HomeMy WebLinkAbout20192920.tiffa
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COLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
July 9, 2019
Dear Sir or Madam:
RECEIVED
JUL 1 2 2019
WELD COUNTY
COMMISSIONERS
On July 11, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Verdad Resources LLC - Homestead 01N -66W-34. 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
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
Pt(pl is Rvie.w
Cricit9G/I9 O9/19
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2019-2920
a
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CDPHE
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Verdad Resources LLC - Homestead 01 N -66W-34 - Weld County
Notice Period Begins: July 11, 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: Verdad Resources LLC
Facility: Homestead 01 N -66W-34
Well Production Facility
NWSE SEC 34 Ti N R66W
Weld County
The proposed project or activity is as follows: Condensate tank, truck loadout, and separation equipment
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 18WE1237 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.Qov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department otPubi�
Health & Environment
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Timothy Thar
390523
11/20/2018
2/4/2019
Section 01- Facility Information
Fe
Company Name: Verdad Resources LLC
County AIRS ID: 123
Quadrant
Section
Township
Range
NWSE
14
_ `;
--
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
A�£.-
v .c ..
Homestead 01N -66W-34
NWSE quadrant of Section 34, Township 1N, Range 66W
Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant?
Yee
❑ Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Particulate Matter (PM) El
Ozone (NOx & VOC)
AIRs Point if
Emissions Source Type
Equipment Name
Emissions
Control?
Permit If
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Condensate Tank
TIf01-16
18WE1237
Permit Initial
Issuance
Produced Water Tank
PWOI-04
1SWE1238
:.
Permit Initial
Issuance
s_iquid Loading
Permit Initial
Issuance
Separator Venting
HT -VENT 01
18WE1240
Permit Initial
Issuance
Separator Venting
VRT-VENTO1
18WE1241.
Permit Initial
Issuance
Section 03 - Description of Project
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Greater than 25 tons per year in Non -Attainment Area
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.
No
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)
Is this stationary source a major source?
SO2 NOx CO VOC
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑
PM2.5 PM10 TSP HAPs
❑ ❑
D 000
Colorado Air Permitting Project
If yes, explain what programs and which pollutants heri5O2 NOx CO VOC PM2 5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) 0 0 0 CI 0 0
Title V Operating Permits (OP) 0 0 ❑ 21 0 000
Non Attainment New Source Review (NANSR) 0 0
l
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
Facility AIRs ID:
123
County
A013 001
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
16x538bbl Condensate Storage tank
Emission Control Device ECD
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
1,1u5,.000 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
1,16-8,000 Barrels (bbl) per year
Requested Permit Limit Throughput = 1,401,600 Barrels (bbl) per year
Requested Monthly Throughput =
119040 Barrels (bbl) per month
Potential to Emit (PTE) Condensate
Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of
liquids produced =
1,401,600 Barrels (bbl) per year
9.63
Btu/scf
scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
29,161 MMBTU per year
34,993 MMBTU per year
34,993 MMBTU per year
Emission Factors
Condensate Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Condensate
Throughput)
(Condensate
Throughput)
VOC
0.77
0.04
Benzene
0.001
0.000
Toluene
0.001
0.000
Ethylbenzene
0.000
Xylene
0.000
0.000
n -Hexane
0.016
0.001
224 TMP
0.000
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM 10
0.0000
AP42 chapter 135:1*dtlaI iar0 iNQx}
r 13,5 Industrial Elates (COI
PM2.5
0.0000
N O x
0.0680
0.0017
CO
0.3100
0.0077
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
542.2
451.8
22.6
542.2
27.1
4605
PM10
0.0
0.0
0.0
0.0
0.0
0
PM2.5
0.0
0.0
0.0
0.0
0.0
0
NOx
1.2
1.0
1.0
1.2
1.2
202
CO
5.4
4.5
4.5
5.4
5.4
921
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
1682
1402
70
1682
84
Toluene
1247
1040
52
1247
62
Ethylbenzene
0
0
0
0
0
Xylene
364
304
15
364
18
n -Hexane
22426
18688
934
22426
1121
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
3of14
K:\PA\2018\18W E 1237 18WE1239 12 39 18WE1240 1240 18WE1241.CP1.xlsm 1241. C P1.xlsm
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. Ye;.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device? No
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
001
Process it
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.04 0 lb/1,000 gallons condensate throughput
VOC 18.4 95 lb/1,000 gallons condensate throughput
CO 0.18 0 lb/1,000 gallons condensate throughput
Benzene 0.03 95 lb/1,000 gallons condensate throughput
Toluene 0.02 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.01 95 lb/1,000 gallons condensate throughput
n -Hexane 0.38 95 lb/1,000 gallons condensate throughput
224 TMP 0.00 95 lb/1,000 gallons condensate throughput
4 of 14 K:\PA\2018\18WE1237 18WE1239 18WE1240 18WE1241.CP1.xlsm
Hydrocarbon Loadout Emissions Inventory
003 Liquid Loading
Facility AIRs ID:
County
A013
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Hydrocarbon Truck Loadout
Requested Overall VOC & HAP Control Efficiency %:
N
eget
100.0
95
95.00
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions- Hydrocarbon Loadout
Actual Volume Loaded =
1,168,000 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
1,168,000 Barrels (bbl) per year
Requested Permit Limit Throughput = 1,401,603 Barrels (bbl) per year
Requested Monthly Throughput =
119040 Barrels (bbl) per month
Potential to Emit (PTE) Volume Loaded =
1,401,600 Barrels (bbl) per year
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 =
2592.6 Btu/scf
1928688 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?
Does the hydrocarbon liquid loading operation utilize submerged fill?
4,167 MMBTU per year
5,000 MMBTU per year
5,000 MMBTU per year
The state default emissions factors may be used to estimate emissions.
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Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
2.36E-01
1.18E-02
! 4iN135dt . £.e,osi,-) t:. >w / , ,
Benzene
4.10E-04
2.05E-05
-_.z"ns; to toatk u State I.,Y.
Toluene
0.00E+00
0.00E+00
•.st:,.'t.. ) oldt)ut St 4r :r_
Ethylbenzene
0.00E+00
0.00E+00
Xylene
0.00E+00
0.00E+00
n -Hexane
3.60E-03
1.80E-04
224 TMP
0.00E+00
0.00E+00
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
P M 10
0.00E+00
`_:. - .. .
PM2.5
0.00E+00
SOx
0.00E+00
NOx
2.43E-04
CO
1.11E-03
S of 14 K:\PA\2018\18WE1237 18WE1239 18WE1240 18WE1241.CP1.xlsm
Hydrocarbon Loadout Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.17
0.14
0.14
0.17
0.17
29
165.39
137.82
6.89
165.39
8.27
1405
0.78
0.65
0.65
0.78
0.78
132
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
575
479
24
575
29
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5046
4205
210
5046
252
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Not enough information
RACT - Regulation 3, Part B, Section III.D.2.a
The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT.
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device? l'1
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
003
Process #
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Pollutant
PM10
PM2.5
SOx
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.00
0.00
0.00
0.01
5.6
0.03
0.01
0.00
0.00
0.00
0.09
0.00
Control %
0
0
0
0
95
0
95
95
95
95
95
95
Units
lb/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
Ib/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
lb/1,000 gallons transferred
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Separator Venting Emissions Inventory
004 Separator Venting
Facility AIRs ID:
1 3
County
A013
Plant
004
Point
Section 02 - Equipment Description Details
Separator venting during VRU downtime
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
23,360.0 Barrels (bbl) per year
Requested Permit Limit Throughput =
28,032.0 Barrels (bbl) per year
Requested Monthly Throughput =
2381
MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
28,032 Barrels (bbl) per year
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04- Emissions Factors & Methodologies
Description
MW
36.2978
Weight %
Helium
0.00
CO2
1.90
N2
0.15
methane
13.21
ethane
13.94
propane
30.29
isobutane
5.34
n -butane
15.01
isopentane
3.75
n -pentane
4.44
cyclopentane
0.35
n -Hexane
1.25
cyclohexane
0,36
Other hexanes
117
heptanes
0.94
methylcyclohexane
0.41
224-TMP
0.00
Benzene
0.17
Toluene
0.16
Ethylbenzene
0.02
Xylenes
0.07
C8+ Heavies
1.03
Total
99.97
VOC Wt %
65.76
lb/lb-rnol
Displacement Equation
Ex=Q*MW*Xx/C
1.5821
0.1971
30.18
23.08
25.17
3.37
9.46
1.91
2.26
0.18
0.53
0.16
0.92
0.34
0.00
0.08
0.08
0.06
0.01
0.02
0.30
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Liquid Throughput)
-
(Liquid Throughput)
VOC
5.0385
0.2519
Benzene
0.0133
0.0007
Toluene
0.0119
0.0006
Ethylbenzene
0.0012
0.0001
Xylene
0.0055
0.0003
n -Hexane
0.0959
0.0043
224 TMP
0.0001
0.0000
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/bbl
(Waste Heat
Combusted)
(Gas Throughput)
PM 10
0.000
PM2.5
0.000
SOx
0.000
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Separator Venting Emissions Inventory
NOx
0.0630
0.011
CO
0.3100
0.052
,
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Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
SOx
0.00
0.00
0.00
0.00
0.00
0
NOx
0.16
0.13
0.13
0.16
0.16
27
VOC
70.62
58.85
2.94
70.62
3.53
600
CO
0.72
0.60
0.60
0.72
0.72
123
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
374
311
16
374
19
Toluene
333
278
14
333
17
Ethylbenzene
34
28
1
34
2
Xylene
154
129
6
154
8
n -Hexane
2689
2241
112
2689
134
224 TM P
2
2
0
2
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
• •
You nave indicated above the monitorea process parameter is uquia r nrougput. I ne toiiowing question aoes not require an answer.
Using Liquid Throughput to Monitor Compliance
Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the
equipment covered under this AIRs ID) and process simulation to estimate emissions?
This sample should have been collected within one year of the application received date. However, 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 collect a site -specific liquid sample and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
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Separator Venting Emissions Inventory
Section 08 -Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
004
Process #
01
SCC Code
3-10-001-29 Oil & Gas Production: Gas/liquid separation
Uncontrolled
Emissions
Pollutant Factor
PM10 0.00
PM2.5 0.00
SOx 0.00
NOx 11.32
VOC 5038.49
CO 51.61
Benzene 13.33
Toluene 11.83
Ethylbenzene 1.20
Xylene 5.50
n -Hexane 95.92
224 TMP 0.08
Control %
0
0
0
0
95
0
95
95
95
95
95
95
Units
Ib/1000bbl
lb/1000bbl
lb/1000bbl
Ib/1000bbl
Ib/1000bbl
Ib/1000bbl
lb/1000bbl
Ib/1000bbl
Ib/1000bbl
Ib/1000bbl
lb/1000bbl
Ib/1000bbl
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Separator Venting Emissions Inventory
005 Separator Venting
Facility AIRs ID:
123
County
A013
Plant
005
Point
Section 02 - Equipment Description Details
VRT venting during VRU downtime
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
23,360.0 Barrels (bbl) per year
Requested Permit Limit Throughput =
28,032.0 Barrels (bbl) per year
Requested Monthly Throughput =
2331 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
28,032 Barrels (bbl) per year
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04- Emissions Factors & Methodologies
2386
21.4
Btu/scf
scf/bbl
Description
MW
Weight %
Helium
0.00
CO2
1.55
N2
0.04
methane
4.65
ethane
21.09
propane
34.27
isobutane
21.29
n -butane
3.82
isopentane
3.29
n -pentane
3.80
cyclopentane
0.29
n -Hexane
1.62
cyclohexane
0.31
Other hexanes
2.42
heptanes
0.61
methylcyclohexane
0.30
224-TMP
0.01
Benzene
0.22
Toluene
0.09
Ethylbenzene
0.01
Xylenes
0.04
C8+ Heavies
0.32
Total
VOC Wt %
100.00
72.67
Ib/Ib-mol
Displacement Equation
Ex=Q*MW*Xx/C
Emission Factors
Separator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(Ib/bbl) (lb/bbl)
(Liquid Throughput)
(Liquid Throughput)
VOC
1.7064
0.0353
Benzene
0.0050
0.0003
Toluene
0.0022
0.0001
Ethylbenzene
0.0002
0.0000
Xylene
0.0008
0.0000
n -Hexane
0.0380
0.0019
224 TMP
0.0002
0.0000
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/bbl
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.000
PM2.5
0.000
5Ox
0.000
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Separator Venting Emissions Inventory
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Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
0.00
0.00
0.00
0.00
0.00
0
PM2.5
0.00
0.00
0.00
0.00
0.00
0
SOx
0.00
0.00
0.00
0.00
0.00
0
NOx
0.05
0.04
0.04
0.05
0.05
8
VOC
23.92
19.93
1.00
23.92
1.20
203
CO
0.22
0.18
0.18
0.22
0.22
38
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
142
118
E
142
7
Toluene
62
52
3
62
3
Ethylbenzene
6
5
0
6
0
Xylene
24
20
1
24
1
n -Hexane
1065
888
44
1065
53
224 TM P
5
4
0
5
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
You have indicated above the monitored process parameter is Liquid Througput. The following question does not require an answer.
Using Liquid Throughput to Monitor Compliance
Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the
equipment covered under this AIRs ID) and process simulation to estimate emissions?
No
This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought online), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
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Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
005
Process # SCC Code
01 3-10-001-29 Oil & Gas Production: Gas/liquid separation
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 Ib/1000bbl
PM2.5 0.00 0 Ib/1000bbl
SOx 0.00 0 Ib/1000bbl
NOx 3.47 0 Ib/1000bbl
VOC 1706.38 95 Ib/1000bbl
CO 15.83 0 Ib/1000bbl
Benzene 5.05 95 Ib/1000bbl
Toluene 2.21 95 Ib/1000bbl
Ethylbenzene 0.21 95 Ib/ 1000b bl
Xylene 0.85 95 Ib/1000bbl
n -Hexane 37.99 95 Ib/1000bbl
224 TMP 0.19 95 Ib/1000bbl
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COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE1237
7
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
Verdad Resources LLC
Homestead 01 N -66W-34
123/A013
NWSE SEC 34 T1 N R66W
Weld County
Well Production Facility
Equipment or activity, subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Condensate
Storage
Tanks
001
Sixteen (16) 538 barrel fixed roof storage
vessels used to store condensate
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit 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
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
I. F.4. )
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the, permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This ''construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
Condensate
Storage Tanks
001
---
1.3
27.2
5.5
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
During the first twelve (12) months of operation, compliance with both the monthly and annual
emission limitations is required. After the first twelve (12) months of operation, compliance
with only the annual limitation is required.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The emission points in the table below 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
Condensate
Storage
Tanks
001
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Condensate
Storage
Tanks
001
Condensate
Throughput
1,401,600 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. 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)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. 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
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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)
13. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the following schedule:
All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d.'and maintain records of the inspections for a period of two years, made available
to the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. 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
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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)
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:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level, reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S.` requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
Permit History
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Pub19c Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Pubic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https:/ /www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Benzene
71432
1441
72
001
Toluene
108883
1038
52
Xylenes
1330207
301
15
n -Hexane
110543
18240
912
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.068 (lb/MMbtu)
AP -42
CO
0.310 (lb/MMbtu)
AP -42
VOC
7.70E-01
Source
71432
Benzene
1.20E-03
Source
108883
Toluene
8.90E-04
Source
1330207
Xylene
2.6E-04
Source
110543
n -Hexane
1.60E-02
Source
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, nHex
NANSR
Synthetic Minor Source of: VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE1239 Issuance: 1
Verdad Resources LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Homestead 01 N -66W-34
123/A013
NWSE SEC 34 T1N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point.
Equipment Description
Emissions Control
Description
Hydrocarbon
Truck
Loadout
003
Truck loadout of condensate by
submerged fill using vapor balance
system
Enclosed Flare
This permit is granted subject to all roles 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 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
I. F.4. )
4. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION. LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation
Number 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
PM2.5
NO,
VOC
CO
Emission
Type
Hydrocarbon
Truck Loadout
003
8.3
1.2
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
Hydrocarbon
Truck
Loadout
003
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Reference: Regulation Number 3 Part
B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Hydrocarbon
Truck
Loadout
003
Condensate Loaded
,600 barrels
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation
Number 3, Part B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases 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.)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
12. 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 and emissions shall be controlled by a flare. (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.
13. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to
the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2):
a. The owner or operator shall inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loading and unloading. The inspections shall occur at least monthly.
Each inspection shall be documented in a log available to the Division on request.
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.
Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers shall be weighted and properly seated.
Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs shall be set to release at a pressure that will ensure flashing, working
and breathing losses are not vented through the PRD under normal operating conditions.
Document annual inspections of thief hatch seals and PRD with an indication of status,
a description of any problems found, and their resolution.
14. For this controlled loading operation, the owner or operator shall follow loading procedures
that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference:
Regulation 3, Part B, III.D.2):
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless
the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
OPERATING Et MAINTENANCE REQUIREMENTS
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
15. Upon startup of these points, the owner or operator shall follow the most recent operating
and maintenance (OEtM) 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 OEtM plan are subject to Division approval prior to implementation. (Reference:
Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significantincrease in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or 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.
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.
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit isissued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct ofthe activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall b deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air. Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
Page 6 of 9
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
Timothy Sharp
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
575
29
n -Hexane
110543
5046
252
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors lb/bbl
Source
N0x
0.068
(lb/MMbtu)
AP -42
CO
0.310
(lb/MMbtu)
V0C
2.36E-01
CDPHE
Benzene
71432
4.10E-04
CDPHE
n -Hexane
110543
3.60E-03
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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: VOC, nHex
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http: / /ecf r. gpoaccess. 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
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE1240
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
Verdad Resources LLC
Homestead 01 N -66W-34
123/A013
NWSE SEC 34 T1N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
HT-VENT01
004
Low Pressure Separator Venting During VRU
Downtime
Enclosed Combustor
\This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.Rov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4. )
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
HT-VENT01
004
---
---
3.4
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Pubic Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
HT-VENT01
004
Emissions from the Separator are routed to
an Enclosed Flare during Vapor Recovery
Unit (VRU) downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
HT-VENT01
004
Liquids Throughput
28,032 bbl/yr
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
11. The owner or operator must use monthly VRU downtime records, monthly condensate/crude
oil throughput records, calculation methods detailed in the DEW Plan, and the emission
factors established in the Notes to Permit Holder to demonstrate compliance with the process
and emissions limits specified in this permit.
Page 3 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
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it must
be enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the following schedule:
•
All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
All combustion devices installed before May 1, 2014, must be equipped with an
operational auto igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation
from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must
either be routed to a gas gathering line or controlled from the date of first production by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING Et MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health ErEnvironment
Dedicated to protecting and improving the health and environment of the people of Colorado
17. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence
of visible emissions. "Visible Emissions" means observations of smoke for any period or
periods of duration greater than or equal to one minute in any fifteen minute period during
normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17)
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, ',a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.'
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Pubtic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
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.
By:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
HT-VENT01
004
Benzene
71432
340
17
Toluene
108883
280
14
Ethylbenzene
100414
32
1.6
Xylenes
1330207
106
5.3
n -Hexane
110543
3740
187
2,2,4-
Trimethylpentane
540841
22
1.1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
(lb/bbl)
Source
NOx
0.068
(lb/MMbtu)
AP -42
CO
0.310
(lb/MMbtu)
AP -42
VOC
4.81E00
Source
(Promax/HYSYS)
71432
Benzene
1.20E-02
Source
(Promax/HYSYS)
108883
Toluene
1.00E-02
Source
(Promax/HYSYS)
110543
n -Hexane
1.30E-01
Source
(Promax/HYSYS)
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, nHex
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
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
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
COLORADO
Air Pollution Control Division
Department of Pubtic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 18WE1241 Issuance: 1
Date issued:
Issued to: Verdad Resources LLC
Facility Name: Homestead 01N -66W-34
Plant AIRS ID: 123/A013
Physical Location: NWSE SEC 34 T1N R66W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID '
AIRS
Point
Equipment Description
Emissions Control
Description
VRT-VENTO1
005
VRT Venting During VRU Downtime
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Pubic Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
VRT-VENT01
005
-
---
1.3
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
Page 2 of 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
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
VRT-VENT01
005
Emissions from the Separator are routed to
an Enclosed Flare during Vapor Recovery
Unit (VRU) downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request, (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT-VENTO1
005
Liquids Throughput
28,032 bbl/yr
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
11. The owner or operator must use monthly VRU downtime records, monthly condensate/crude
oil throughput records, calculation methods detailed in the 0&M Plan, and the emission
factors established in the Notes to Permit Holder to demonstrate compliance with the process
and emissions limits specified in this permit.
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Pubic Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it must
be enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation
from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must
either be routed to a gas gathering line or controlled from the date of first production by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING & MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (0&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the 0am 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
Page 4 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
17. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence
of visible emissions. "Visible Emissions" means observations of smoke for any period or
periods of duration greater than or equal to one minute in any fifteen minute period during
normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17)
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part, A,
II.C.)
Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
Page 6 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
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.
Bv:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT-VENT01
005
Benzene
71432
100
5
Toluene
108883
74
4
Ethylbenzene
100414
7
0
Xylenes
1330207
24
1
n -Hexane
110543
1080
54
2,2,4-
Trimethylpentane
540841
6
0
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Pubiic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
(lb/bbl)
Source
NOx
0.068
(lb/MMbtu)
AP -42
CO
0.310
(lb/MMbtu)
AP -42
VOC
1.75E00
Source
(Promax/HYSYS)
110543
n -Hexane
3.90E-02
Source
(Promax/HYSYS)
Note:
The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, nHex
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
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
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 10 of 10 ,
'Cbc
Condensate Storage Ta3tk(.„jAP
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
18WE1237
AIRS ID Number:
(u /A,(3/60(
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
REcEivED
WV 10i 8
APCD
5tfAl
S @ur
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Homestead 01 N -66W-34
Site Location: NWSE Sec 34 T1 N R66W
40.00719/-104.75928
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
E -Mail Address2: bganong@verdadoil.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
4OLORA0O
Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017
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
O Request coverage under traditional construction permit
O Request coverage under a General Permit
El GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
El Change in equipment ❑ Change company name
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: Initial Permit Application - Site Specific Emission Factors
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:
Condensate Storage Tanks
For new or reconstructed sources, the projected start-up date is: 8/22/18
Normal Hours of Source Operation: 24
hours/day 7 days/week
Storage tank(s) located at: 0 Exploration & Production (E&P) site
52
weeks/year
❑ Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
0
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
•
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:
0.0017
m3/titer
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)El
805 series rules? If so, submit Form APCD-105.
Yes
No
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualGI
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
�® COLORADO
2 I Asan,amKmaamn
K ttAb Enclvanmvrt
Permit Number: AIRS ID Number: /
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limit4
(bbl/year)
Condensate Throughput:
1,168,000
From what year is the actual annual amount? projected
Average API gravity of sales oil: ~42 degrees
❑ Internal floating roof
Tank design: E Fixed roof
1,401,600
RVP of sales oil: ~9.4
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)
TK01-16
16 x 538 bbl
8608
07/2018
08/2018
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05
- 123
- 44638
Homestead 15 (05-123-44638)
❑✓
05
- 123
- 44636
Homestead 16 (05-123-44636)
17
05
- 123
- 44643
Homestead 17 (05-123-44643)
l7
05
- 123
- 44627
Homestead 18 (05-123-44627)
o
05
- 123
- 44631
Homestead 19 (05-123-44631)
GI
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EEO 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)
40.00719/-104.75928
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
EC01
32
1000
50
0.017
Indicate the direction of the stack outlet: (check one)
2 Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
0 Square/rectangle
❑ Other (describe):
Interior stack diameter (inches):
0 Upward with obstructing raincap
96
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
COLORADO
3 I ®' beps,tmeAtot=
NnL]�b Envftxrt�<n!
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: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model: GCO Beast 3200
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A
Waste Gas Heat Content:
Constant Pilot Light: LI Yes D No Pilot Burner Rating:
2592.6
0.040
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (EEtP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -7 psig
Describe the separation process between the well and the storage tanks: Produced fluids from the
wells are directed to four 3 -phase horizontal heated separators. From the separators, oil is
directed to four 3 -phase vertical heater treaters for further separation and pressure reduction.
From the heater treaters, oil is directed to two VRTs.
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit 1/ and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
(
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
V0C
Enclosed Combustor
95
NOx
CO
HAPs
Enclosed Combustor
95
Other:
2018/proected
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
0.77
lb/bbl
Site Specific
451.88
22.59
542.26
27.11
NOx
0.0017
lb/bbl
Calculated
1.01
1.01
1.21
1.21
CO
0.0078
lb/bbl
Calculated
4.53
4.53
5.44
5.44
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions
(Pounds/year)
Benzene
71432
0.0012
lb/bbl
Site Specific
1,440.69
72.03
Toluene
108883
0.00089
lb/bbl
Site Specific
1,038.44
51.92
Ethylbenzene
100414
Xylene
1330207
0.00026
lb/bbl
Site Specific
301.22
15.06
n -Hexane
110543
0.016
lb/bbl
Site Specific
18,240.42
912.02
2,2,4-
Trimethylpentane
540841
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
5 I A,COLORADO
V =IT.' n"m r,
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit 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.
WI° //87
Signature of Legally Authorid Person (not a vendor or consultant) Date
Michael Cugnetti EH&S Manager
Name (print) Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
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 For more information or assistance call:
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
COLORADO
6 I Ay kS Ic
Neullb Ewuanment
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.Rov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
I'►IE 1239
AIRS ID Number:
1Z3 /A013/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: TL01
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Homestead 01 N -66W-34
Site Location: NWSE Sec 34 T1 N R66W
40.00719/-104.75928
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
LUse the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on
all documents issued by the APCD. Any changes will require additional paperwork.
2
Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017
390516
COLORADO
A
1 I - ' Wray aye F�.n�vmom 1
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
El NEW permit OR newly -reported emission source
2 Request coverage under construction permit
0 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
0 Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Initial Application
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Hydrocarbon Truck Loadout
For existing sources, operation began on: / /
For new or reconstructed sources, the projected
start-up date is:
08/ 22 /2018
Will this equipment be operated in any NAAQS nonattainment area?
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Does this source load gasoline into transport vehicles?
Is this source located at an oil and gas exploration and production site?
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Does this source splash fill less than 6750 BBL of condensate per year?
Does this source submerge fill less than 16308 BBL of condensate per year?
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
O Yes ❑ No
❑ Yes E No
❑ Yes ❑✓ No
r❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑✓ No
®• 'COLORADO
2 I 'G��mliY n.c—,Vem.11ot rnwc
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑ Crude Oil 0 Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume
Loaded4:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
1,168, 000
Bbl/yr
1,401,600
Bbl/yr
Actual Volume
Loaded:
This product is loaded from tanks at this facility into: trucks
(eg, "rail tank cars" or "tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature
of bulk liquid loading:
'F
True Vapor
Pressure
Asia @ 60 °F
Molecular weight of
displaced vapors
Lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Actual Volume
Loadeds: Bbl/yr Loaded:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Bbl/yr
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
VIRT COLORADO
=Fn°1r°nmoni
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)
40.00719/-104.75928
ack i) Tlo
Dierascharge }eight
Above Ground Level
(Feet)
Temp
Fbw M)
ACE
�1oc#i
Hsec
EC01
32
1000
50
0.017
Indicate the direction of the stack outlet: (check one)
❑ Downward
O Other (describe):
❑✓ Upward
D Horizontal
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
96
Section 6 - Control Device Information
O Loading occurs using a vapor balance system:
Requested Control Efficiency 95
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPS
Rating:
Type: Enclosed Combustor Make/Model: GCO Beast 3200
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
MMBtu/hr
95
98
Minimum Temperature: n/a Waste Gas Heat Content 2592.6 Btu/scf
Constant Pilot Light: El Yes O No Pilot burner Rating
-0.040
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
p COLORADO
4 I ,m,.6 Z=7=,
RwItH 6F�v3fne�oenf
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
Sax
NOx
CO
VOC
vapor balance
95
HAPs
vapor balance
95
Other:
Using State Emission Factors (Required for GP07) VOC
❑✓ Condensate 0.236 Lbs/BBL
O 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? 2018
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
RequestedAnnual Permit`
Emission Li s
mitts
Uncontrolled
(Tons/year)
Controlled5
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
Sax
NOx
0.00034
lb/bbl
Calculated
0.20
0.20
0.24
0.24
VOC
0.236
lb/bbl
CDPHE
137.82
6.89
165.39
8.27
CO
0.0016
lb/bbl
Calculated
0.92
0.92
1.11
1.11
Benzene
0.00041
lb/bbl
CDPHE
0.24
0.012
0.29
0.014
Toluene
Ethylbenzene
Xylenes
n -Hexane
0.0036
lb/bbl
CDPHE
2.10
0.11
2.52
0.13
2,2,4-
Trimethylpentane
Other:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
'AV
COLORADO
Department of Puttic
Harman Rh&x tr t
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.
11
Signature of Legally EF brized Person (not a vendor or consultant) Date
Michael Cugnetti EH&S Manager
Name (print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General
Permit registration fee of $250 as applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
COLORADO
6j Y
° xciunar vironmom
546/2011
RECEIVED
NOV 202010
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
Ml 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 Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, welt head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. 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.aov/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.
APCD
Stationary
Sources
Permit Number: \31') L1 h AIRS ID Number: 1 23 /A0131004 -
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: HT-VENT01
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Homestead 01 N -66W-34
Site Location: NWSE Sec 34 T1 N R66W
40.00719/-104.75928
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
'Please 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-211 - Natural Gas Venting APEN - Rev 03/2017
390520
•COLOR ADO
1 •. Enutt,t
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
l NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name El Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership3 El Other (describe below)
-OR-
❑ APEN submittal for update only (Please note 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 & Notes: Initial Application
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
compressor downtime.
Heater Treater venting during VRU
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
08 / 22 / 2018
El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation:
variable hours/day variable days/week variable weeks/year
Will this equipment be operated in any NAAQS nonattairvnent
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
❑✓ Yes ❑ No
❑ Yes El No
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
2 I ota,�;�
1SCiNh6Envffeeaneni
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
ID Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
# of Events/year: Volume per event: MMscf/event
0 Other
Description: During VRU compressor downtime, gas from the heater treaters is directed to the enclosed combustor.
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? El Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
0 No
Maximum Vent
Rate:
10672.7
SCF/hr
Vent Gas
Heating Value:
2081
BTU/SCF
Requested:
2.24
MMSCF/year
Actual:
1.87
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
42.58
VOC (Weight %)
62.76
Benzene (mole %)
0.0719
Benzene (Weight %)
0.227
Toluene (mole %)
0.0524
Toluene (Weight %)
0.113
Ethylbenzene (mote %)
0.0050
Ethylbenzene (Weight %)
0.013
Xylene (mole %)
0.0170
Xylene (Weight %)
0.050
n -Hexane (mole %)
0.7349
n -Hexane (Weight %)
1.747
2,2,4-Trimethylpentane
(mole %)(Weight
0.0032
2,2,4-Trimethylpentane
%)
0 0090
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
CO�,LORADO
3 I AV nv' =.
y�w,.�an,
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit Al and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.00719/-104.75928
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp,
(*F)
Flow Rate
(ACFM)
Velocity
(ft!ser)
EC01
32
1000
50
0.017
Indicate the direction of the stack outlet: (check one)
2 Upward
0 Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
0 Other (describe):
0 Upward with obstructing raincap
96
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
%
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating:
Type: Enclosed Combustor Make/Model: GCO Beast 3200
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
95
98
N/A Waste Gas Heat Content 2592.6 Btu/scf
Constant Pilot Light: z Yes ❑ No Pilot burner Rating 0.040 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
4 A, COLORADO
°"", bt„`yt Win, t[u:iT.6F
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, please 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.
VOC
Enclosed Combustor
95
CO
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
N/A
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
Emission Limit(05
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOS
NOX
0.014
Ibs/bbl
Calculated
0.16
0.16
VOC
5.76
lbs/bbl
Site specific
67.28
3.36
CO
0.062
lbs/bbl
Calculated
0.72
0.72
Benzene
0.021
lbs/bbl
Site specific
0.24
0.012
Toluene
0.010
Ibs/bbl
Site specific
0.12
0.0061
Ethylbenzene
0.0012
lbs/bbl
Site specific
0.014
0.00069
Xylenes
0.0046
lbs/bbl
Site specific
0.053
0.0027
n -Hexane
0.16
lbs/bbl
Site specific
1.87
0.094
2,2,4-
Trimethylpentane
0.00082
lbs/bbl
Site specific
0.010
0.00048
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
//� -COLORADO
5 I Hatt, 7% Hatt,b `nwamnen+
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally orized Person (not a vendor or consultant)
Michael Cugnetti
Name (please print)
///zpg,
Date
EH&S Manager
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)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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
o COLORADO
6 I =rte ¢.��
flMlthbtmfronnl,nt
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. 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:
vw..cotorado. gov/cdplie/aped.
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: 18WE1240
AIRS ID Number: 123 /A013/ 004
[Le ve btarik urie-ss APr_D li;e. already asvi iieed ;, permit = and AIRS IDl
Company equipment Identification: HT-VENT01
IPiovide Facility Equipment ID tii iamtify 1 vw t ii; egan anie:i; i; [Pret nce:I xithin your vi iiuizat viii
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Homestead 01 N -66W-34
Site Location: NWSE Sec 34 T1 N R66W
40.00719/-104.75928
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
(Please 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.
Firm APCD-7.1 I Natural Gm .Ievtiii APEN Rev 0:;/2017 I_
vl 1,41
COLORADO
Permit Number: 18WE1240
AIRS ID Number: 123 /A013/ 004
[Leave blank unless APCD has :heady assigned a permit /j and AIRS !DI
Section 2- Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
El Change fuel or equipment ❑ Change company name ❑ Add point -to existing permit
El Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
- OR
• APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: APEN redline update to initial application
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
compressor downtime.
Heater Treater venting during VRU
For existing sources, operation began on: / /
For new or reconstructed sources, the projected
start-up date is:
08 / 22 / 2018
El Check this box if operating hours are 8,760 hours per year; if fewer; fill out the fields below:
Normal Hours of Source Operation: variable hours/day variable days/week variable weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APLp.211 Natural Gas Venting a\PFN Rev 03/2017
Q Yes
El Yes
• No
❑✓ No
COLORADO
2
Permit Number: 18WE1240
AIRS ID Number: 123 /A013/ 004
(I_^car blurt: untess APCD has already assigned a permit fi eat+d AIRS IDI
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/past
❑ Blowdown Events
# of Events/year: Volume per event: MMscf/event
❑✓ Other
Description: During VRU compressor downtime, gas from the heater treaters is directed to the enclosed combustor.
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? D Yes ❑✓ No
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
Maximum Vent
Rate:
SCF/hr
Vent Gas
Heating Value:.
BTU/SCF
Requested:
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
28,032
Bbl/yr
Actual:
23,360
Bbt/yr
4 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
Ito. 2.q 1-18
VOC (mole %)
42.58
V0C (Weight %)
62.80
Benzene (mole %)
0.0719
Benzene (Weight %)
0.155
Toluene (mole %)
0.0524
Toluene (Weight %)
0.133
Ethylbenzene (mole %)
0.0050
Ethylbenzene (Weight %)
0.015
Xylene (mole %)
0.0170
Xylene (Weight %)
0.050
n -Hexane (mole %)
0.7349
n -Hexane (Weight %)
1.745
2,2,4-Trimethylpentane
(mole %)
0 0032
2,2,4-Trimethylpentane
(Weight %)
0.0102
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX it n -Hexane, temperature, and
pressure)
❑
Form APCD•21 I hNraturat Gas venting APCN - Rev 03/2017
31
COLORADO
El Upward
❑ Horizontal
Permit Number: 18WE1240
AIRS ID Number: 123 /A013/ 004
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.00719/-104.75928
Operator
Stack ID No.
Discharge Height
Above Ground Level
Temp.
(•F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
(Feet)
EC01
32
1000
50
0.017
Indicate the direction of the stack outlet: (check one)
❑ Downward
O Other (describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches):
O Other (describe):
❑ Upward with obstructing raincap
96
Section 6 - Control Device Information
0 VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
Combustion
Leal
Device:
Pollutants Controlled: VOC/HAPs
Rating:
Type: Enclosed Combustor Make/Model: GCO Beast 3200
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
N/A
MMBtu/hr
95
98
Waste Gas Heat Content
2,081.23 Btu/scf
Constant Pilot Light: D Yes ElNo Pilot burner Rating -0.040 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0
r\l .. i 11 NAi!_rai Vent 1t'; 5' APE ; I Pc--‘; (P.:/2017
ACO�ORAQO
Permit Number: 18WE1240
AIRS ID Number:
123 /A013/ 004
[]_ :ve blank unless APC[1 has already assigned a permit aid AIRS IDI
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, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
-
SOX
NOX
VOC
Enclosed Combustor
95
CO
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
N/A
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
4 5
Emission Umit(s)
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tans/year)
Controlled
(Tons/year)
PM
50X
NOX
0.011
lbs/bbl
Calc/AP-42
0.16
0.16
VOC
4.81
lbs/bbl
Site specific
67.39
3.37
CO
0.052
Ibs/bbl
Calc/AP-42
0.72
0.72
Benzene
0.012
Ibs/bbl
Site specific
0.17
0.0083
Toluene
0.010
lbs/bbl
Site specific
0.14
0.0071
Ethylbenzene
0.0011
lbs/bbl
Site specific
0.016
0.00079
Xylenes
0.0038
lbs/bbl
Site specific
0.053
0.0027
n -Hexane
0.13
Ibs/bbl
Site specific
1.87
0.094
2,2,4-
Trimethylpentane
0.00078
Ibs/bbl
Site specific
0.011
0.00055
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form AFCD-211 -Natural ;as Venting APEN Rnv 03/2017
5 I :A►Y t6�es�r�o
Permit Number: 1 8WE1240
AIRS ID Number: 123 /A013/ 004
[Leave blank unless APCD has already assi ned e permit a and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Leg lily Person (not a vendor or consultant)
Michael Cugnetti
Date
EH&S Manager
Name (please print)
Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Farm ,,:KD 2 1 Natural Gas Venting APR] Rev 0312017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
COLORADO
N14Nt(
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Natural Gas Venting APEN - Form APCD-211 bow s�
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 Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. 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.ov/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:
$V J2q-) AIRS ID Number: 123 /40/3 /60S'
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: VRT-VENTO1
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Verdad Resources LLC
Homestead 01 N -66W-34
Site Location: NWSE Sec 34 T1 N R66W
40.00719/-104.75928
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
'Please 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-211 - Natural Gas Venting APEN - Rev 03/2017
COLORADO
39 vumm
Permit Number: AIRS ID Number:
(Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 2- Requested Action
❑ NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
9 Change fuel or equipment ❑ Change company name 9 Add point to existing permit
❑ Change permit limit 9 Transfer of ownership3 9 Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes: Initial Application
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
compressor downtime.
VRT venting during VRU
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
10 / 20 / 2018
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation:
variable hours/day variable days/week variable weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
❑✓ Yes
9 Yes
❑ No
❑r No
//(/j�yy�����j�SLV COL 0
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L≥V bF vao mu'n
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑r Gas/Liquid Separator
D Well Head Casing
❑ Pneumatic Pump
Make: Model:
Serial #:
Capacity: Gal/min
❑ Compressor Rod Packing
Make: Model: # of Pistons: Leak Rate: Scf/hr/pist
O Blowdown Events
# of Events/year: Volume per event: MMscf/event
E Other
Description: During VRU compressor downtime, gas from the VRTs is directed to the enclosed combustor.
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑r No
Maximum Vent
Rate:
2922.9
SCF/hr
Vent Gas
Heating Value:
2386
BTU/SCF
Requested:
0.61
MMSCF/year
Actual:
0.51
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
57.28
VOC (Weight %)
72.67
Benzene (mole %)
0.0783
Benzene (Weight %)
0.215
Toluene (mole %)
0.0498
Toluene (Weight %)
0.094
Ethylbenzene (mole %)
0.0042
Ethylbenzene (Weight %)
0.009
Xylene (mole %)
0.0139
Xylene (Weight %)
0.036
n -Hexane (mole %)
0.7800
n -Hexane (Weight %)
1.618
2,2,4-Trimethylpentane
(mole %)
0.0031
2,2,4-Trimethylpentane
(Weight %)
0.008
Additional Required Information:
O Attach a representative gas analysis (including BTEX lr n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
O
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
AV
COLORADO
3 I L3] Hw"'�,
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.00719/-104.75928
Operatpr
S�' No
tack ID
Discharge Height
Above Ground Level
(Feet)
hemp
( F) - �
flow Rate
(�CfM)
Velocity .
(ft/sec)
EC01
32
1000
50
0.017
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
0 Upward
O Horizontal
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
96
Section 6 - Control Device Information
O VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
O Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating:
Type: Enclosed Combustor Make/Model: GCO Beast 3200
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu / hr
95
98
N/A Waste Gas Heat Content
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating
2592.6
-0.040
Btu/scf
MMBtu / hr
O Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
� COLORADO
4 I i�L•i nolommt
Ye ahb F .vs�n+�meM
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? 0 Yes ❑ No
If yes, please 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.
VOC
Enclosed Combustor
95
CO
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
N/A
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
Emission Limit(s)
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NO.
0.0043
lbs/bbl
Calculated
0.50
0.50
VOC
2.09
lbs/bbl
Site specific
24.45
1.22
CO
0.019
lbs/bbl
Calculated
0.23
0.23
Benzene
0.0062
lbs/bbl
Site specific
0.072
0.0036
Toluene
0.0027
Ibs/bbl
Site specific
0.031
0.0016
Ethylbenzene
0.00027
lbs/bbl
Site specific
0.0031
0.00016
Xylenes
0.0010
Ibs/bbl
Site specific
0.012
0.00060
n -Hexane
0.047
lbs/bbl
Site specific
0.54
0.027
2,2,4-
Trimethylpentane
0.00022
Ibs/bbl
Site specific
0.0025
0.00013
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
5 I ACOLORADO
. tr,= ;, M,
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.
A/
Oc/if)
Signature of L'egahorized Person (not' a vendor or consultant) Date
Michael Cugnetti
EH&S Manager
Name (please print) Title
Check the appropriate box to request a copy of the:
❑� Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 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
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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
6 I AV'COLORADO
ulfl,
pet j
Natural Gas Venting APEN - Form APCD 11 1 ` ' 1
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 Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. 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/cdohe/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: 18WE1241
AIRS ID Number: 123 /A013/ 005
[Leave blank uniess APCD lies already assigned a pennii a and AIRS IDI
Company equipment Identification: VRT-VENT01
lP,ovide - r idly ciiuipmrn ID u; idrn.lfy 1 hrs e r;q:mer;t 1: referenced 'rnlhi'Oil r orc3aa,z1tioal
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Homestead 01 N -66W-34
Site Location: NWSE Sec 34 T1 N R66W
40.00719/-104.75928
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
Please 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 APCC 211 Natural Gas \`aniir1$; APrI.l - Rev 0'Si 2017
AYCOLORADO
1I:i1. Ervwwmm..1
Permit Number: 18WE1241
AIRS ID Number: 123 /A013/ 005
[_e,ve blank unless APCD aas ,ilreldy assigned a permit 4' rind AIRS IDI
Section 2- Requested Action
r❑ NEW permit OR newly -reported emission source
-Os -
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment 0 Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
- OR
APEN submittal for update only (Please note 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 a Notes: APEN redline update to initial application
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
compressor downtime.
VRT venting during VRU
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
10 / 20 / 2018
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: variable hours/day variable days/week variable weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
Form APCD-2I i •Platural Gas Venting APEN Rev 03/2017
O Yes
❑ Yes
21A
❑ No
❑r No
COLORADO
I'.luni<u r. u11Lw�!
u :un, c.m�.,ain.,•�
Permit Number: 18WE1241
AIRS ID Number: 123 /A013/ 005
'Lave bttrnr untass APCD n[3s aifnad;: assigned a peirnfl and AIRS IDl
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
Serial #:
# of Pistons:
Capacity: Gal/min
Leak Rate: Scf/hr/pist
❑ Blowdown Events
# of Events/year: Volume per event: MMscf/event
E Other
Description: During VRU compressor downtime, gas from the VRTs is directed to the enclosed combustor.
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑Q No
Maximum Vent
Rate:
SCF/hr
Vent Gas
Heating Value:
BTU/SCF
Requested:.
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
28,032
Bbl/yr
Actual:
23,360
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
Lt t . S13-7?...
VOC (mole %)
57.28
VOC (Weight %)
72.69
Benzene (mole %)
0.0783
Benzene (Weight %)
0.147
Toluene (mole %)
0.0498
Toluene (Weight %)
0.110
Ethylbenzene (mole %)
0.0042
Ethylbenzene (Weight %)
0.011
Xylene (mole %)
0.0139
Xylene (Weight %)
0.036
n -Hexane (mole %)
0.7800
n -Hexane (Weight %)
1.616
2,2,4-Trimethylpentane
(mole %)
0.0031
2,2,4-Trimethylpentane
(Weight %)
0.0086
Additional Required Information:
O Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Ft n -Hexane, temperature, and
pressure)
Farm APCD•2 I I Natural Gas Venting APEN Rev 03/2.0! 7
COLORADO
3 I
Permit Number: 18WE1241 AIRS ID Number: 123 /A013/ 005
.. .. r.. ;•bull: :fii::,s :il"°'Jvl u`• ; i"i1 d n£ir:i i ?' mid AIRS li;l
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.00719/-104.75928
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
(F)
Flow Rate
(ACFM)
Velocity
(ftlsec)
EC01
32
1000
50
0.017
Indicate the direction of the stack outlet: (check one)
0 Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Other (describe):
O Upward with obstructing raincap
96
Section 6 - Control Device Information
❑ VRU;
Pollutants Controlled;
Size: Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model: GCO Beast 3200
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
N/A
98 %
Waste Gas Heat Content
2,385.64 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0,040 MMBtu/hr
Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
.CCLORAOO
.: •n AP( .;• 21 I Hiiturai il•?; Venthig A! E!•! /20! /
Permit Number: 18WE1241
AIRS ID Number: 123 /A013/ 005
1._cavo clank un r'•s APCD La: airtarly ascinned a axv:nir and AIRS IDl
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? 0 Yes ❑ No
If yes, please describe the control eguipment AND state the overall control efficiency (X reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO,,
VOC
Enclosed Combustor
95
CO
HAPs
• Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
N/A
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
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NO,,
0.0036
Ibs/bbl
Calc/AP-42
0.050
0.050
VOC
1.75
Ibs/bbl
Site specific
24.47
1.22
CO
0.016
Ibs/bbl
Calc/AP-42
0.23
0.23
Benzene
0.0035
lbs/bbl
Site specific
0.050
0.0025
Toluene
0,0027
Ibs/bbl
Site specific
0.037
0.0019
Ethylbenzene
0.00026
Ibs/bbl
site specific
0.0036
0.00018
Xylenes
0.00085
Ibs/bbl
Site specific
0.012
0.00060
n -Hexane
0.039
Ibs/bbl
Site specific
0.54
0.027
2,2,4-
Trimethylpentane
0.00021
Jbs/bbl
Site specific
0.0029
0.00014
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD 21 I I latt!ral Gas Ventin9 APEN - Rev 03/2011
5 Alh
Permit Number: 18WE1241
AIRS ID Number: 123 /A013/ 005
[Levy ble,iu unless APCD has already assigned a permit C and i`-..RS ID)
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally Authorized Person (not a vendor or consultant)
Michael Cugnetti
Date
EH&S Manager
Name (please print)
Title
Check the appropriate box to request a copy of the:
E✓ 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)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-21 I Natural Gao; Venting APEN Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692.3148
Or visit the APCD website at:
https: / /www. colorado. gov/cdphe/apcd
COLORADO
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