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HomeMy WebLinkAbout20192275.tiffCOLORADO Department of Public Health €t Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 June 10, 2019 Dear Sir or Madam: RECEIVED JUN 1 4 2Z19 WELD COUNTY COMMISSIONERS On June 13, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for SRC Energy, Inc. - Beebe 3-34 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: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer POOV Pte ytek.) cc:?LCTP4 NL(sq WIJMIeskIcAlc") Co/ICI /Icl CP/1411cl 2019-2275 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: SRC Energy, Inc. - Beebe 3-34 Pad - Weld County Notice Period Begins: June 13, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: SRC Energy, Inc. Facility: Beebe 3-34 Pad Exploration Et Production Well Pad NENW Sec. 34 T6N R66W Weld County The proposed project or activity is as follows: This is a new facility that is requesting individual permits for their 10% contingency condensate loadout and their condensate storage tanks. Additionally, they have requested GP08 coverage for their produced water tanks and GP02 coverage for three (3) natural gas fired reciprocating internal combustion engines. The general permits were received at the same time as the individual permits and were processed concurrently. 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 18WE0210 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 ADO COLORADO Air Pollution Control Division Department of Public Health & Er.vlronnnent Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 1 8WE021 0 Issuance: SRC Energy, Inc. Facility Name: Beebe 3-34 Pad Plant AIRS ID: 123/9F9F Physical Location: NENW SEC 34 T6N R66W County Weld County General Description Well Production Facility Equipment or activity subject to this permit: 1 Facility Equipment 1 AIRS Point Equipment Description Emissions Control Description LDG-1 001 Truck loadout"of condensate by submerged fill Enclosed Combustion Device 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 Page 1 of 10 COLORADO Air Pollution Control Division Department of Pubic Health & Envirohoient Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit 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. LIMITATIONS AND RECORDS EMISSION 5 E isstons `of air pollutants shat not exceed the • m l Number 3, Part B, Section II.A.4) Annual Limits following limitations. - (Reference: "Regulation Facility Equipment ID AIRS. " . Point '. T - " Per Year Emission Type ; PM2.5 :."NOX VOC Cn' LDG-1 001 --- - 0.5 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. 4;- Facility -wide emissions of each individual hazardous air 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. pollutant shall not exceed 8.0 tons per Page 2 of 10 COLORADO Air Pollution Control Division Department of Public. Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LDG-1 001 Enclosed Combustion Device (Leed 30" Enclosed Combustor) VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. 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 rocess/Consumption Limits Facility Equipment AIRS Point Process Parameter Annual Limit LDG 1 001. Condensate Loaded 123,596.3 barrels ompliance with the annual throughput -limits shall be determined on a rolling -twelve (12) onth total By the end of each month a new twelve-month total is calculated based on the revious twelve months' data. . The permit holder shall calculate throughput each month and eep a compliance record on site or at a local field office with site responsibility, for Division STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. 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. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.D.2) 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. Page 3 of 10 COLORADO Air Pollution Control Division Department of Pubuo.Health £r£rvirottment Dedicated to protecting and improving the health and environment of the people of Colorado 11. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. spect pressure relief devices (PRD) annually for proper operation and replace as ecessary. PRDs shall be set to release at, a pressure tl at 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. 12. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3. Part B. 'III D.2). 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. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING £t MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&tM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 COLORADO Air Pollution Control Division Department of Pubiii: Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C. ,nnually by April 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 fast APEN; or For volatileorganic compounds (VOC)-and nitrogen oxides sources (NO.) in ozone nonattainment„areas emitting less than 100 tons of VOC or NOS per year, a change in annual. actual emissions of one (1) ton per year or more or five percent, hichever is greater, above the Level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actualemissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 17. 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 Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Ervirorunertt Dedicated to protecting and improving the health and environment of the people of Colorado commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self certification of all points has been reviewed and approved by the Division, it wilt provide written documentation of such final authorization. Details for obtainingfinal authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is` conditioned upon conduct of the activity, or construction, installation and operation of ,,:the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. Itis valid only for the equipment and operations or activity specifically identified on the permit,,, 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. Page 6 of 10 By: COLORADO Air Pollution Control Division Department of Public He&Rh E." Ervi or ment Dedicated to protecting and improving the health and environment of the people of Colorado Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to SRC Energy, Inc. Page 7 of 10 COLORADO Air Pollution Control Division Repast rent of Public Health & Envi;oscmeni 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 cif non -criteria reportable air pollutants are estimated based, upon the process limits as indicated in this permit. This ,information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions _ (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 29 1 001 Toluene 108883 33 2 Xylenes 1330207 18 1 n -Hexane 110543 353 18 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division LUepartment of Public Health & Er virotme€tt Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 1.67E-01 8.35E-02 AP -42, Chapter 5.2, Equation 1 Benzene 71432 2.35E-04 1.18E-05 Toluene 108883 2.70E-04 1.35E-05 Ethylbenzene 100414 1.39E-05 6.95E-07 Xylene 1330207 1.48E-04 7.40E-06 n -Hexane 110543 2.85E-03 1.43E-04 2,2,4- Trimethylpentane 540841 1.06E-05 5.30E-7 the'"uncontrolled VOC emission factor was calculated using AP -42, Chapter Eversion 1/95) using the following values: L = 12.46*S*P*M/T S= 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 6.2 psia M (vapor molecular weight) =45.19 lb/lb-m°l T (temperature "'of liquid loaded) = 526-°R Equation 1 e uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were, calculated multiplying the mass fraction of each NCRP in the "Working" emissions stream from the omax Simulation based on the pressurized liquid sample taken 1/8/2018 by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, n -Hexane, Total HAPs NANSR Synthetic Minor Source of: NOx, VOC Page 9 of 10 PSD COLORADO Air Pollution Control Division T3ePartrr3ent of Pubic Health h.Er?Y•iror o erts.. Dedicated to protecting and improving the health and environment of the people of Colorado Synthetic Minor Source of: V0C 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //www.ecrf.gov Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK 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 63.600-63.1 99 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP Subpart MACT 63.1440-63.6175 part YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX:._ Page 10 of 10 COLORADO Air Pollution Control Division Department of Pub",?c Healy[ & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE0211 Facility Name: Plant AIRS ID: Physical Location: aunty'' on: Issuance: 1 SRC Energy, Inc. Beebe 3-34 Pad 123/9F9ir NENW SEC 34 T6N R66W Weld County Well Production Facility Equipment or activity.subject to this permit: Facfity Equipment ID AIRS Point Equipment Description Emissions Control Description TNK 1-8 002 Eight (8) 4D0 barrel fixed roof storage vessels used to store condensate liquids Enclosed Combustion Devices 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 etseq), 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 Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health E Erviro nest Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit 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. Tile 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 ANDY RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, ,.Part B, Section II.A.4 Annual Limits Facility Equipment ID AIRS point Tons per Year ,,, Emission Type PM2.5 NO. VOC CO TNK 1- 002 3.7 40 5 16.9 Point Note: See "Notes to Permit Holder" for information on emission factors an 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 shalt not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Envirorroerli Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled TNK 1-8 002 Enclosed Combustion Devices (Four (4) - 96" IES Combustors) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TNK 1-8 002 Condensate throughput 1,235,963 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 W f:? 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be, marked on the subject equipment for ease of identification. (Regulation Number 3, Part ' B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Page 3 of 10 COLORADO Air Pollution Control Division Department erf Pubiic. Health £, Ertviro?i, lent Dedicated to protecting and improving the health and environment of the people of Colorado Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been ,authorized by:permit prior to May 1,2014. The source shalt follow -the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by, this permit are subject to the venting and Storage Tank Emission Management System ("S iLM") requirements'' of Regulation Number 7, Section XVI C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the; owner or, operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format ;approved by the Division, An order to demonstrate compliance on an ongoing basis with the tequirements of this permit. Revisions to the tem-plan are subject to Division approval prior to.implementation. (Regulation; Number 3, Part B, Section III.G.7.}' COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) 17. A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval Page 4 of 10 COLORADO Air Pollution Control Division Department of Pubic Health , &:virorimenl Dedicated to protecting and improving the health and environment of the people of Colorado at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) 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: or sources emitting less than 100 tons per year, a change in actual emissions of five 5) tons per yearoir more, above the levelreported on the last APEN, or . For volatile organic compounds (VOC) and nitrogen oxides sources (N0x) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN,• or For sources emitting 100 tons per ; year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less,above the level reported on the last APEN submitted; or For, any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) 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 Number 3, Parts C and D). Page 5 of 10 COLORADO Air Pollution Control Division Department of Pub;fc Heath b Ervirotanert. Dedicated to protecting and improving the health and environment of the people of Colorado GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in tie Requirements to Self Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, Installation and operation of the source, in accordance : with this information ' and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and„operations or activity specifically identified oh -the permit 24. Unless specifically stated otherwise, the general and specific "conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. .: 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. Page 6 of 10 By: COLORADO Air Pollution Control Division Department of Public. Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Lauraleigh Lakocy Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to SRC Energy, Inc. Page 7 of 10 002 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 TOI the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant 71432 Uncontrolled Emissions '. (Ib/yr) Controlled' Emissions (lb/yr) Benzene 9,023 180 Toluene 108883 9,789 196 Ethylbenzene 100414 467 9 Xylenes 1330207 5,290 106 n -Hexane 110543 72,798 1,456 2,2,4- Trimethylpentane 540841 282 6 Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public. Health & Er ronment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 5.99E-03 5.99E-03 AP -42, Chapter 13.5 CO 2.73E-02 2.73E-02 VOC 3.277 6.55E-02 ProMax simulation of flash and working/breathing emissions based on a pressurized liquid sample analysis taken 01 C08f2t18 71432 Benzene 7.30E-03 1.46E-04 108883 Toluene 7.92E-03 1.58E-04 100414 Ethylbenzene 3.78E-04 7.56E-06 1330207 Xylene 4.28E-03 8.56E-05 110543 n -Hexane 5.89E-02 1.18E-03 540841 2,2,4-2.28E-04 Trimethylpentane 4.56E-06` Note: The Controlled emissions factors for this point are based on a control efficiency of 98%. The combustion emissionsare based on a waste gas heat content of 2,537 BTU/scf. 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 shalt be sub►itted'no later than 30 days before the five year term expires. Please refer to the mostirecent annual fee invoice to determine. the APE expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at`(303)=692-315Q 7) This'permit fulfills the requirement to:hold a valid permit ref lecting,the storage tank and associated control device per the Colorado Oil and :.Gas Conservation Commission rule 805b(2)(A) when applicable• 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6l. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalreQister.gov/documents/2016/06/03/2016-11971 /oil -and - natural -Ras -sector -emission -standards -for -new -reconstructed -and -modified -sources 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, n -Hexane, Total HAPs NANSR Synthetic Minor Source of: NOx and VOC PSD Synthetic Minor Source of: VOC Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT HH Area Source Requirements: Not Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.Rov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ Subpart MMMMM' Subpart NNNNN - Subpart XXXXX CT 63.8980 -End. Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: 2)?/3Ltis Review Start Date: ?s/2&12G1e I Section 01- Facility Information Company Name: �;SF.tC.EnerE County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: What industry segment?. Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Carbon Monoxide (CO) y NENW quadrant of Ser tiun 34, Township 6N, Rage 66W Weld County Section 02 - Emissions Units In Permit Application fParticulate Matter (PM) Quadrant Section Township Range NENW 4' ,I1 Ozone (NOx & VOC) AIRS Point Is Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks to log ontina 5021 Gain r,>ate Tank T 13UlED Section 03 - Description of Project Th eating individual permits forthteir 10%coral Ind cPO2 coverage for their three(3) natura 'ocesseditcnCttrreitiy, .. Section 04 - Public Comment Requirements Is Public Comment Required? rewa If yes, why? eq aloadnutant)the,rtteato€geetant¢s A ki all they are requesting' GPOScoverage. ,reciprocal„E internal combustion engines; The gene aj 3 T v ere eecieved attire same time as the Section 05 -Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? «" If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs 1 Is this stationary source a major source? , ' r"t If yes, explain what programs and which pollutants her( 502 NOx Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) CO r— VOC PM2.5 PM10 r— ❑ ❑ TSP HAPs ❑ ❑ Hydrocarbon Loadout Emissions inventory 001 Liquid Loading Facility AIRs ID: Coun Plant DDx Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: 05.00 :.,, tdh8ed Cambusto: 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 = 02990) Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 22 Barrels (bbl) per year Requested Monthly Throughput = Barrels (bbl) per year .ii3497 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 = Btu/scf 173477 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/T .369 MMBTU per year 443 MMBTU per year 53.1 MMBTU per year Barrels (bbl) per year A site specific stabilized hydrocarbon liquid sample must he provided to develop a site specific omissions fec[oc- Factor Meaning Value Units Source S Saturation Factor 0.6 - ��`u '`— A�4?, �v. Sir P True Vapor Pressure "{r 2 p a s�i e, AP 42Tabie 7< =1 " - - M Molecular Weight of Vapors �.--.,45;,3$ ,g, lb/lb-mol Mot2e.udar We l fl*)afysstslaos It no Ill rklna' straam Iron F?fKtii$Y,2iiiNnlatIon T Liquid Temperature ";Sg5.67 '1 Rankine M. .�='Tcrab ra L Loading Losses 3.884643541 lb/1000 gallons 0.16-07365 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene .0,4D1di - Il 11E307_₹59'Ti lb/bbl „ Mds5 F,ractton frg 0 Wmrking"Streaus to f23'msa>tSlmiYiatb3n (,1d0.51fO s5 SCP0) Toluene iiinii0.0316143 0,8.00370262 lb/bbl .,. 404,0241Eidlhditi8VCir if raominpro:ma"0Sf lation4 9s".'VON3,bpsvetgd6000 Ethylbenzene 0;0004828 1.35732E-051b/bbl co ti' Stfdz0wIMP' rbIri�57m41atiaY9{ 44/a,.U'QCsby3}ue Xylene El0008140 0.0001.48042 lb/bbl ` Macy Ptastionfrotiv,.% sing"Oti"arn In Ylea(naii*,Alf7tulatlbS i f i` cOOY--s``+44W... n -Hexane U 8170664 0.302856152 lb/bbl F..eaciiiiri, i:"Working"Stre m irnRcuriiau'SimOlatfaSr.( 208341364 b' igiri) 224 TMP -0,00006332 1.06969005 lb/bbl ill&ass,Faaction koon 5Wor$ing" 52r ani trfPi',rrrrY°4` .Smiulst O ,(1bL1%'VOCo byiv plal) .. - Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Volume Loaded) (Volume Loaded) 0.37E-03 1..18E-05 1.35£ -OS 6.54E-07 7.411E 06 1.43E-14 5,34E-07 Emission Factor Source VOC 1.67E-01 2.36EE 04 2.70E-04 1.39E-05 1.485-04 2,26E-03 1.04E-05 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Emission Factor Source Pollutant (waste heat combusted) Control Device Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) (Volume Loaded) 1.67E-35 2.87E-05 2.11E 06 2,431-0,4 1,11E.03 PM10 PM2.5 AMON SOB NOx CO 2 of 10 K: \ PA\2 018\18 W E 0210. C P 1 Hydrocarbon i_oadout 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 (Ibs/month) PM10 PM2.5 5Ox NOx VOC CO 0.00 0.00 0,00 0.00 0,00 0 0.00 0.00 0.00 0.00 0,00 0.00 0,00 0.00 11.00} 11.011 0 002 0.01 0.01 0.02 0.02 3 12.41 8.62 0.43 20.34 0.52 88 0.00 0.04 0.00 0.07 0.07 12 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 224TMP 35 24 .1. 29 1 40 28 1 33 2 2 1 0 2 0 22 .1r .1. 18 .1 424 294 15 303 to 2 7. II 1 11 Section 06- Regulate y,Summary Anal Regulation 3, Parts A, 8 Source reguIre5 a permit RACT- Regulation 3, Part 8, Section III.D.2.a (See regulatory applicability worksheet for detailed analysi ) The loadout ,must be epmated with snitmerged fill to satisfy RAIL. Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95%for a flare or combustion device? , ?: • fA,n- _ 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 Source did not use a stabilized liquid sample analys s but instead used pressurized liquid Isadout. Source utt6zed AP -42 methodology to calculation VOC emassic —` Per the ADEN, the fast 2 per mt exempt questions were answered as yes; how Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point ft Process 8 SCC Code :ustidrr related emissions are non-r_eportabin of applicable due to operationallconditiods.Thissourc 001 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) ' ffi n the permit Uncontrolled Emissions Pollutant Factor PM10 0.00 PM2.5 0.00 SOx 0.000 NOx 002 VOC 4,0 CO 0.03 Benzene 0.01 Toluene 0.01 Ethylbenzene 0.00 xylene 0.,30 n -Hexane 0.07 224 TMP 0.00 Control% Units O lb/1,000 gallons transferred O lb/1,000 gallons transferred O lb/1,000 gallons transferred O lb/1,000 gallons transferred 95 lb/1,000 gallons transferred O lb/1,000 gallons transferred 45 lb/1,000 gallons transferred 95 lb/1,000 gallons transferred 95 lb/1,000 gallons transferred 05 lb/1,000 gallons transferred 95 lb/1,000 gallons transferred 95 lb/1,000 gallons transferred 3 of 10 K:\PA\2018\18 W E0210.CP1 Hydrocarbon loadout Regulatory Analysis Worksheet Colorado Re. ulatlon 3 Parts A and B- APEN and Permit Requirements agitate i_ in the Non-Atteinmant Ares ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 WY (Regulation 3, Part A, Section II.D.1.e)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.117 3. Is the loadout operation loading less than 10,000 gallons (238 BBls) of crudeoil per day an an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section 11.0.3)7 'Yoe have ,noiiucfed that so urea is In the Plom:Atta-umer.4 Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section 11.0.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (2313 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? ISauae requires a permit 7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.0.2.al? 'TPA luaacui :gust he operated with auh,torged fill to sa4isiy RAOT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may,""should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the tents of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself idC�(•E MO* Go to next Go to then Go to next Go to next Go to next The loadou AAreete AThe loadou Condensate Storage Tank(s) Emissions Inventory 002 Condensate Tank 'Facility AIRs ID: County Plan Dtaz , Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: FORA (4 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = 029 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 1,083. Barrels (bbl) per year Requested Monthly Throughput = 1114472 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput Barrels (bhp per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = 33,4;; scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Btu/scf 7,2274:'. MM BTU per year a.0'. MM BTU per year Potential to Emit (PTE) heat contem of waste gas routed to combustion device = i2a57r' MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bhl) (Condensate Throughput) (Condensate Throughput) Emission Factor Source VOC 0.07 0,000 0.000 0.000 0,040 0.007 Benzene Toluene Ethylbenzene Xylene n -Hexane 0,044 224 TMP Emission Factor Source Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat (Condensate combusted) Throughput) PM10 PM2.5 0.0006 0.0000 0,0008 0,0263 NOx CO Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled Icons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 NOx CO 2430.2 1687.9 33.0 2025,1 40.5 5890 0.3 0.3 0..3 0.4 0.4 66 0.5 0.3 0.3 0-4 0.4 66 4.3 0,5 3,0 3.5 3.9 605 19,3 .3::3.5 13.3 16.2 15.7 7757 Hazardous Air Pollutants Potential to Emit Uncontrolled Ohs/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 TMP 10027 7519 150 9033 150 .17147 81:7 153 4709 195 561 380 0 467 9 6348 4408 88 5190 106 87330 60664 1213 733173 1416 338 235 a 282 6 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Source require; a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, S=_ct:o:i X:€.C-F Regulation 7, Section 111.6, C Storage Tank is not subject to Regulation 7, Scx tion 31€.0 Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section 3011, 8, C.2.% C.:3 Regulation 7, Section XVII.C.2 Storage tank €s subject to Regulation 7, Section 3011.0,2 Regulation 6, Part A, NIPS Subpart Kb St. -age Tank is not stabled to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to 0193 00010 Regulation S, Part E, MACT Subpart HH Storage Tank is not subject to MACT #0H (See regulatory applicability worksheet for detailed analysis) 5 of 10 K:\PA\2018\18 W E021O. CP1 Condensate 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 80 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 05-01. 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 drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. .17 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 00 -Technical Analysis Notes , ;Ualtim sf mast® gas emftted/bi) ihro-ughputsyas siege aas a well -affected facility and a AIRS Point # Process # 5CC Code 002 01 tt...- Section 09 - Inventory 5CC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.02 0 15/1,000 gallons condensate throughput PM2.5 0.02 0 16/1,000 gallons condensate throughput NOx 0.14 0 16/1,000 gallons condensate throughput VOC 78.0 98 16/1,000 gallons condensate throughput CO 0.63 0 16/1,000 gallons condensate throughput Benzene 0.17 98 lb/1,000 gallons condensate throughput Toluene 0.19 98 15/1,000 gallons condensate throughput Ethylbenzene 0.01 98 lb/1,000 gallons condensate throughput Xylene 0.10 98 lb/1,000 gallons condensate throughput n -Hexane 1.40 98 lb/1,000 gallons condensate throughput 224 TMP 0.01 98 lb/1,000 gallons condensate throughput 6 of 10 KtPA\2018\18W E0210.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and 0-APEN and Permit Requirements I5oa:ex, Is Diu t000A:L'iinn:ent Anna Trt Or 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greamrihan 2 TPY(Regulation 3, Part A,Section 11.0.1.a)? 2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather eppllcabilhy)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 P. or CO emissions greater than 10 TPY (Regulation 3, Part B, Sectionll.D3)? IYon has+ indicalesi°I:at Dues iv In the Non-Attuinnrentntea NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3. Part A, Section ll.D.1.a)? 2. Is the construction. date (service date) priorto 12/30/2002 and not modified after 12/31/20021tee PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicabillty)? 3. Are total facility uncontrolled VOL emissions greater than 2 TPY, NOT greater than 5 TPY or CO emissions greater than 10 TOY (Regulation 3, Part B, Section 11.0.2)? la e requires epermit. Colorado Regulation 7, Section 01.0-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation`, natural gas compressor station or natural gas drip station? 3. Is this storage tankloated upstream of a natural gas proc sing plant? ISv,raen tank is sub;eotso Heuulat:or Section 01.0.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section XII.C.2— Emission Estimation Procedure Section MILD —Emissions Control Requirements Section XII.E— Monitoring Section XII.F— Recadkeeping and Reporting Colorado Regulation 7. Semen X11.0 1. Is this storage tank located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Isthle storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit"Flashe (e.g. string no stabil'aed liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? ISrerage ran 10 not1:ib:e0 to R_mildien ?, Section Xll.A Section 01.0.2 - Emssions Control Requirements Section )01.C.1 - General Requirements for Air Pollution Control Equipment- Prevention of Leakage Section XII.C.2 -Emission Estimation Procedures Colorado Regulation 1, Semen XVII 1. Is this tank located at a transmission/storage facility? 2. Is thls condensate storage tanks located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storagetank a fixed roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to car greater than 6 tons per year VOC1 • ISta: sr... Regstl:nt:on 2, Section rill:. R, C18,73 Semen XVII.e—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section IMI.C3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only...abi111ed"Ilqubb? ISLo-a ct tan. .s puree... La Regitiatren 0, Sod.,11.11. Section X011.01- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 4o CFR. Part 60. Subpart an, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (0')1'472 nobs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)7 a. Does the vessel has a design capacity less than or equal to 1,589.874 m' 1'10,000 BBL) used for petroleumorondensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was the condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) efterluly 23, 1984? 4. Does the tank meet the definition of "storage vessel" in 60.111b? 5. Does the storage vessel store a"volatile organic liquid (VOL)" as defined in 60.11lb? 6. Does the storage Vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa 1`29.] psi) and without emissions to the atmosphere (60.110h(d)(2()?; or b. The design capacity is greater than or equal to 151 m' ["550 BBL( and stores a Ifauid with a maximum true vapor pressure' less than 35 eta (60.110dtb()?; or c. The design capacity s greater than car equal to 75 Ma [`622 BBL) but less than 151 m' 1"950 BBL( and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.1100(b()? IsLoeurie5,r0h:s nor pu16et.410 NrP6 hb Subpart A, General Provisions §601126- Emftsions Control Standards for VOC §60.1136- Testing and Procedures §60.1150- Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude OR and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located ate facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 2. Was the condensate storage vessel conatrutted,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential V0C emissions' from the individual storage vessel greater than or equal to 6 tans peryear? 4. Does this condensate storage vessel meet the definition of"eroragevssel"' per 60.5430? 5. Is the storage vessel subject to and controlled In accordance with requirements for storage vessels In 40 CFR Part 50 Subpart Kb or 40 CFR Part 63 Subpart HH? IGb.-.-siltmrreo WV 000? Subpart A, General Provisions per §605425 Table 3 560.5390 - Emissions Control Standards for 1/00 §60 ting and Procedures §60.53951g)- ',reification, Reporting and Recordkeeping Requirements 56o.s416(c) - Cover and Closed Vent system Monitoring Requirements §60.5417- Control Device Monitoring Requirements [Note: Ira storage vessel is previously determined to be subject to NIPS 0000 due to errdssions above 6 tons per year VOC on the applicability determination date, it should remain subject to SOPS 0000 per 60.5365(e)(2) even It potential VOC emissions drop below 6 tons per year) so CFR. Pan 63. Subpart MAR HH. Oil and G. Production Facilities 1. s the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades arstores hydrocarbon liquids' (63.260(x)(2)); Qi b. Afacility that processes, upgrades or stores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.260(e)(3)(? 2. Is the tank located at a facility that a majors for HAPs? 3. Does the tank meet the definition of "storage vessel"' in 63,?61? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions' per 63.]61? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? IG:e,zgn 000.. 0100 011-.00000 MACY HH Subpart A, General provisions per §63.]64 (a) Table 2 §63.266 - Emissions Control Standards §63.773 -Monitoring §63.274- Recordkeeping §63.775 -Reporting RACT Review RACT review Is required If Regulation 7 does not apply AND If the tank is In the non -attainment area. If rite tank meets both criteria, then review RAU requirements. Disclaimer This document assists operators with determining applicability of certain regcirements of the Clean Air Act, as implementing regulations, and Air Quality Control Commission regulations. This document is note rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any few, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language Of this document and the language of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations, the language °Pale statute or regulation will control. The use of non -mandatory language such as "recommend" 'should,' and'can,' is intended to describe APCD interpretations and recommendations. Mandatory terminology such 20 5,00t" and "required, are intended to describe controlling requirements under the terms of the. Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself T a Source Req Ga to next source Req Continue Continue st Continue-' Storage Tar Continue Go to the n Go to the n Source is sr Continue Storage Tar storage Tar COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc County AIRS ID 123 Plant AIRS ID 9F9F Facility Name Beebe 3-34 Pad History File Edit Date Ozone Status 3/25/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN T AIRS PERMIT Description PM10 PM2.5 H2S S02 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE0210 Contingent Condensate 0.0 10.3 0.1 0.2 0.0 0.5 0.1 0.0 Newly requested point, Calculated via AP - 002 18WE0211 Condensate Storage Tanks (8)- 0.4 0.4 3.7 2,025.4 16.9 48.8 0.4 0.4 3.7 40.5 16.9 1.0 Newly requested point, EF from ProMax 003 GP08 Produced Water Tanks (2) - 0.7 37.4 3.1 3.4 0.7 5.9 3.1 0.2 New GP08 - state emission factors 004 GP02 Doosan 390 HP 4SRB RICE 0.2 0.2 27.5 2.6 46.2 0.4 0.2 0.2 0.3 2.6 0.2 0.4 New GP02 005 GP02 Cummins GTA 855, 225 HP 0.2 0.2 26.3 1.5 6.3 0.3 0.2 0.2 2.2 1.5 4.3 0.3 New GP02 006 GP02 Caterpillar 365 HP 4SRB RICE 0.1 0.1 88.7 2.4 7.2 1.3 0.1 0.1 3.4 2.4 6.8 1.3 New GP02 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 12 Heaters (Emissions from All) 0.2 0.2 3.2 0.20 2.7 0.1 0.2 0.2 3.2 0.20 2.7 0.1 From Form APCD-102 Fugitive Emissions 0.4 0.0 0.4 0.0 From Form APCD-102 0.0 0.0 FACILITY TOTAL 1.1 1.1 0.0 0.0 150.1 2,079.8 0.4 82.5 54.5 1.1 1.1 0.0 0.0 13.5 53.6 0.4 34.1 3.2 VOC: Bye Minor (NANSR, PSD and OP) NOx: Bye Minor (OP), True Minor (NANSR) CO: True Minor (PSD and OP) HAPS: Syn Minor n -hexane and Total Permitted Facility Total 0.9 0.9 0.0 0.0 146.9 2,079.6 0.0 79.8 54.5 0.9 0.9 0.0 0.0 10.3 53.4 0.0 31.4 3.1 Excludes units exempt from (A) Change in Permitted Emissions 0.9 0.9 0.0 0.0 10.3 53.4 0.0 31.4 Pubcom required based on synthetic minor permits & project emissions Note 1 Total VOC Faci ity Emissions (point and fugitive A) Change in Total Permitted VOC emissions (point and fugitive 54.0 Facility is eligible for GP02 because < 90 Project emissions not less than 25 tpy 53.4 Note 2 Page 8 of 10 Printed 4/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name SRC Energy, Inc 123 9F9F Beebe 3-34 Pad Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0210 Contingent Condensate Loading (10%) 29 33 2 18 353 1 0.2 002 18WE0211 Condensate Storage Tanks (8)-400bbl 9023 9789 467 5290 72798 282 48.8 003 GPM Produced Water Tanks (2) - 400 bbl 1665 5233 3.4 004 GP02 Doosan 390 HP 4SRB RICE 510 39 65 39 76 0.4 005 GP02 Cummins GTA 855, 225 HP 4SRB 380 52 49 29 57 0.3 006 GP02 Caterpillar 365 HP 4SRB RICE 2384 68 64 38 74 1.3 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 12 Heaters (Emissions from All) 4 115 0.1 Fugitive Emissions 2 7 1 13 15 0.0 0.0 TOTAL (tpy) 1.6 0.1 0.1 5.4 4.9 0.2 2.7 39.3 0.1 0.1 0.0 0.0 54.5 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0210 Contingent Condensate Loading (10%) 1 2 0 1 18 0 0.0 002 18WE0211 Condensate Storage Tanks (8)-400bb1 180 196 9 106 1456 6 1.0 003 GP08 Produced Water Tanks (2) - 400 bbl 83 262 0.2 004 GP02 Doosan 390 HP 4SRB RICE I 510 39 65 39 76 0.4 9 18WE0210.CP1 4/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name SRC Energy, Inc 123 9F9F Beebe 3-34 Pad 005 GP02 Cummins GTA 855, 225 HP 4SR 380 52 49 29 57 0.3 006 GP02 Caterpillar 365 HP 4SRB RICE 2384 68 64 38 74 1.3 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 12 Heaters (Emissions from All) 4 115 0.1 Fugitive Emissions 2 7 1 13 15 0.0 0.0 TOTAL (tpy) 1.6 0.1 0.1 0.2 0.1 0.0 0.1 0.9 0.1 0.0 0.0 0.0 3.2 10 18WE0210.CP1 4/4/2019 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. 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: t (JD 0 2 A. O AIRS ID Number: 123 / m c- G ` [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: LDG-1 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: Beebe 3-34 Pad Site Location: NENW Sec. 34 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Greeley, CO 80634 E -Mail Address2: brogers@srcenergy.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brad Rogers Phone Number: (970) 475-5242 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on alt documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 3155° 1I AVCOLORADO �V aounn��� of e,tiw� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 O Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: Requesting 10% load out as contingency 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: Contingency truck load out of condensate from storage tanks For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 11/ 28 /2017 Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? ▪ Yes O No ❑ Yes ❑✓ No ❑ Yes ❑✓ No ❑ Yes O No • Yes ❑ No E Yes ❑ No ❑ Yes ❑✓ No Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 2 I E7 Department DI Fuabc HasIU.6 &unto .DD!I • Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 123,596.3 Bbt/yr Actual Volume Loaded: 102,995.7 Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") tank trucks If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 66 nF True Vapor Pressure 5.2 Psia 60 ° F Molecular weight of displaced vapors 45.19 Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: Bbl/yr Actual Volume Loaded: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 � V COLORADO 3 I E`77 �I�Yi 6 FhnNnYinYmu Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.44917 /-104.76360 Operator ' Stack ID No. Discharge Height Above. Ground Level - (Feet) Temp. (° F) Flow Rate (ACFIN) : Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward El Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): 0 Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system: Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 14.88 Type: Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 1076 F MMBtu/hr Make/Model: Leed 30" L30-0011 95 98 % Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes 0 No Pilot burner Rating 2551 0.051 Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 �� COLORADO 4 � H7:=7,W°,d`:,',1, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO,, CO VOC Leed 30" enclosed combustor 95% HAPs Leed 30" enclosed combustor 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate 0.236 Lbs/BBL ❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2017-18 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions - . ° Requested Annual Permit s , - Emission Limits) Uncontrolled (Torts/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO), VOC 1.67E-01 lbs/bbl ProMax 8.61 0.43 10.33 0.52 CO Benzene 2.35E-04 Ibs/bbl ProMax 1.21E-02 6.06E-04 1.45E-02 7.27E -d4 Toluene 2.70E-04 Ibs/bbl ProMax 1.39E-02 6.95E-04 1.67E-02 8.34E-04 Ethylbenzene 1.39E-05 lbs/bbl ProMax 7.14E-04 3.57E-05 8.56E-04 4.28E-05 Xylenes 1.48E-04 lbs/bbl ProMax 7.62E-03 3.81 E-04 9.14E-03 4.57E-04 n -Hexane 2.85E-03 lbs/bbl ProMax 1.47E-01 7.35E-03 1.76E-01 8.82E-03 2,2,4- Trimethylpentane 1.06E-05 Ibs/bbl ProMax 5.45E-04 2.73E-05 6.54E-04 3.27E-05 Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 QQ COLORADO ' AV 5 1 V Xaalel6 Fsa4ar..,.on� • • Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. jZCCP Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Supervisor Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 6 I 'COLORADO A7>dmm�NP We Condensate Storage Tank(s) APEN - Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loadings, 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: f C G2t AIRS ID Number: t2 / Fc p/ bd7/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: Beebe 3-34 Pad Site Location: NENW Sec. 34 T6N R66W Mailing Address: (Include Zip code) 5400 W. 11th Street, Suite C Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brad Rogers Phone Number: (970) 475-5242 E -Mail Address2: brogers@srcenergy.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 375498 1[AV COLORADO a v,.ohc Megol S Envun+men, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit 0 GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment ❑ Change company name O Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) - OR • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Storage of condensate from production wells For new or reconstructed sources, the projected start-up date is: 11/28/2017 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 0 Exploration a Production (E&P) site 52 weeks/year 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ■ No Are Flash Emissions anticipated from these storage tanks? SI Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? GI Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.0062 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ri ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 2I ATCOLORADO • �o Permit Number: AIRS ID Number: / / ❑ Upward ❑ Horizontal [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl/year) Condensate Throughput: 1,029,957 1,235,963 From what year is the actual annual amount? Average API gravity of sales oil: 48.9 degrees Tank design: ❑✓ Fixed roof ❑ Internal floating roof 2017-18 RVP of sales oil: 10.2 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) TNK 1-8 8 3200 10/2017 11/2017 Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123-44719 Beebe 11N -26A -M o 05 - 123-44720 Beebe 14N -26B -M NI 05 - 123-44721 Beebe 36N -26B -M ri 05 - 123-44722 Beebe 25N -26B -M o 05 - 123-44723 Beebe 11C -26-M ig 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.44917 /-104.76360 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular O Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 AV at= Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 274.80 MMBtu/hr (4) IES - 96" Type: (4) Enclosed Combustors Make/Model: Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 1076 F Waste Gas Heat Content: 2537 Btu/scf Constant Pilot Light: p Yes O No Pilot Burner Rating: 0.051 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 27 psig Describe the separation process between the well and the storage tanks: (12) Horizontal Worthington 3 -phase separators, (5) 2 -phase vertical knockout separators, and (1) gas buster Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 COLORADO 4 I 7;,t, Permit Number: AIRS ID Number: [Leave blank unless APCD has aiready assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 98% NOx CO HAPs ECD 98% Other: From what year is the following reported actual annual emissions data? 2017-18 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 3.277 ✓ Ibs/bbl ProMax 1,687.77 ./ 33.76 ✓ 2,025.35 v 40.51 v NOx 0.068 _ Ib/MMBtu AP -42 N/A 3.09 _ N/A 3.71 CO 0.310 lb/MMBtu AP -42 N/A 14.08 N/A 16.89 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor6 Actual Annual Emissions Chemical Name Abstract Service CAS (CAS) Uncontrolled Units Source (AP -42, Uncontrolled Emissions Controlled Emissions7 Number Basis Mfg. etc) ) (Pounds/year) (Pounds/year) Benzene 71432 7.30E-03 •/Ibs/bbl ProMax 7,518.69 ,/ 150.37 Toluene 108883 7.92E-03 ✓Ibs/bbl ProMax 8,157.26 f 163.15 v Ethylbenzene 100414 3.78E-04 Ibs/bbl ProMax 389.32 ,r 7.79 Xylene 1330207 4.28E-03 J Ibs/bbl ProMax 4,408.22 " 88.16 n -Hexane 110543 5.89E-02 ,/Ibs/bbl ProMax 60,701.46 `/ 1,214.03 2,2,4- Trimethylpentane 540841 2.28E-04 fibs/bbl ProMax 234.83 ✓ 4.70 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017 COLORADO 5j AV b�T,'" h Envsronment Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit q and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 717 Signare-vf't_egally Authorized Person (not a vendor or consultant) Brad Rogers 2,21 Zo1CP Dat Health and Environmental Supervisor Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Small Business Assistance Program Environment (303) 692-3175 or (303) 692-3148 Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 COLORADO 6 I Lia.7 H�r��tiiMe.eti tt Hello