaking ❑ Emergency Back-up ❑ Compression ❑ Pump ❑ Water Pump 2 Other: Generation of Electricity What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Doosan Engine Model: 11.1L hours/year Serial Number6: EEIOH403746 What is the maximum designed horsepower rating? 268 — hp What is the engine displacement? 1.85 l/cyl What is the maximum manufacturer's site -rating? 268 7- hp 200 kW What is the engine Brake Specific Fuel Consumption at 100% Load? 16,052 / BTU/hp-hr Engine Features: Cycle Type: El 2 -Stroke 0 4 -Stroke Combustion: ❑ Lean Burn ❑✓ Rich Burn Ignition Source: 0 Spark ❑ Compression Aspiration: ❑ Natural ❑✓ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑ Yes ❑✓ No If yes, what type of AFRC is in use? ❑ O2 Sensor (mV) ❑NOX Sensor (ppm) Is this engine equipped with a Low-NOX design? ❑ Yes ❑r No Engine Dates: What is the manufactured date of this engine? 8/12/2014 What date was this engine ordered? ❑ Other: What is the date this engine was first located to Colorado? What is the date this engine was first placed in service/operation? 4/6/2018 What is the date this engine commenced construction? March 2018 What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 3 AVCOLORADO N".� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.449075/-104.794558 • Operator ' • Stack ID No. Discharge Height Above Ground (_eve Temp. (` F) Flow Rate -1 (ACFM) „ Velocity (ft/sec). - ENG-3 10 1350 1425 68.0 Indicate the direction of the Stack outlet: (check one) El Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): 8 ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate ® 1OO% Load -. '=(SCFLhour) _° '_ ' Actual Annual Fuel Use .. (MMSCF/ year)Y Requested Annual Permit Limit? '. (MMSCF_/ year) 2,114.85 / 18.53 / 18.53 From what year is the actual annual amount? 2018 Indicate the type of fuel used': ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ✓❑ Field Natural Gas Heating value: 2034 BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑ Other (describe): Heating Value (give units): 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 8 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 4 I AVCOLORADO ,',Z b 4 ot, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ['Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) PM10 PM2.5 SOX NO NSCR Catalyst 94% vOC CO NSCR Catalyst 93% Other: Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory _ Emission Factor Actual Annual Emissions9 Requested Annual Permit Emission Limit(s). Pollutant Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions - (Tons/year) TSP (PM) 1.94E-02 lb/MMBtu AP -42 3.66E-01 . 3.66E-01 l 3.66E-01 / 3.66E-01 PM 10 9.50E-03 lb/MMBtu AP -42 1.79E-01 1.79E-01 1.79E-01 1.79E-01 PM2.5 9.50E-03 lb/MMBtu AP -42 1.79E-01 1.79E-01 1.79E-01 1.79E-01 SOX 5.88E-04 lb/MMBtu AP -42 1.11E-02 1.11E-02 1.11E-02 1.11E-02 NO 2.21 lb/MMBtu AP -42 41.64 - 2.59, 41.64 - 2.59 VOC 0.70 g/hp-hr Regulatory Limit 1.81 ' 1.81 / 1.81 - 1.81 -- CO 3.72 lb/MMBtu AP -42 70.09 / 5.17 70.09 / 5.17 Does the emissions source have any uncontrolled actual emissions of non -criteria ❑✓ Yes pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: ❑ No Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions' Chemical Name Abstract ServiceUncontrolled (CAS) Basis Units Number Mfg. etc) (Pounds/ Source (AP -42, Uncontrolled Emissions year) Controlled Emissions (Pounds/ year) Formaldehyde 50000 2.05E-02 lb/MMBtu AP -42 772.54 / 772.54 ---- Acetaldehyde 75070 2.79E-03 lb/MMBtu AP -42 105.14 , 105.14 / Acrolein 107028 2.63E-03 lb/MMBtu AP -42 99.11 - 99.11 / Benzene 71432 1.58E-03 lb/MMBtu AP -42 59.54 - 59.54 ...- Other: 67561 3.06E-03 lb/MMBtu AP -42 115.32/ 115.32.- 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. v Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. I; Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 5 I AlCOLORADO 7 =7, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assiened 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of general permit GP02. 7/3/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (please print) Title Check the appropriate box to request a copy of the: E Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $1,500, if applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https: //www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 6VIN I COLORADO Y Sc c ) Se -!_1 - Sew— A.Ftp�t k� APEiJ P�,du.w. 69 %tit i2o i `t Condensate Storage Tank(s) APEN - Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: RECEIVED JUL, I52018 APCD StationtAry Sources 46wt °gi n AIRS ID Number: 12 gmot o + [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: Ag 26-32 Pad Site Location: NENE Sec. 32 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brad Rogers Phone Number: E -Mail Address2: (970) 475-5242 brogers@srcenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017 385016 1 I jeCOLORADO llf scut nl PJv�c Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source r❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) El Change in equipment ❑ Change company name O Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Storage of condensate from production wells For new or reconstructed sources, the projected start-up date is: 4/6/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 El Exploration Et Production (EEtP) site weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? O Yes ■ No Are Flash Emissions anticipated from these storage tanks? 0 Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? I0 Yes • No If "yes", identify the stock tank gas -to -oil ratio: 0.012 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No 0 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 ®V COLORADO 2 I ,=-Z,""`m�¢..0 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbllyear) Requested Annual Permit Limit4 (bbllyear) Condensate Throughput: 1,040,615 1,248,738 From what year is the actual annual amount? Average API gravity of sales oil: 49 degrees 0 Internal floating roof 2018 Tank design: ❑✓ Fixed roof RVP of sales oil: 7.07 0 External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First - Production (month/year) TK 1-6 6 -400' 2400 3/2018 4/2018 Wells Serviced by this Storage Tank or Tank Battery5 (EftP Sites Ony) API Number Name of Well Newly Reported Well 05 - 123 - 44873 Ag # 5C -31-L ri 05 - 123 - 44874 Ag # 4N-31 B -L 19 05 - 123 - 44875 Ag # 31 N-31 B -L 12 05 - 123 - 44876 Ag # 31 N-31 C -L IV 05 - 123 - 44877 Ag # 32C -31-L Fl 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.449075/-104.794558 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward 0 Horizontal 0 Downward 0 Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle 0 Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 AV COLORADO 3 I AV Mo m Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 142 Type: Enclosed Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 1,076 F MMBtu/hr Make/Model: (2) I ES 96" 98 98 % Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2,627 0.051 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 12 psig Describe the separation process between the well and the storage tanks: (12) 36" 3 -phase horizontal separators, (6) 36" 2 -phase vertical separators and (1) 60" gas buster Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 4 I g7COLORADO ,=== Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 98% NOx CO HAPs ECD 98% Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons! ear Y ) Controlled Emissions7 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 6.886 - Ibs/bbl ProMax 3,582.777 71.66 / 4,299.32' 85.99 - NOx 0.068 .- Ib/MMBtu AP -42 N/A 6.25 , N/A 7.50 - CO 0.31 ' Ib/MMBtu AP -42 N/A 28.49 - N/A 34.19 ' Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor6 Actual Annual Emissions Chemical Name Abstract Service CAS (CAS) Uncontrolled Units Source (AP -42, Uncontrolled Emissions Controlled Emissions7 Number Basis Mfg. etc) g Pounds/ ear (Pounds/year) ) (Pounds/year) Benzene 71432 1.75E-02 ' lbs/bbl ProMax 18,200.53 ' 364.01 ' Toluene 108883 1.55E-02 / Ibs/bbl ProMax 16,129.73 - 322.59 Ethylbenzene 100414 8.93E-04 ' lbs/bbl ProMax 929.27 / 18.59 Xylene 1330207 8.81E-03 ' Ibs/bbl ProMax 9,167.82 / 183.36 ' n -Hexane 110543 1.19E-01 - Ibs/bbl ProMax 123,407.56 / 2,468.15 2,2,4- Trimethylpentane 540841 0.00 Ibs/bbl ProMax 0.00 0.00 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017 5 Ay COLORADO Departmental 6 L.v..nnm.,u Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit n and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 7/3/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager 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 $152.90 and the General Permit registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 6 I AlCOLORADO fr �,a , i•Ock \/ t C Condensate Storage Tank(s) APEN - Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 18WE0828 AIRS ID Number: 123 / 9FE0 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: SRC Energy, Inc. Ag 26-32 Pad Site Location: NENE Sec. 32 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brad Rogers Phone Number: (970) 475-5242 E -Mail Address2: brogers@srcenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 nY,=,,, 1 I m .COLORADO ,-.moo ALIrt Permit Number: 18WE0828 AIRS ID Number: 123 / 9FE0 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. OR - • MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name O Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Combustor pilot light emissions have been added to the requested controlled emissions for NOx and CO. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Storage of condensate from production wells 4/6/2018 For new or reconstructed sources, the projected start-up date is: N/A Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ❑✓ Exploration a Production (EaP) site 52 weeks/year O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? • Yes • No Are Flash Emissions anticipated from these storage tanks? SI Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? • Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 2.23E-03 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No i • Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 COLORADO 2 I AV o�,m..rt 7�� NWN6 EnuNaemartt Permit Number: 18W E0828 AIRS ID Number: 123 / 9FE0 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbllyear) Requested Annual Permit Limit4 (bbl/year) Condensate Throughput: 1,040,615 1,144,676.5 From what year is the actual annual amount? Average API gravity of sales oil: 49 degrees ❑ Internal floating roof 2018 Tank design: ✓❑ Fixed roof RVP of sales oil: 9.5 O External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK 1-6 6 400 3/2018 4/2018 Wells Serviced by this Storage Tank or Tank Battery5 (EttP Sites On y) API Number Name of Well Newly Reported Well 05 - 123 - 44873 Ag # 5C -31-L Fl 05 - 123 - 44874 Ag # 4N-31 B -L Fl 05 - 123 - 44875 Ag # 31 N-31 B -L Fl 05 - 123 - 44876 Ag # 31 N-31 C -L Fl 05 - 123 - 44877 Ag # 32C -31-L NI 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EaP 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) 40.449075/-104.794558 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): O Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other (describe): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 3 Ay, Department of NU. COLORADO Permit Number: 18WE0828 AIRS ID Number: 123 / 9FE0 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor El Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 138 MMBtu/hr Make/Model: (2) IES 96" Type: Enclosed Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 1,076 F 95 98 Waste Gas Heat Content: 2,548 Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: 0.051 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 10.7 psig Describe the separation process between the well and the storage tanks: (12) 36" 3 -phase horizontal separators, (6) 36" 2 -phase vertical separators and (1) 60" gas buster Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 COLORADO • 4 I AV Hey b Enr,ronm n, Permit Number: 18W E0828 AIRS ID Number: 123 / 9FE0 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95%. NOx CO HAPs ECD 95% Other: ' From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant VOC Emission Factor6 Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis lbs/bbl Uncontrolled Emissions (Tons/year) Controlled Emissions? (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) 1.206 ProMax 627.46 31.37 690.21 34.51 NOx 0.068 Ib/MMBtu AP -42 N/A 1.04 N/A 1.27 CO 0.31 lb/MMBtu AP -42 N/A 4.76 N/A 5.78 Non -Criteria Reportable Pollutant Emissions Inventory :- Chemical Name Chemical Abstract (CAS) Service CAS Number Emission Factor° Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) ) Uncontrolled Emissions (Pounds/ ear ) y Controlled Emissionsz (Pounds/year) Benzene 71432 3.26E-03 lbs/bbl ProMax 3,392.40 169.62 Toluene 108883 2.96E-03 lbs/bbl ProMax 3,080.22 154.01 Ethylbenzene 100414 1.46E-04 Ibs/bbl ProMax 151.93 7.60 Xylene 1330207 1.08E-03 lbs/bbl ProMax 1,123.86 56.19 n -Hexane 110543 2.74E-02 lbs/bbl ProMax 28,524.45 1,426.22 2,2,4- Trimethylpentane 540841 5.14E-05 lbs/bbl ProMax 53.49 2.67 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 COLORADO 5 I AY' ° °rcnvi r,}�� HWN}Envirnr.n� Permit Number: 18WE0828 AIRS ID Number: 123 / 9FE0 / 004 [Leave blank unless APCD has already assigned a permit JI and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. g2/ ZO/ Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 © COLORADO 6 t33� e �: 11 Rb F»,vonrr� Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: IS ° e() g'�� AIRS ID Number: f / ooc [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: LDG-1 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: SRC Energy, Inc. Ag 26-32 Pad Site Location: NENE Sec. 32 T6N R66W Mailing Address: (Include zip code) 5400 W. 11th Street, Suite C Greeley, CO 80634 E -Mail Address2: brogers@srcenergy.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brad Rogers Phone Number: (970) 475-5242 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 -.Hydrocarbon Liquid Loading APEN - Rev 02/2017 385018 1 I AlCOLORADO f el Punt. ,\N\' Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and so S Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name ❑ Change permit limit El Transfer of ownership3 ❑ Other (describe below) OR ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Truck loading of condensate from storage tanks. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 4/ 6 /2018 Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? 0 Yes ❑ No O Yes 0 No ❑ Yes ❑✓ No 0 Yes ❑ No O Yes ❑ No O Yes ❑ No ❑ Yes 0 No Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 ®V COLORADO 2 I oea�neni etswu� Xul« 6 Eaav,romm�m Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: E Condensate ❑ Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth 62,437 Bbl/yr 52,031 Bbt/yr This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") Actual Volume Loaded: Tank Trucks If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 66.1 ° F True Vapor Pressure 5Asia 60 °F Molecular weight of displaced vapors 47.94 Lb/lb-mol Li - If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: Bbl/yr Actual Volume Loaded: Bbl/yr 4 Requested values will become permit limitations. Requested limits) should consider future process growth Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 ® 1 COLORADO 3 I �o��° q�ult� be rn°,�°,�m.o, Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.449075/-104.794558 Operator . P Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (:F) Flow Rate ` (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward O Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system: Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 15.33 MMBtu/hr Type: Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 1,076 F Make/Model: LEED 48" 95 98 % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 2,708 Btu/scf 0.10 MMBtu/hr O Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 4I A` „whh..m4n, (14 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑✓ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2018 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions _i' - Requested Annual Permit Limit(ss 5 ( ) ._ Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO. VOC 1.23E-01 lbs/bbl ProMax 3.20 - 0.16 - 3.84 - 0.19 -- CO Benzene 2.19E-04 lbs/bbl ProMax S.-11 E-03 � 2.85E-04 ,- ((.BS E-03,- 3.42E-04/ Toluene 2.08E-04 lbs/bbl ProMax S:�1 E-03 / 2.70E-04 '- 4..41 E-03 -7 3.24E-04/ Ethylbenzene 1.33E-05 Ibs/bbl ProMax ',NT E-04 1.73E-05 , 4.16E-04 , 2.08E-05,. Xylenes 1.21 E-04 Ibs/bbl ProMax 3.14E-03 / 1.57E-04 - 3.77E-03 ill E-04� n -Hexane 2.37E-03 lbs/bbl ProMax 6.17E-02 / 3.09 E-03 / 7.4i E-02 .- 3.70E-03 . 2,2,4- Trimethylpentane M•316 -a' Ibs/bbl ProMax - 3.S7E°9 O1l .- s 4:2-1-`d'i l -OS -2...p4. Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 5 I AyCOLORADO bep en,4, Public Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 7/3/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 6 I eV [=77.7,rat ,t Hwi:fl6 Enu:ronmoni 3/4/2019 State.co.us Executive Branch Mail - Response to Dan Williams, APCD concerning SRC Energy Ag 26-32 Pad STATE OF COLORADO Williams - CDPHE, Dan <dan.e.williams@state.co.us> Response to Dan Williams, APCD concerning SRC Energy Ag 26-32 Pad Mark Losowski <mlosowski@ltenv.com> To: "Williams - CDPHE, Dan" <dan.e.williams@state.co.us>, Daniel Ryan <dryan@ltenv.com> Cc: Brad Rogers <brogers@srcenergy.com>, Steve Kahn <skahn@ltenv.com> Fri, Mar 1, 2019 at 2:37 PM Hello Dan, We have reviewed the three redlined APENs provided in your previous email and agree with all suggested changes. Attached is an O&M plan for the Hydrocarbon Loadout source. Please let us know if you need any additional information for the Ag 26-32 application. Thank you, Mark_L:osowski ---- — — Staff Air Quality Scientist 720.539.0243 cell 303.962.5516 direct 4600 West 60th Avenue Arvada, CO 80003 www.ltenv.com disclosure. ..-Think before you print. Click for our email From: Williams - CDPHE, Dan <dan.e.williams@state.co.us> Sent: Wednesday, February 27, 2019 11:30 AM To: Daniel Ryan <dryan@ltenv.com> Cc: Brad Rogers <brogers@srcenergy.com>; Mark Losowski <mlosowski@ltenv.com> [Quoted text hidden] [Quoted text hidden] httns://mail.aooalie.com/mail/u/0?ik=fad3271603&view=pt&search=all&permmsgid=msg-f%3A1626840766222731318&simpl=msg-f%3A16268407662... 1/2 Hello