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HomeMy WebLinkAbout20193972.tiffRECEIVED bg,a- COLORADO Department of Public Health Et Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 November 19, 2019 Dear Sir or Madam: NOV 2 5 2019 WELD COUNTY COMMISSIONERS On November 20, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Enerplus Resources (USA) Corporation - Irish Well Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pvbl c Rev;ew cc: o�� j,Hi_(l.x),Pw(rh/ER c) /cH/c, 11 /0°l/19 laiov19 44 T3\ dtotq -397a Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Enerplus Resources (USA) Corporation - Irish Well Pad - Weld County Notice Period Begins: November 20, 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: Enerplus Resources (USA) Corporation Facility: Irish Well Pad gas plant SWSE, Section 26, T8N, R67W Weld County The proposed project or activity is as follows: operator requests to permit a gas plant set up on a well pad 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 18WE1125 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.Qov/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: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health & Environment COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE1125 Issuance: 1 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Enerplus Resources (USA) Corporation Irish Well Pad 123 9FD9 SWSE, Section 26, T8N R67W Weld County Well Production Facility/Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment ID' AIRS Point° Equipment Description PRD_WTR 004 Two 400 barrel produced water tanks This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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 in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 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 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.) 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: AIRS Point CO Equipment ID Tons per Year PM2.5 NOX VOC Emission Type PRD_WTR 004 0.6 1.3 2.7 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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 owner or operator must use the emission factors found in Notes to Permit Holder to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 9 COLORADO Air Pollution Control Division Department of Puhlic. Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than 100 tons per year of VOC. 9. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled PRD_WTR 004 Emissions from the produced water tank are routed to an enclosed combustor when the Ecovapor and/or NGL skid is not operating VOC and HAP 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 rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, ILA.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit PRD_WTR 004 Process flow is directed to the operating Ecovapor/NGL skid 65,524 barrels Ecovapor/NGL skid is bypassed and process flow is directed to the enclosed separators 196,571 barrels 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. 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. Page 3 of 9 COLORADO Air Pollution Control Division Department of Public Heath & Envirori.nern Dedicated to protecting and improving the health and environment of the people of Colorado 11. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the produced water tank using the flow meter or the operator will use the default value of 36 scf waste gas/barrel until the flowmeter is installed. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 12. The owner or operator shall monitor and record Ecovapor gathering unit downtime on a daily basis. Ecovapor gathering unit downtime must include times when the GTUIT NGL skid is down and/or gas vented from the Ecovapor gathering unit bypasses the GTUIT NGL skid and/or the Ecovapor gathering unit and is routed to the enclosed combustor and/or when the Ecovapor unit is bypassed. The owner or operator shall use monthly records of GTUIT NGL skid downtime and Ecovapor gathering unit downtime to demonstrate compliance with the process and emission limits specified in this permit. 13. The owner or operator shall monitor and record GTUIT NGL skid downtime on a daily basis. GTUIT NGL skid downtime shall be defined as times when the gas vented from the separators and/or gas vented from the Ecovapor gathering unit bypasses the GTUIT NGL skid and is routed to the enclosed combustor. The owner or operator shalt use monthly records of GTUIT NGL skid downtime and Ecovapor gathering unit downtime to demonstrate compliance with the process and emission limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 14. 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) 15. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 16. 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 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. 17. 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 Page 4 of 9 COLORADO Air Pollution Control Division Department of Pubte Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 18. 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 19. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan submitted with this package and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis withthe requirements of this permit. Revisions to the OM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7. ) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. 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.B2. and XVII.A.16) Periodic Testing Requirements 21. The owner or operator shall demonstrate compliance with opacity standards by following the O >_t M plan submitted with the application. ADDITIONAL REQUIREMENTS 22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30`h 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 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 For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. if this permit specifically states that finalauthorization 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. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 26. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 27. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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 Page 6 of 9 COLORADO Air Pollution Control Division Department of Public Hcifhb Envirmment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Enerplus Resources (USA) Corporation Page 7 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder 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 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) 001 Benzene 71432 1835 69 n -Hexane 110543 5766 216 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Source NOx 0.0681b/MMBtu AP -42 CO 0.310 lb/MMBtu AP -42 VOC 0.262 CDPHE 71432 Benzene 0.007 CDPHE 110543 n -Hexane 0.022 CDPHE 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 Page 8 of 9 COLORADO Air Pollution Control Division Department of Public Health b Enviro amend Dedicated to protecting and improving the health and environment of the people of Colorado emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 9) 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 for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix. I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Produced Water Storage Tank(s) Emissions Inventory 004 Produced Water Tank Facility AIRS ID: O.2 91 Cobnty Plant Pain Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: • iQ,barrel prodpced water Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput= Requested Permit Limit Throughput = ha.; 25%ggesto ( 01:, Barrels (bbl) per year Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = Requested Monthly Throughput = 22260 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Th rough put = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device= Requested heat content of waste gas routed to combustion device = Barrels (661) per year 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? 22,636 MMBTU per year 22,636 MMBTU per year 22.636 MMBTU per year Pollutant Pollutant Produced Water Tank Uncontrolled Controlled (lb/bbl) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) 0,000 0.000 0.000 0.000 0.001 0.000 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/bbl) (waste heat combusted) cLoGao--4. .3100 (Produced Water Throughput) 0.0000 0.0059 0.0268 Emission Factor Source Emission Factor Source 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) uncontrolled NGL ecd 25% 75% controlled NGL ecd 95% VOC PM10 PM2.5 NOx CO 34.3 14.0 -18.7 343 1.7 8.58 0.00 0.00 0.19 0.88 458.67 0.00 0.00 0.00 1441.52 0.00 25.75 0.00 0.00 0.58 2.63 1376.00 0.00 0.00 0.00 4324.57 0.00 1.3 0.0 0.0 0.0 0.1 68.8 0.0 0.0 0.0 216.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.8 0,8 0.8 0.8 0.8 3.5 3.5 3.5 3.5 3.5 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (16s/year) Requested Permit Limits Uncontrolled Controlled (Ns/year) (Ids/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 1335 746 -997 1035 92 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 5766 2346 -3132 5766 288 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.i & C:3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVtl.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NIPS 0000 1 oft K:\PA\2018\18 W E1125.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory (See regulatory applicability worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells hrought on-line), then it may he appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9.and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain 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 Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point S 004 Process 9 01 Uncontrolled Emissions SCC Code Pollutant Factor Control % Units 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+Flashing losses PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.14 0 lb/1,000 gallons liquid throughput VOC 6.2 95 16/1,000 gallons liquid throughput CO 0.64 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 , lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallonsliquid throughput n -Hexane 0.52 95 lb/1,000 gallons liquid'throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput Definitions for Drop Down Lists Storage Tank Emissions Factor Options Produced Water State E.F. (includes flash) - Front Range & Other Produced Water State E.F. (includes flash) - West Slope Other (Documented in Technical Analysis Notes) Site Specific E.F. (includes flash) Site Specific EPA TANKS E.F. Working and Breathing Only Qualifiers No Yes Not applicable - stabilized tank Control Devices Enclosed Flare Open Flare Vapor Recovery Unit (VRU) Control Device Combustion Emissions Factor Options NOx CO PM AP -42 Chapter 13.5 Industri AP -42 Chapter 13.5 AP -42 Table 1.4-2 (PM10/PM.2.5) TNRCC Flare Emissions Guic TNRCC Flare Emissii Other - Explain AP -42 Table 1.4-1 (NOx) AP -42 Table 1.4-1(CO) Other - Explain Other -Explain 2 of 2 K:\PA\2018\18WE1125.CPl.xlsm COLORADO Air Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1126 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Enerplus Resources (USA) Corporation Irish Well Pad 123 9FD9 SWSE, Section 26, T8N, R67W Weld County Well Production Facility/Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description TANKS 005 Six 400 barrel crude oil tanks This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R. S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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 in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 11 COLORADO Air Pollution Control Division D pa; tment of Public Health £i Environiner t Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit 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 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: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX YOC CO TANKS 005 -- -- 9.5 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. Page 2 of 11 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 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than 100 tons per year of VOC. 9. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled 005 Emissions from the crude oil tank are routed to an enclosed combustor when the Ecovapor and/or NGL skid is not operating VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. 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 Equipment ID AIRS Point Process Parameter Annual Limit TANKS 005 Crude oil barrels with emissions directed to the NGL stand via the Ecovapor unit 68,479 Crude oil barrels with emissions directed to the enclosed combustors 102,718 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. 10. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the crude oil tank using the flow meter or the operator will use the default value of 23 scf waste gas/barrel until the flowmeter is installed. The owner or Page 3 of 11 COLORADO Air Pollution Control Division Department of Pi bl€c Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 11. The owner or operator shall monitor and record Ecovapor gathering unit downtime on a daily basis. Ecovapor gathering unit downtime must include times when the GTUIT NGL skid is down and/or gas vented from the Ecovapor gathering unit bypasses the GTUIT NGL skid and/or the Ecovapor gathering unit and is routed to the enclosed combustor and/or when the Ecovapor unit is bypassed. The owner or operator shall use monthly records of GTUIT NGL skid downtime and Ecovapor gathering unit downtime to demonstrate compliance with the process and emission limits specified in this permit. 12. The owner or operator shall monitor and record GTUIT NGL skid downtime on a daily basis. GTUIT NGL skid downtime shall be defined as times when the gas vented from the separators and/or gas vented from the Ecovapor gathering unit bypasses the GTUIT NGL skid and is routed to the enclosed combustor. The owner or operator shall use monthly records of GTUIT NGL skid downtime and Ecovapor gathering unit downtime to demonstrate compliance with the process and emission limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. 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 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. 16. 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%. Page 4 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 17. 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 £t MAINTENANCE REQUIREMENTS 18. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0&M) plan submitted with this package 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 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section 111.6.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. The owner or operator must complete an initial site specific analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis must be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 20. 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 XVII.B.2. and XVII.A.16) Periodic Testing Requirements Page 5 of 11 COLORADO Air Pollution Control Division Department of Public Health E Ervtrohment: Dedicated to protecting and improving the health and environment of the people of Colorado 21. The owner or operator shall demonstrate compliance with opacity standards by following the O it M plan submitted with the application. 22. On an annual basis, the owner or operator must complete a site specific analysis ("Analysis"), including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis is greater than or equal to the emissions factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. ADDITIONAL REQUIREMENTS 23. 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 (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 Page 6 of 11 COLORADO Air Pollution Control Division Department of Public Health & Ernrornnent Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 24. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section IIIG. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 26. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the, equipment and operations or activity specifically identified on the permit. 27. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 28. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 29. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and Page 7 of 11 COLORADO Air Pollution Control Division Department of Pubic health f•°Ervirohment Dedicated to protecting and improving the health and environment of the people of Colorado administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance ' Date Description Issuance 1 This Issuance Issued to Enerplus Resources (USA) Corporation Page 8 of 11 COLORADO Air Pollution Control Division Department of Public Health bEnvironment 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 set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (ib/yr) Controlled Emissions (lb/yr) 005 Benzene 71432 1024 31 Toluene 108883 732 22 Ethylbenzene 100414 56 2 Xylenes 1330207 116 4 n -Hexane 110543 6356 191 224 TMP 540841 0 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 11 5) COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Source NOx 0.068 lb/MMBtu AP -42 CO 0.310 lb/MMBtu AP -42 VOC 3.67 ERP Tanks 71432 Benzene 0.0060 EEtP Tanks 108883 Toluene 0.0043 EEtP Tanks 100414 Ethylbenzene 0.0003 EEtP Tanks 1330207 Xylene 0.0007 EEtP Tanks 110543 n -Hexane 0.0371 EEtP Tanks 540841 224 TMP 0.0000 EEtP Tanks Note: The controlled emissions factors for this point are based on a control efficiency of 95. 6) In accordance with. C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no tater than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tankand associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, HAP NANSR Synthetic Minor Source of: VOC, NOx PSD Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart.A - Subpart KKKK Page 10 of 11 COLORADO Air Pollution Control Division Department of Public Heath Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Crude Oil Storage. Tank(s) Emissions Inventory 005 Crude Oil Tank Facility AIRs ID: County Plant Pain Section 02- Equipment Description Details .5₹ , AaS`Igr`c!). Description: r..z;;;fy f; Emission Control Device Description: .4td£f'th" Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions- Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput = Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating= 1 Barrels (bbl) per year Requested Monthly Throughput = 14040 Barrels (bbl) per month Potential to Emit (PTE) Throughput = Secondary Emissions- Combustion Devices) Heat content of waste gas= Volume of waste gas emitted per BBL of liquid produced = :.::::41y 1661 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barre s (bbl) per year Btu/scf 16,066 MMBTU per year 16,866 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 16,866 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Crude Oil Throughput) i a 3 670tf'F f::: 61. W''. Pollutant 0A043;• 0.0007 0,0000 (Crude Oil Throughput) Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat combusted) (Ib/bbl) g 03Yt10s;>;7% (Crude Oil Throughput) Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory 0.256 0.183 0.014 0.029 1.589 512 0.005982 366 0.004276 28 0.000327 58 0.000678 3178 0.03713 Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (Ions/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) uncontrolled NGL ecd 40% 60% controlled NGL ecd 95% VOC PM10 PM2.5 NOx CO 314,1 166,9 -131.6 014,1 10,7 125.66 0.00 0.00 0.23 1.05 409.6 292.8 22.4 46.4 2542.6 0.0 188.49 0.00 0.00 0.34 1.57 614.4 439.2 33.6 69.6 3813.9 0.0 9.42 0.00 0.00 0.02 0.08 30.7 22.0 1.7 3.5 190.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0k₹ 0.0 0.5 0.0 0,8 0,6 0,6 2,5 2.6 2.6 2.6 2.6 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/Year) Actual Emissions Uncontrolled Controlled (Ibs/year) fibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1024 5.24 .429 1924 51 732 180 -307 732 3'7 50 30 -20 56 3 116 62 -49 116 6 0306 3376 -2662 6356 318 0 0 0 0 0 Section 06- Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII,B, C.1, C.3 Storage tank is subject to Regulation 7, Section XV€€, 8, C,1 & C3 Regulation 7, Section XVII.C.2 Stora₹„e took is sub)et8 to Regulation 7, Section XV€€.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not stdtject to HOPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not stilled to MPS 0000 Regulation B, Part E, MAC Subpart HH Storage Tank €s not st$x)ect to MACT HH (See regulatory applicability worksheet for detailed analysis) 1 of 2 K:\PA\2018\18W E1126.CP1.xlsm Crude Oil Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the't-'?' facility being permitted? If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point It Process 005 01 5CC Code Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 1611,000 gallons crude oil throughput PM2.5 0.00 0 lb/1,000 gallons crude oil throughput NOx 0.16 0 lb/1,000 gallons crude oil throughput VOC 87.4 95 lb/1,000 gallons crude oil throughput CO 0.73 0 lb/1,000 gallons crude oil throughput Benzene 0.14 95 lb/1,000 gallons crude oil throughput Toluene 0.10 95 lb/1,000 gallons crude oil throughput Ethylbenzene 0.01 95 lb/1,000 gallons crude oil throughput Xylene 0.02 95 lb/1,000 gallons crude oil throughput n -Hexane 0.88 95 lb/1,000 gallons crude oil throughput 224 TMP 0.00 95 lb/1,000 gallons crude oil throughput 2 of 2 K:\PA\2018\ 18WE1126.CP1.xlsm COLORADO Air Pollution Control Division Department of Public Health & Enviror r. tertt Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE1127 Issuance: 1 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Irish Well Pad Plant AIRS ID: 123 9FD9 Physical Location: SWSE, Section 26, T8N, R67W County: Weld County Description: Well Production Facility/Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Control Device LOAD1 006 Truck loadout of crude oil Enclosed Combustor This permit is granted subject to all rules and regwlations 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 in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 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 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: Equipment ID AIRS Point Tons per Year PM2.5 NOX VOC CO Emission Type LOAD1 006 3.0 Point Note: See "Notes to Permit Holder" for information art 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 must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below 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.) Page 2 of 9 COLORADO Air Pollution Control Division Department of Public Health Environment Dedicated to protecting and improving the health and environment of the people of Colorado Equipment ID AIRS Point Control Device Pollutants Controlled LOAD1 006 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 Equipment ID AIRS Point Process Parameter Annual Limit LOAD1 . 006 Crude Oil 171,197 barrels 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, III.D.2.a. Loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Regulation 3, Part B, III.D.2) 12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 13. The owner or operator 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): Page 3 of 9 c. 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 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. 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 (Regulation 3, Part B, III.D.2). Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. Include devices to prevent the release of vapor from vapor recovery hoses not in use. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (08M) plan submitted with this package and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your 0&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Health & Enviroranerit Dedicated to protecting and improving the health and environment of the people of Colorado 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 NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 5O tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS Page 5 of 9 COLORADO Air Pollution Control Division Department of Pizbttc Heath b Erveonr ent Dedicated to protecting and improving the health and environment of the people of Colorado 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 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. 20. 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. 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 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 enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Enerplus Resources (USA) Corporation 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 set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps Page 7 of 9 COLORADO Air Pollution Control Division Department of Fubac Health Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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) 006 Benzene 71432 29 10 Toluene 108883 21 7 Ethylbenzene 100414 2 1 Xylenes 1330207 3 1 n -Hexane 110543 176 59 224 TMP 540841 0 0 Note: All non -criteria reportable pollutants in the table above with uncontrolledemission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Source NOx AP -42 CO AP -42 VOC 0.10270 AP -42 Benzene 71432 0.00017 Mass balance Toluene 108883 0.00012 Mass balance Ethylbenzene 100414 0.00001 Mass balance Xylene 1330207 0.00002 Mass balance n -Hexane 110543 0.00103 Mass balance 224 TMP 540841 0.00000 Mass balance 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) Page 8 of 9 COLORADO Air Pollution Control Division Department of Public Health t• Ervircment Dedicated to protecting and improving the health and environment of the people of Colorado P (true vapor pressure) = 3.4 psia M (vapor molecular weight) = 50 lb/lb-mol T (temperature of liquid loaded) = 520 °R 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: VOC, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website: http: / /ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Hydrocarbon Loadout Emissions Inventory 006 Liquid Loading 'Facility AIRs ID: County 9FD9 Plant 006 Paint Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: 66.50 Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput = Potential to Emit (PTE) Volume Loaded= sl,<IUM Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating= Requested Monthly Throughput = 7i Barrels (hbl) per year 14540 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas=' Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 400 Btu/scf 133271 scf/year 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/1' 320 MMBTU per year 320 MMBTU per year 320 MMBTU per year A site specific stabilized hydrocarbon liquid sample most be provided to develop a site speci€ic emissions factor. Factor Meaning Value Units Source S Saturation Factor 0,6 �//�� �;✓, :^'%' ,R ,;'.++„,,�.'_ , P True Vapor Pressure iq y{x} „,:, P s i a M Molecular Weight of Vapors ,a u$ - lb/lb-mol T Liquid Temperature .; 5, 4 Rankine L Loading Losses 24441 Ib/100D gallons iLli12'7 Ib/bbl Component Mass Fraction Emission Factor Units Source Benzene :M0'0o16d 0,00017 lb/bbl Toluene ,4 0.00118 0,000)2 lb/bbl Ethylhenzene z,, ,. ,. 4}00004, , 0.00001 lb/bbl Xylene t, iP.000^`si`' 'I 0,00002 lb/bbl n -Hexane ,,,1„,$07000 x ';r"^;;' 0,00103 lb/bbl 224TMP „x''.,,,, ,........ ••":i 0.0000016/bbl Pollutant MININZEIMEMIN IIIMMEEMEIMMI 1171 Hydrocarbon Loadout Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Volume Loaded) (Volume Loaded) 0.0052 0.0000 0.0005 Pollutant 0,0000 0.0001 0.00E51 0.0000 0.0050 0.0000 Control Device Uncontrolled (Ib/MMBtu) Uncontrolled (Ib/bbl) (Volume Loaded) (waste heat combusted) Emission Factor Source Emission Factor Source loft K:\PA\201B\18 W E1127.CP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) Ohs/month) PM10 0,00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0,00 0 500 11.00 0.00 0.00 0.00 0.00 0 NOx 0,01 0.01 0.01 0.01 0.01 2 VOC 0.78 8.78 2.94 8.79 2.94 500 CO 0.05 - 0.05 0.05 0.05 0.05 8 Potential to Emit Actual Emissions Requested Permit Limits - HazardousAirPollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ihs/year) (Ihs/year) (11m/year) (Ihs/year) Benzene 39 28 10 29 /0 Toluene 21 21 7 21 7 Ethylbenzene 2 2 1 2 1 Xylene :3 3 n -Hexane 176 176 59 176 59 224TMP £1 0 0 D 0 Section 06 - Regulatory Summary_Anaiysis Regulation 3, Parts A, B Source requires a permit RACT- Regulation 3, Part B, Section 111.0.2.a (See regulatory applicability worksheetfor detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements 'fhe loadout must be operated with submerged fill to satisfy RACT. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 006 Process# 5CC Code 01 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 5Ox 0.00 0 lb/1,000 gallons transferred NOx - 0.00 0 lb/1,000 gallons transferred VOC 2.4 67 lb/1,000 gallons transferred CO 0,01. 0 lb/1,000 gallons transferred Benzene 0.00 67 lb/1,000 gallons transferred Toluene 0.00 67 110/1,000 gallons transferred Ethylbenzene 0.00 67 lb/1,000 gallons transferred Xylene 0.00 67 lb/1,000 gallons transferred n -Hexane 0.02 57 lb/1,000 gallons transferred 224 TMP 0.00 07 lb/1,000 gallons transferred 2 of 2 K:\PA\2018\18WE1127.CP1.xlsm PERMIT NO: DATE ISSUED: ISSUED TO: 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 CONSTRUCTION PERMIT 18WE1128 Enerplus Resources (USA) Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Irish Well Pad, located in the SWSE, Section 26, T8N, R67W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Equipment ID AIRS Point Description Plant FUG 007 Fugitive emissions from a gas plant. The plant is located inside a well -pad. The gas plant components are the GTUIT NGL skid, the associated generator, the NGL tank and alt other associated equipment., 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. 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. (Reference: Regulation No. 3, Part B, 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 Page 1 of 9 COLORADO Air Pollution Control Division Department of Public Health b E rvironment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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.) 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 (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)' Annual Limits: Equipment ID AIRS Point Tons per Year VOC Emission Type Plant FUG 007 1.4 Fugitive 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. Facility -wide emissions of total hazardous air pollutants 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-minimus reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. Total emissions from the facility, including permitted emissions and insignificant activities, shall be less than: Page 2 of 9 COLORADO Air Pollution Control Division epartment of Public l-featth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 100 tons per year of any criteria pollutant 9. The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas and liquids analyses, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. 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. 8 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. This source is subject to the requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities. 13. This source is subject to Regulation No. 7, Section XII.C General Provisions (State only 'enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 14. The fugitive emissions addressed by AIRS ID 007 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart 0000a, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. 15. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Regulation No. 3, Part B, III.D.2.a). Directed Inspection & Maintenance (DI£tM) shall satisfy the requirement to apply Reasonably Available Control Technology (RACT). 16. The owner or operator shall follow the Directed Inspection and Maintenance (DIEM) program and record keeping format as approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your DI&M plan are subject to Division approval. 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 OPERATING a MAINTENANCE REQUIREMENTS 17. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas analyses and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 19. Within one hundred and eighty days (180) of the tatter of commencement of operation or issuance of this permit,;! the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification', process to ensure compliance with emissions limits. Periodic Testing Requirements 20. On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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 Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Heitt`t & Ervi onr:'ient Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. 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 henever a permit limitation must be modified; or No later. than 30 days before the existing APEN expire 22. Federal regulatory program requirements (i.e. PSD, 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). 23. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production. Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 24. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 25. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 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 Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Health t, tnN•oriment Dedicated to protecting and improving the health and environment of the people of Colorado documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 26. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 27. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 28. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeat of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab intio. This permitmay 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 sourcemay request a hearing before the AQCC for review of, the Division's action. 29. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution oEmission 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 inwriting requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear Permit Engineer Permit History Issuance Date Description Page 6 of 9 COLORADO Air Pollution Control Division Department of Public Health f; Ei Mror ent Dedicated to protecting and improving the health and environment of the people of Colorado Issuance 1 This Issuance Issued to Enerplus Resources (USA) Corporation Page 7 of .9 iCOLORADO Air Pollution Control Division o nt of Public Health a 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 (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The 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 set, forth in Part ; II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacificicdphe/agcc-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 # BIN Uncontrolled Emissions (lb/yr) Reportable Controlled Emissions (lb/yr) 007 Benzene 71432 A 9 no 9 Toluene 108883 C 6 no 6 Ethylbenzene 100414 C 1 no 1 Xylenes 1330207 C 2 no 2 n -Hexane 110543 C 39 no 39 5) The emission levels contained in this permit are based on EPA -453/R95-017 table 2-4. Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. 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 Page 8 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 emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx NSPS 0000a Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at http://ecfr.gpaaccess.gov/. Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX 9) 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. Page 9 of 9 Colorado Department of Public Health Environment Air Pollution Control Division Summary of Preliminary Analysis - Fugitive Components Source Company Name Enerplus Resources (USA) Corporation Facility Name Irish Well Pad Permit No 18WE1128 AIRS 123/9FD9/007 Permit Engineer Kirk Bear Application Date 10/26/2018 Review Date 5/17/2019 227.944467 Summary of Emissions VOC (tpy) Benzene (Ib/yr) Toluene (Ib/yr) Ethylbenzne (Ib/yr) Xylenes (Ib/yr) n -Hexane (Ib/yr) Uncontrolled Requested Emissions 1.3 9 6 1 2 39 Controlled Requested Emissions 1.3 9 6 1 2 39 Reportable? I No No No No No Total HAP, Uncontrolled (tpy) 0.0 Total HAP, Controlled (tpy) 0.0 Highest HAP, Uncontrolled (tpy) 0.0 n -Hexane Emission Factors Emission Factor Source: Controls Stream VOC Fraction: Gas 0.4158 Light Oil 1.0000 Heavy Oil 1.0000 Water/Oil 1.0000 EPA -453/R-95-017, Table 2-4 Control Efficiencies from Table 5-3, quarterly monitoring (EPA -453/R-95-017) Stream HAP Components (wt frac HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.0016 0.0000 0.0000 0.0000 Toluene 0.0010 0.0000 0.0000 0.0000 Ethylbenze 0.0001 0.0002 0.0000 0.0000 Xylene 0.0003 0.0000 0.0000 0.0000 n -Hexane 0.0071 0.0000 0.0000 0.0000 Comments/Notes: Please enter description of the project and any technical notes about corrections made to the application. Printed 11/15/2019 Page 1 or 2 COLORADO Air Pollution Control Division Department of Pub*:. Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1129 Issuance: 1 Date issued: Issued to: Enerplus Resources (USA) Corporation Facility Name: Irish Well Pad Plant AIRS ID: 123 9FD9 Physical Location: SWSE, Section 26, T8N, R67W County: Weld County Description: Well Production Facility/Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control! Description NGL 008 GTUIT NGL skid with maximum raw gas rate of 1.00 MM scf/day Enclosed combustor Separator 009 Two 2 -phase and two 3' -phase separators Enclosed combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. Point 008, 009: 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. Point 008, 009: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days Page 1 of 12 COLORADO Air Pollution Control Division Department of Pub€=:c Health £ Environment Dedicated to protecting and improving the health and environment of the people of Colorado may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at www.colorado.Qov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. Point 008, 009: This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Point 008, 009: The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. Point 008, 009: The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION! LIMITATIONS AND RECORDS 6. Point 008, 009: Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX vOC CO NGL 008 -- 1.9 10.9 8.6 Point Separator 009 -- 3.8 54.3 17.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 12 COLORADO Air Pollution Control Division Department of Pubes: {,o 1 h b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. Point 008, 009: The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. Point 008, 009: The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled NGL 008 Emissions from the NGL are routed to an enclosed combustor VOC and HAP Separator 009 Emissions from the separators are routed to an enclosed combustor when the NGL skid is not operating VOC and HAP PROCESS'. LIMITATIONS AND RECORDS 9. Point 008, 009: This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit NGL 008 Residual Gas Venting to enclosed combustors 51.1 MM scf/year Separator 009 Process flow is directed to the operating NGL skid 64.1 MM scf/year NGL skid is bypassed and process flow is directed to the enclosed separators 75.4 MM scf/year Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. Page 3 of 12 COLORADO Air Pollution Control Division Department of Public Health & Erxiro anent Dedicated, to protecting and improving the health and environment of the people of Colorado 10. Point 008: The owner or operator must continuously monitor and record the volumetric flow rate of residual gas vented from the NGL using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 11. Point 008, 009: The owner or operator shall monitor and record GTUIT NGL skid downtime on a daily basis. GTUIT NGL skid downtime shall be defined as times when any gas vented from the separators and/or any gas vented from the Ecovapor gathering unit bypasses the GTUIT NGL skid and is routed to the enclosed combustor. The owner or operator shall use monthly records of GTUIT NGL skid downtime and Ecovapor gathering unit downtime to demonstrate compliance with the process and emission limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. Point 008, 009: The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. Point 008, 009: This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. Point 008, 009:: The combustion device covered by this permit is subject to Regulation Number 7, Section XVILB.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of'volatile organic compounds to comply with Section XVII, it''must be enclose have • no visible emissions during normal operations, as defined under Regulation Number 7, XVILA.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion. device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 15. Point 008, 009: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. Page 4 of 12 COLORADO Air Pollution Control Division Department of Pubic Health & Enviror1 merit Dedicated to protecting and improving the health and environment of the people of Colorado OPERATING :t MAINTENANCE REQUIREMENTS 16. Point 008, 009: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O8: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 08M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. Point 008, 009: The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n - hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 18. Point 008, 009: The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 19. Point 008: On a semi-annual basis, the owner/operator must complete a site specific extended gas analysis ("Analysis") of the residual gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the Page 5 of 12 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this inaccuracy. 20. Point 009: On a semi-annual basis, the owner/operator must complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this inaccuracy. 21. Point 008, 009: The owner or operator shall demonstrate compliance with opacity standards by following the O Ft M plan submitted with the application. ADDITIONAL REQUIREMENTS 22. Point 008, 009: A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or 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 Page 6 of 12 COLORADO Air Pollution Control Division Department of Pubac Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 23. Point 008, 009: Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 24. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured ' from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S.and AQCC, Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and hasbeen verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 26. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 27. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 28. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be Page 7 of 12 COLORADO Air Pollution Control Division Department of Pubs=.c Health E.: Environment Dedicated to protecting and improving the health and environment of the people of Colorado revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 29. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. Bv: Kirk Bear Permit Engineer Permit History issuance Date Description Issuance 1 This Issuance Issued to Enerplus Resources (USA) Corporation Page 8 of 12 COLORADO Air Pollution Control Division Department of Puble Health f: Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based, upon the process limits as indicated in this` permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Point 008: Equipment' ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) NGL 008 Benzene 71432 0.0 0.0 Toluene 108883 0.0 0.0 Ethylbenzene 100414 0.0 0.0 Xylenes 1330207 0.0 0.0 n -Hexane 110543 0.0 0.0 224 TMP 540841 0.0 0.0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Point 009: Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Page 9 of 12 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Benzene 71432 7316 366 Toluene 108883 3658 183 Ethylbenzene 100414 523 26 Separator 009 Xylenes 1330207 1045 52 n -Hexane 110543 32607 1630 224 TMP 540841 1045 52 5) The emission levels contained in this permit are based on the following emission factors: Point 008: CAS # Pollutant Uncontrolled Emission Factors lb/MM scf Source NOx 0.068 lb/MM Btu AP -42 CO 0.310 lb/MM'Btu AP -42 VOC 8602.7 lb/MM scf Mass balance 71432 Benzene 0.0 lb/MM scf Mass balance 108883 Toluene 0.0 lb/MM scf Mass balance 100414 Ethylbenzene 0.0 lb/MM scf Mass balance 1330207 Xylene 0.0 lb/MM scf Mass balance 110543 n -Hexane 0.0 lb/MM scf Mass balance 540841 224 TMP 0.0 lb/MM scf Mass balance Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 009: CAS # Pollutant Uncontrolled Emission Factors lb/MM scf Source NOx 0.068 lb/MM Btu AP -42 CO 0.310 lb/MM Btu AP -42 Page 10 of 12 COLORADO Air Pollution Control Division Department of Pubzc heottf & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/MM scf Source VOC 28798.35 Mass balance 71432 Benzene 97.02 Mass balance 108883 Toluene 48.51 Mass balance 100414 Ethylbenzene 6.93 Mass balance 1330207 Xylene 13.86 Mass balance 110543 n -Hexane 432.45 Mass balance 540841 224 IMP 13.86, °',; Mass balance 6) In accordance with -,C.R.S. 25-7-114.1, ; each Air Pollutant Emission Notice (APEN) associated with this permit is valid fora term of fiveyears from the date it was received by the Division. A revised APEN mustbe submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at. (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 11 of 12 r COLORADO Air Pollution Control Division Department of Public Health ft Errirortrtent Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 12 of 12 Separator Venting Emissions Inventory 008 Separator Venting Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details GTtlIT 140k.akid Detailed Emissions Unit Description: d egmhustur Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Y .rnetari-s currehtlslontalled ctrl operational i. Section 03 - Processing Rate Information for Emissions Estimates MMscf per year MMscf per year Requested Permit Limit Throughput Requested Monthly Throughput = 4.34 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 51..10 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04- Emissions Factors& Methodologies scf/bbl d. gas from the produced watertanits and the crude oil tanks is also sent to the NGL skid via the ec vapor unit, the NGL residual gas is directed to enclosed combustors nalysis of the treatedgas, quarterly sampling will be recomended. an extended gas analysis will be done (of this residual gas downstream of the NGL skid) and input into 'hr emission rates from the NGL the estimated analysis was in mole %sot converted' to weight % for the table belowthe operator is stating that zero HAP will be emitted. >: IMW 20.06 Ib/Ib-mol Weight % Helium %= CO2 '..4,3100 methane 58:1000' ethane 20.060'0 propane ........ ',1'.n900'. isobutane :: G 7200 n -butane :..1800' isopentane 00 nit- entane 0 i00i' cyclopentane e -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene -:- Toluene Ethylbenzene Xylenes CO* Heavies Total VOCWt% :00.33 18.53 Emission Factors Separator Venting Pollutant Uncontrolled (lb/MMscf) (Gas Throughput) 002.0880 VOC Benzene 0.0000 Toluene 0.0000 0.0000 0.0000 Ethylbenzene. Xylene n -Hexane 0.0000 224 TMP 0.0000 Pollutant Controlled (lb/MMscf) (Gas Throughput) 430.134 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Primary Control Device Uncontrolled lb/MMscf Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) PM10 PM2.S SOx NOx (Gas Throughput) 0.000 0.000 0.000 7:5.002 Displacement Equation Ex=Q"MW 'Xx/C 1 of 4 K:\PA\2018\18 W E1129.CP1.xlsm Separator Venting Emissions Inventory 2 of 4 K:\PA\2018\18WE1129.CP1.xlsm Separator Venting 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/month) PM10 PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0,00 0.00 0.00 0.00 0.00 0 0,00 0.00 0.00 0.00 0.00 0 1.83 1.89 1.89 1.89 1.89 321 219.80 219,80 10.99 219.80 1099 1867 8,63 8.93 8.63 8,63 8,63 1460 ' 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 n -Hexane 224 TRIP0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 II 0 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII. B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source is subject to Regulation 7, Section XVII.8.2, G The control device for this separator is subject to Regulation 1, Section XVII.8.2,a Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gal sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 3 of 4 K:\PA\2018\18WE1129.CP1.xlsm Separator Venting Emissions Inventory Section 09- Inventory SCC Coding and Emissions Factors AIRS Point # 008 Process # SCC Code 01 3-10-001-80 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 Ib/MMSCF PM2.5 0.00 0 lb/MMSCF SOx 0.00 0 €b/MMSCF NO0 74.05 0 ib/MMSCF VOC 0602.09 95 lb/MMSCF CO 337.59 0 lb/MMSCF Benzene 0.00 51 lb/MMSCF Toluene 0.00 95 lb/MMSCF Ethylbenzene 0.€30 95 lb/MMSCF Xylene 0.00 95 lb/MMSCF n -Hexane 0.00 95 lb/MMSCF 224 TMP 0.00 95 €b/MMSCF 4 of 4 K:\PA\2018\ 18WE1129.CP1.xlsm JAN 1 6 2019 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN 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. AIRS ID Permit Number: I 0WEt 1266. Number: 123 / 9F D9 / 00- Y V[Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 1 - Administrative Information Company Name': Enerplus Resources (USA) Corporation Site Name: Irish Well Pad Site Location: SWSE Sec. 26, T8N, R67W Mailing Address: (Include Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Kristin Van Hees Phone Number: 720-279-5515 E -Mail Address2: KVanHees@enerplus.com i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 39222a COLORADO 1 I •. a".u_ HWIT6yfW.[nnun, Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR - MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 Change permit limit ❑ Transfer of ownership4 D Other (describe below) -OR- APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - APEN submittal for permit exempt/grandfathered source Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 75% of requested bbl/yr go toward emissions 25% of vapors go to NGL skid for processing 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: 2, 400 bbl produced water tanks PRD_WTR 8/4/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 ❑✓ Exploration & Production (E&P) site days/week 52 weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes • No Are Flash Emissions anticipated from these storage tanks? 4 Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? Fl Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 2 I Ji'�-/•!\ � x.nma[+.a.alim.m r Upward O Horizontal Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 106619 Requested Annual Permit Limits (bbl/year) 262095 From what year is the actual annual amount? Tank design: 0 Fixed roof 2018 O Internal floating roof O External floating roof Storage Tank ID # of Liquid Manifold Storage ° iqui in Storage Tank Yessels Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PRD WTR 2 800 7/2018 8/2018 Wells Serviced by this Storage Tank or Tank Battery(' (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 44918 Pot O' Gold 8-67-35-2C 51 05 -123 -44921 Sligo 8-67-26-23C 0 - - ■ - Ili - ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The Eft? 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) 40.626117/-104.858296 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) f Flow Rate (ACFM) Velocity (ft/sec) Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet: (check one) ❑ Downward ❑Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 48 Square/rectangle Interior stack width (inches): Interior stack depth (inches): 0 Other (describe): Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 •COLORADO 3 I A. xw nrtcc«.i�o...,.rnaa„w� a Permit Number: AIRS ID Number. 123 I 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑✓ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: Type: Enclosed combustors MMBtu/hr Make/Model: Three Cimmaron 48" Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98+ Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 2399 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed, loop system: ❑✓ Other: Pollutants Controlled: VOC and HAPs (emissions associated with Flare) Description: 25% of vapors sent to NGL skid for processing through Ecovapor Unit Control Efficiency Requested: NA Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -38 psig Describe the separation process between the well and the storage tanks: Gas and liquids from each well are sent to a 2 -phase separator, gas goes to Flare or NGL Skid for processing, liquids go to 3 -phase heated separator, oil goes to oil tanks and water goes to water tanks. Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 4 I N � WIn 6 LnNmvrvcnt Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit U and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency . (% reduction in emissions) VOC Combustors 95% NOx • CO HAPs Combustors 95% Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.262 lb/bbl State 14.00 0.70 3't,3 25.75• 1.29 NOx CO Non -Criteria Reportable Pollutant Emissions Inventory , v Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 0.007 lb/bbl State 746.7 37 Toluene 108883 0.022 lb/bbl State 2346.7 117 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 MI COLORADO 5I • �� tlTkrwIw,n.,N I Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] , Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. _v1/4/1 'iJ vv,i) Signature of Legally Adthorized Person (not a vendor or consultant) Date Kristin Van Hees Environmental Coordinator Name (print) Title Check the appropriate box to request a copy of the: ✓❑ Draft permit prior to issuance ✓� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 6 I ®' o.,.,,ri„� r7,2: »+nmr, e�manR�... JAN Crude Oil Storage Tank(s) APEN Form. APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 crude oil associated with oil and gas industry operations. if your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID 123 / 9FD9 / lgyje12 -Q Number: GiJ 5 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Enerplus Resources (USA) Corporation Site Name: Irish Well Pad Site Location: SWSE Sec. 26, T8N, R67W Mailing Address: (Include Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 Site Location County: Weld 1 6 2019 NAICS or SIC Code: 1311 Contact Person: Kristin Van Flees Phone Number: 720-279-5515 E Mail Address2: KVanHees@enerplus.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. Z Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-210 Crude Oil Storage Tank(s) APEN Revision 7/2018 392221 COLORADO 1 I mp,.c�dwsu< N.AN6[nNronrt.nl Permit Number: AIRS ID Number: 123 / 9FD9 / [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 General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $312.5O must be submitted along with the APEN filing fee. -OR- MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment 0 Change company name3 51. Change permit limit 0 Transfer of ownership' -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) 0 Other (describe below) - 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) 12oS, tt/l1/O1 Additional Info & Notes: 75% of requested bbl/yr go toward emissions 25% of vapors go to NGL skid for processing 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): Six, 400 bbl Crude Oil Tanks TANKS For existing sources, operation began on: 8/4/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 ❑✓ Exploration & Production (E&P) site weeks/year 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? Yes No p ■ Are Flash Emissions anticipated from these storage tanks? Yes No p ■ Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ■ BI Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No D ■ Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 AV COLORADO 2 I m. el Public WAIF el Public E/ Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) I Crude Oil Throughput: 90931 171197 From what year is the actual annual amount? Average API gravity of sales oil: -.37 Tank design: ID Fixed roof 2018 degrees ❑ Internal floating roof RVP of sates oil: -.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) TANKS 6 2400 7/2018 8/2018 Wells Serviced by this Storage Tank or Tank Battery' (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 44918 Pot 0' Gold 8-67-35-2C SI 05 - 123 -44921 Sligo 8-67-26-23C 17 - - ■ - ■ - - ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.626117/-104.858296 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) . Velocity (ft/sec) Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet: (check one) Upward O Horizontal Downward Other (describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): o Square/rectangle Interior stack width (inches): Other (describe): ❑ Upward with obstructing raincap 48 Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLORADO 3I �n .� N.e6 [n.nnmo.m Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: 0 Combustion Device: Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Make/Model: Three Cimarron 48" Type: Endosed combustors Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98+ % Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 2399 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑✓ Other: Pollutants Controlled: VOC and HAPs (emissions associated with Flare) Description: V9,4, of vapors sent to NGL skid for processing through Ecovapor Unit Control Efficiency Requested: NA Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —38 psig Describe the separation process between the well and the storage tanks: Gas and liquids from each well are sent to a 2 -phase separator, gas goes to Flare or NGL Skid for processing, liquids go to 3 -phase heated separator, oil goes to oil tanks and water goes to water tanks. Form APCD-210 Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLORADO 4 I M N.+t�kb Crth�nn.n�n� Permit Number: AIRS ID Number: 123 / 9FD9/ [Leave blamk 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 form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant • Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Combustors 95% NOx CO HAPs Combustors 95% Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 3.67 ' llb/bbl E&P Tanks 166.80 8.34 31N,(235.87 / 11.79 1g-11.79 NOx 0.068 Ib/MMBtu AP -42 0.31 0.31 O,(p 674* 0,1 0.44 CO 0.31 Ib/MMBtu AP -42 1.39 1.39 2...(p 2.00 0.1 2.00 Non -Criteria Reportable Pollutant Emissions Invento Chemical Name • Chemical Abstract Service (CAS) Number Emission Factor7 Act 1 Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 6.01E-3 lb/bbl E&P Tanks 545.9 27 Toluene 108883 4.32E-3 lb/bbl E&P Tanks 392.4 20 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 3.71E-2 lb/bbl E&P Tanks 3369.6 168.5 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. ' Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-21O - Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLORADO . =TV= 5 1 Ma Permit Number: AIRS ID Number: 123 / 9FD9/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 4/, kiv\ Signature of Legally Authorized Person (not a vendor or consultant) Date Kristin Van Flees Environmental Coordinator Name (print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-210 Crude Oil Storage Tank(s) APEN - Revision 7/2018 AV COLORADO 6 I m. : mru;a OCT 262019 Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/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: 13 WE 1121 AIRS ID Number: 123 / 9FD9 / a NI [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Enerplus Resources (USA) Corporation Site Name: Irish Well Pad Site Location: SWSE Sec. 26, T8N, R67W Mailing Address: (Include Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Kristin Van Flees Phone Number: 720-279-5515 E -Mail Address2: KVanHees@enerplus.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 389474 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 Allay I r,- COLORADO Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action NEW permit OR newly -reported emission source cgi Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change permit limit ❑ Change company name3 ❑ Transfer of ownership's 0 Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Truck loadout of crude oil Company equipment Identification No. (optional): LOAD1 For existing sources, operation began on: 8/4/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No 12 • Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No • FA Is this source located at an oil and gas exploration and production site? Yes No Igl ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • I2 Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No • ■ Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2I AY COLORADO �ia*gym_ xuatu.en,wronmaM Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 0 Condensate ❑✓ Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 171197 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: Tank trucks (e.g. "rail tank cars" or "tank trucks") bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 70 °F True Vapor Pressure: 3.4 @ 7OF Psia @ 60 °F Molecular weight of displaced vapors: 50 lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I A_ COLORADO H partmemntl NJc HuatOaEErvlronnani Permit Number: AIRS ID Number: 123 I 9FD9I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical.:Coordinates" (Latitude/Longitude or 1.1TM) 40.626117/-104.858296 Operator r „ Discharg Height Above ern p T , ≥Flow mate Ve oci Stack ID No` Ground Level` (feet)c).' { F) {ACF I) ' 'ftIse Combustors 12 1000 Variable Variable Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal 0 Downward 0 Other (describe): Indicate the stack opening and size: (check one) 0 Circular O Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): 48 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Loading occurs using a vapor balance system: Requested Control Efficiency: 70% ❑ Combustion Device: Used for control of: VOC and HAPs Rating: Type: Enclosed Combustors Requested Manufacturer Guaranteed Minimum Temperature: Constant Pilot Light: MMBtu/hr Make/Model:3 Cimmaron 48" Control Efficiency: 95 Control Efficiency: 98+ NA °F Waste Gas Heat Content: El Yes 0 No Pilot Burner Rating: 2399 Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 41 COLORADO Nua1�1sE61vlroivnrtni Permit Number: AIRS ID Number: 123 / 9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO, NO, CO VOC Vapor balance and Combustors 66.5% HAPs Vapor balance and Combustors 66.5% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL o Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL 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 Basis Units Source (/18-42, Mfg., etc.) , Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions - (tons/year)< Controlled Emissions (tons/year) PM SOX NO, CO VOC 2.4 lb/1000 gal AP -42 &if) 3,O 2.89 8.62' Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service CAS ( ) Number Emission Factor Actual Annual Emissions Uncontrolled B Basis _ Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emisslons 6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 Other: - 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5 I I n�,Rd aD 0 xwmeCn,im.uulr1 Permit Number: AIRS ID Number: 123 / 9FO9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. LA/1 ki tolet/i8 Signature of Legally Authorized Person (not a vendor or consultant) Date Kristin Van Hees Environmental Coordinator Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid. Loading APEN - Revision 7/2018 6i AY COLORADO Beputma[ d P:llc Health b Enehonmcnt 0CT 262018 Fugitive Component Leak Emissions APEN Form APCD-203 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 fugitive component leak emissions only. If your emission source does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Qov/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: AIRS ID Number: 123 / 9FD9 / QO 1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Mailing Address: Enerplus Resources (USA) Corporation Irish Well Pad SWSE Sec. 26, T8N, R67W Site Location Weld County: (Include Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 NAICS or SIC Code: 1321 Contact Person: Kristin Van Hees Phone Number: 720-279-5515 E -Mail Address2: KVanHees@enerplus.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 389472: Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 1 I A' COLORADO Nem Permit Number: AIRS ID Number: 123 / 9FD9 [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) -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change process or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: NGL Plant components only, the wellsite components are not included as they are not an affected facility under Nat. Gas Processing Plant 0000a. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information Company equipment Identification No. (optional): Plant FUG For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 11/30/2018 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: ❑ Well Production Facility5 0 Natural Gas Compressor Stations ❑✓ Natural Gas Processing Plants ❑ Other (describe): hours/day days/week weeks/year 5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 2 I Q•1 CoLORAbo ne.vcmauotrutuc }EMM f .Environment Permit Number: AIRS ID Number: 123 /9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? TBD Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes ❑ No Will this equipment be located at a stationary source that is considered a ❑ Yes ❑✓ No Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors ❑ Yes ✓❑ No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑ Yes ✓❑ No Is this equipment subject to 40 CFR Part 60, Subpart 0000? ❑ Yes ❑✓ No Is this equipment subject to 40 CFR Part 60, Subpart 0000a? ❑✓ Yes ❑ No Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑ Yes ❑✓ No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑✓ Yes ❑ No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? O Yes ❑✓ No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ❑ Yes ✓❑ No Section 5 - Stream Constituents ❑✓ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. Stream VOC (wt %) Benzene (wt %) ' Toluene. (wt %) Ethylbenzene (wt %) Xylene (wt %) > n -Hexane (wt %) Z'2'4 Trimethy(pentane (wt X) Gas 41.58 Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) 1 00 Water/Oil Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.626117/-104.858296 Attach a topographic site map showing location Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 31 ANf COLORADO Ilepaite.ntotP;31131e Hmes.l n ironme 1 Permit Number: AIRS ID Number: 123 / 9FD9 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK ❑ Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump O Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑✓ LDAR per 40 CFR Part 60, Subpart 0000/0000a 0 Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81% connectors ❑ LDAR per Colorado Regulation No. 7, Section XVII.F O Other6: O No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 ...__ COLORADO 4I •Y = Permit Number: AIRS ID Number: 123 / 9FD9 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ❑✓ Table 2-4 was used to estimate emissions7. ❑ Table 2-8 (< 10,000ppmv) was used to estimate emissions7. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ✓❑ Estimated Component Count ❑ Actual Component Count conducted on the following date: Service Equipment Type Connectors Flanges Open -Ended Lines Pump Seals Valves Other9 Gas Count8 326 11 44 2 Emission Factor Units Heavy Oil (or Heavy Liquid) Count8 Emission Factor Units Light Oil (or Light Liquid) Count8 60 3 3 Emission Factor Units Water/Oil Count8 Emission Factor Units 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 ICOIORADO 5 I A11Iiro }haft Permit Number: AIRS ID Number: 123 /9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? 2018 Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: (Use the data reported in Section 8 to calculate these emissions.) Chemical Name CAS Number Actual Annual Emissions Requested dim t Permit Emission -{)11 s Uncontrolled (tons/year) Controlled 10 (tons/year) Uncontrolled (tons/year) Controlled (tons/year) voc 1.34 Does the emissions source have any actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? O Yes ❑✓ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name CAS Number Actual Annual Emissions Requested Annual Permit Emission O11 Uncontrolled (lbs/year) Controlled10 Ohs/year) Uncontrolled (lbs/year) Controlled (lbs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4 Trimethylpentane 540841 Other: 1° Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 {COLORADO 6 1 B&W I ``P`®"`"""z Hsa1Ue b Envinnssrf Permit Number: AIRS ID Number: 1 23 /9FD9 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. vo Signature of Legally Authorized Person (not a vendor or consultant) Date Kristin Van Hees Environmental Coordinator Name (print) Title Check the appropriate box to request a copy of the: fl Draft permit prior to issuance E Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 COLORADO 7 I MAY i NVYt won , JAN 1 6 2019 Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: � \&) II Z,Q, AIRS ID Number: 123 / 9FD9 /COB [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Hamel: Site Name: Site Location: Enerplus Resources (USA) Corporation Irish Well Pad SWSE Sec. 26, T8N, R67W Mailing Address: 950 17th Street, Suite 2200 (include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1321 Contact Person: Kristin Van Flees Phone Number: 720-279-5515 E -Mail Address2: KVanHees@enerplus.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 Gas Venting APEN - Revision 7/2018 kstk'er— g0 3v36 392222 1AVCOLORADO HullA =ant Permit Number: AIRS ID Number: 123 /9FD9/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action L4 O CI NEW permit OR newly -reported emission source - OR - MODFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 El Add point to existing permit ja Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR - APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Combine this APEN and Separator APEN for one Flare limit 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Flaring of Processed Gas Company equipment Identification No. (optional): For existing sources, operation began on: NGL TBD For new, modified, or reconstructed sources, the projected start-up date is: Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattairment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year Yes Yes Yes ❑ No ❑✓ No No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I A® flar.annotnt of •COLOPADO hW Hoof IT F Cnhmnm.m Permit Number: AIRS ID Number: 123 /9FD9/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: O Compressor Rod Packing Make: Model: Serial #: - # of Pistons: Capacity: gal/min Leak Rate: Scf/hr/pist ❑ Blowdown Events # of Events/year: Volume per event: ❑✓ Other Description: Flaring of Processed gas through NGL skid MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? El Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 089 BTU/SCF Requested: : s-i,i MMSCF/year Actual: MMSCF/year -OR- r 7 I Requested: bbl/year Actual: bbl/year Molecular Weight: 20.86 VOC (Weight %) 15.64 ) S'. (.3 Benzene (Weight %) 0.0 Toluene (Weight %) 0.0 Ethylbenzene (Weight %) 0.0 Xylene (Weight %) 0.0 n -Hexane (Weight %) 0.0 2,2,4-Trimethylpentane (Weight %) 0.0 Additional Required Information: O Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 Gas Venting APEN - Revision 7/2018 ®® COLORADO 3 I awm� N tlTb[nNmn•.isr., Permit Number: AIRS ID Number: 123 /9FD9/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.626117/-104.858296 o#;`erator a tii Disctiar o Height,. �+e.:C,reiind` +C . Too.... c.6 Flow Rate (41 y 1 1 % Flare —30 1000 Variable Variable Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward Other (describe): Indicate the stack opening and size: (check one) ® Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 102 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. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: 0 Combustion Device: Pollutants Controlled: VOC Rating: Type: Enclosed Flare MMBtu/hr Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98+ Minimum Temperature: NA TBD Waste Gas Heat Content: 1 089 Btu/scf Constant Pilot Light: Q Yes ❑ No Pilot burner Rating: 0.02 MMBtu/hr Other: Pollutants Controlled: VOC and HAPs Description: 100% removal of HAPs prior to flaring and 21% reduction in volume Requested Control Efficiency: NA Form APCD-211 - Gas Venting APEN - Revision 7/2018 AV COLORADO 4 I RR D `f NUdj�EEn.iionn,�n� Permit Number: AIRS ID Number: 123 /9FD9/ [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC Enclosed Flare 95% HAPs Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NO. 0.068 lb/MMBtu AP -42 1.86 1.86 CO 0.31 lb/MMBtu AP -42 O,(, 8.43- 8.b 8t48- VOC 7.86 Ib/MMBtu Mass Balance 215.01 (0.1 10.75 - Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 5 I �. N.�eth II Est V 110n'iott Permit Number: AIRS ID Number: 123 / 9FD9 [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. ctva, %Apr) 1 fl15j10% Signature of Legally Authorized Person (not a vendor or consultant) Date Kristin Van Hees Environmental Coordinator Name (please print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1!i30 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 A COLORADO any 1AN 1 6 1019 Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options wilt 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: IgwE 112 R AIRS ID Number: 123 / 9FD9 /0 Gci [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Enerplus Resources (USA) Corporation Site Name: Irish Well Pad Site Location: SWSE Sec. 26, T8N, R67W Mailing Address: (Include Zip Code) 950 17th Street, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Kristin Van Nees Phone Number: 720-279-5515 E -Mail Address2: KVanHees@enerplus.com i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 Gas Venting APEN - Revision 7/2018 392223 COLORADO M 1 I . tvr " , Permit Number: AIRS ID Number: 123 /9FD9/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action NEW permit OR newly -reported emission source -OR- \(1 A MODIFICATION to existing permit (check each box below that applies) /Atk ❑ Change fuel or equipment ElChange company name3 0 Add point to existing permit Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - E] Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Combine this APEN and NGL APEN for one Flare limit 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Flaring of separator gas Company equipment Identification No. (optional): For existing sources, operation began on: Separator 8/4/2018 For new, modified, or reconstructed sources, the projected start-up date is: • Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section ,XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 El days/week weeks/year Yes Yes Yes ❑ No • No ❑ No 2 I �COLORADO . 1= 4",=, Permit Number: AIRS ID Number: 123 /9FD9/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Process Equipment Information O Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Capacity: gal/min Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Q Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 1486 BTU/SCF Requested: 75.4 MMSCF/year Actual: 553,36 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 26.266 ..- VOC (Weight %) 41.58 Benzene (Weight %) 0.0014 Toluene (Weight %) 0.0007 Ethylbenzene (Weight %) 0.0001 ' Xylene (Weight %) 0.0002 n -Hexane (Weight %) 0.0062 - 2,2,4-Trimethylpentane (Weight %) 0.0002 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 Gas Venting APEN - Revision 7/2018 •COLORADO 3 . N 1" Permit Number: AIRS ID Number: 123 / 9FD9 l [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.626117/-104.858296 rat*'I'p • Ois. arge ti i lc- :0 ve round flan► date fie! Flare -30 1000 Variable Variable Indicate the direction of the stack outlet: (check one) ® Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular O Other {describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 102 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. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Flare Make/Model: TBD Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98+ % Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: 1486 0.02 Btu/scf MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 Gas Venting APEN - Revision 7/2018 4I IgV.COLORADO Heath E Enw,nnner.4 Permit Number: AIRS ID Number: 123 /9FD9/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOx CO VOC Enclosed Flare 95% HAPs Enclosed Flare 95% Other: 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)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOx NOx 0.068 lb/MMBtu AP -42 2.70 2.70 3,$ 3,84 3.$ 3.81- CO 0.31 lb/MMBtu AP -42 12.30 12.30 17.37 17.37 VOC 19.39 lb/MMBtu Mass Balance 768.40 38.42 1086.29 S'(.3 C4.31 — Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service CAS -(CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) 252 Benzene 71432 94.60 lb/MMscf Mass Balance 5047.7 Toluene 108883 62.92 Ib/MMscf Mass Balance 2257.4 168 Ethylbenzene . 100414 8.19 lb/MMscf Mass Balance 437.1 22 Xylene 1330207 17.29 lb/MMscf Mass Balance 922.7 46 n -Hexane 110543 432.49 lb/MMscf Mass Balance 23077.8 1154 2,2,4- Trimethylpentane 540841 13.38 lb/MMscf Mass Balance 714.0 36 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. O Form APCD-211 Gas Venting APEN - Revision 7/2018 AV 'COLORADO 5 ==g=t Permit Number: AIRS ID Number: 123 / 9FD9 / [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. ttv•iN %/%-r) Signature of Legally Authorized Person (not a vendor or consultant) Kristin Van Flees I15ID, Date Environmental Coordinator Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ✓0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 or visit the APCD website at: https: //www.colorado.gov/cdphe/aped Form APCD-211 Gas Venting APEN - Revision 7/2018 COLORADO 6 I �. eEntI . Hello