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Home My WebLink About20190712COLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 March 7, 2019 Dear Sir or Madam: RECEIVED MAR 18 2019 WELD COUNTY COMMISSIONERS On March 14, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Mallard Exploration, LLC - Anderson Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health >:t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer I��bl�c P,e,'\e,,,-) '3/251n 2019-0712 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Mallard Exploration, LLC - Anderson Facility - Weld County Notice Period Begins: March 14, 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: Mallard Exploration, LLC Facility: Anderson Facility Well production facility SESW Section 31 T9N R59W Weld County The proposed project or activity is as follows: New EEtP well production facility within the ozone non - attainment area. Permitted equipment are crude oil storage tanks, loadout of crude oil to tank trucks, and produced water storage tanks. There is also a compression engine permitted under general permit GP02. Fugitive component leak emissions are APEN-exempt. 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 Permits 18WE0944, 18WE0947 and 18WE1180 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air- permit- public- notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLURA DO Wp+%tkb P.+^a�mwrL Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 9: Received Date: Review Start Date: 24/2018 /1/2{018 .i Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: SESW quadrant of Section 31, Township 9N, Range 59W County: Ld County Type of Facility: What industry segment?O Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) c'd 2/28/19; further revision 3/5/19 Section 02 - Emissions Units In Permit Application Quadrant Particulate Matter (PM) Ozone (NOx & VOC) Section Township Range AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks »>.ea3'iii`�s33y�,331i5�1 sur ti., 45 t1g � N� f � �W ££ 3£ i33££333� O No C i Z IOWE0Y4 � gfi kij��.:''� J �3£1 £'£'r131113�£i Y1N££1111JIIJ1j�11a /ejlOlyl ,e5'�l Y.:n ( is ie � .�l.../... � % PSg//%/ ///( A fl££lf 1 ) ji « ?��,`E� �t?.sr(�.. -�t��rt .. »y y..;1 : • ' ... Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Req€ Section OS - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 502 NOx CO Ian VOC PM2.5 PM10 TSP HAPs t✓ J CO VOC PM2.5 El El PM10 TSP HAPs ❑ ❑ Hydrocarbon Loadout Emissions Inventory 002 Liquid Loading 'Facility AlRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? 0.00 Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = ... Requested Permit LimitThroughput= Potential to Emit (PTE) Volume Loaded = Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = Requested Monthly Throughput = 32529 Barrels (bbl) per month i,544-0'''00 Barrels (bbl) per year ':'41E(11;000, Barrels (bbl) per year Secondary Emissions - Combustion Device(s) 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? Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Volume Loaded) (Volume Loaded) Emission Factors Hydrocarbon Loadout MMBTU per year MMBTU per year MMBTU per year The state default emissions factors may be used to estimate emissions. Emission Factor Source VOC 0.104 0.104 Benzene Toluene 0.00018 0.00018 0 0 0 Ethylbenzene Xylene 0 n -Hexane 224 TMP 0.0016 0.0016 0 Emission Factor Source Pollutant Control Device Uncontrolled Uncontrolled (Ih/MMBtu) (Ib/bhl) (Volume Loaded) 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 (waste heat combusted) PM10 PM2.5 SOx NOx CO Barrels (bbl) per year 2 of6 K:\PA\2018\18W E0944.CP1 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 5Ox NOx VOC CO 19.92 17.36 17.36 19.92 19.92 3383 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions, Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 69 60 60 69 69 613 534 534 613 613 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) The loadout must he operated with submerged fill to satisfy RACT. Section 07 - Initial and Periodic Sampling and Testing Requirements You have indicated above the source is not controlled. The following question does not require an answer. Section 08 - Technical Analysis Notes This ana{ysjsif)ased ort the Mere642R1.9kPEN'_ AIRS Point# Section 09 - Inventory SCC Coding and Emissions Factors Process # SCC Code 002 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (0=0.6) Uncontrolled Emissions Pollutant Factor Control% Units PM10 0 0 1b/1,000 gallons transferred PM2.5 0 0 1b/1,000 gallons transferred 5Ox 0 0 lb/1,000 gallons transferred NOx 0 0 lb/1,000 gallons transferred VOC 2.4762 0 1b/1,000 gallons transferred CO 0 0 lb/1,000 gallons transferred Benzene 0.0043 0 (b/1,000 gallons transferred Toluene 0 0 lb/1,000 gallons transferred Ethylbenzene 0 0 lb/1,000 gallons transferred Xylene 0 0 lb/1,000 gallons transferred n -Hexane 0.0381 0 lb/1,000 gallons transferred 224 TMP 0 0 lb/1,000 gallons transferred 3 of 6 K:\PA\2018\18WE0944.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Mallard Exploration, LLC County AIRS ID 123 Plant AIRS ID 9FED Facility Name Anderson Facility History File Edit Date Ozone Status 314/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 GP02 Cummins GTA655P1. sn: 0.2 0.2 26.3 0.7 6.3 0.3 0.2 0.2 2.2 0.7 4.3 0.3 new GP02 Aug 2018 002 18WE0944 Loadout of crude oil to trucks 19.9 0.3 19.9 0.3 Default EFs accepted 003 18WE0947 Crude oil tanks (3000 bbl) 0.1 0.1 1.1 612.8 4.8 55.7 0.1 0.1 1.1 30.6 4.8 2.8 Default EFs accepted; sampling req'd 004 18WE1180 Produced water tanks (1000 bbl) 0.0 0.0 0.3 27.2 1.5 3.0 0.0 0.0 0.3 1.4 1.5 0.2 Default EFs accepted, no sampling req'd APEN-Exempt / Insignificants Fugitives 0.1 0.0 0.1 0.0 From Aug 2018 Form 102 FACILITY TOTAL 0.3 0.3 0.0 0.0 27.7 660.6 0.1 12.6 59.3 0.3 0.3 0.0 0.0 3.6 52.6 0.1 10.7 3.5 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hex & Total ZZZZ: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 27.7 660.6 0.0 12.6 59.3 0.3 0.3 0.0 0.0 3.6 52.6 0.0 10.7 3.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.3 0.3 0.0 0.0 3.6 52.6 0.0 10.7 Pubcom required based on new syn minor limits for NANSR Note 1 Total VOC Fad ity Emissions (point and fugitive' (A) Change in Total Permitted VOC emissions (point and fugitive 52.7 Facility is eligible for GP02 because < 90 Project emissions less than 25/50 tpy 52.6 Application was revised multiple times. The entries above reflect the March 4 2019 revised APENs. Note 2 Page 4 of 6 Printed 3/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Mallard Exploration, LLC 123 9FED Anderson Facility Emissions - uncontrolled (Ibs per year POIN1 PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Cummins GTA855P1, sn: 253286' 343 47 44 26 51 0.3 002 18WE0944 Loadout of crude oil to trucks 69 613 0.3 003 18WE0947 Crude oil tanks (3000 bbl) 17618 93835 55.7 004 18WE1180 Produced water tanks (1000 bbl) 1454 4571 3.0 APEN-Exempt / Insignificants Fugitives 0.0 TOTAL (tpy) 0.2 0.0 0.0 9.6 0.0 0.0 0.0 49.5 0.0 0.0 0.0 0.0 59.3 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus tmissions wain controls (ips per year) POIN1 PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H25 TOTAL (WY) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Cummins GTA855P1, sn: 253286' 343 47 44 26 51 0.3 002 18WE0944 Loadout of crude oil to trucks 69 613 0.3 003 18WE0947 Crude oil tanks (3000 bbl) 881 4692 2.8 004 18WE1180 Produced water tanks (1000 bbl) 73 229 0.2 5 18WE0944.CP1 3/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Mallard Exploration, LLC 123 9FED Anderson Facility I I APEN-Exempt I Insignificants Fugitives 0.0 TOTAL (tpy) 0.2 0.0 0.0 0.5 0.0 0.0 0.0 2.8 0.0 0.0 0.0 0.0 3.5 6 18WE0944.CP1 3/4/2019 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: SESW quadrant of Section 31, Township 9N, Range 59W County: (Weld County Type of Facility: 'syle a on c,Pt What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) 2✓ Ozone (NOx @ VOC) d 2/28/19; further revision 3/5/19 Quadrant Section 02 - Emissions Units In Permit Application Section Township Range AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks iir gti1 ...; Natural infEt i�l�° Yes: 6f�� ..._ �No��\��.�'7 /i 002 �t��dgalltng \N 8WEO '4U 2 cP1 eq itik W\- \®�� .:. 18WlwdS4 ' �11≥Nik≥m'.CP1 �'� \�`.`: Prird asp ., hex Section 03 - Description of Project Appltrdnt's consdltant maslvd'a confirma cornp�ete revision of yll APENs re a 2 ?$a Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No , If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Willie 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? If yes, explain what programs and which pollutants hers 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 502 NOx CO VOC PM2.5 PM10 TSP HAPs NOx J ❑ ❑ CO VOC PM2.5 PM10 T5P HAPs ❑ ❑ Crude Oil Storage Tank(s) Emissions Inventory 003 Crude Oil Tank Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: ado oit Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput= "> $83,OOIHi Barrels (bbl) per year Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating = Requested Monthly Throughput = 32529 Barrels (bbl) per month I Potential to Emit (PTE) Throughput = Secondary Emissions- Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Btu/scf scf/bbl 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? default for crude oil (PS Memo 14-03) default for crude oil (PS Memo 14-03) 27,145 MMBTU per year 31,140 MMBTU per year 31,140 MMBTU per year Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Crude Oil Throughput) 5.20;"...,,..:_;: 0.046 Benzene TIMEIIMEN Pollutant (Crude Oil Throughput) 0.002 0.000 0.000 0.000 0.000 (Ib/M MBtu) (waste heat combusted) Y,. 0.0075 S9=L6. (lb/bbl) 0.0075 0.3100 (Crude Oil Throughput) Emission Factor Source Uncontrolled Uncontrolled Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 N Ox CO 612.8 534.2 26.7 612.80 30.64 5205 0.1 0.10 0.10 0.12 0.12 20 0.1 0.10 0.10 0.12 0.12 20 1.1 0.92 0.92 1.06 1.06 180 4.8 4.21 4.21 4.83 4.83 820 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 17618 15358 768 17618 881 93835 81798 4090 93835 4692 Section 06- Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, SectionXVII.B, Cl..C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1&C3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVll.C.2 Regulation 6, Part A, NIPS 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, MACE Subpart HH Storage Tank is not subject to MACI HH (See regulatory applicability worksheet for detailed analysis) 2 of K:\PA\2018\18 W E0947.CP1 Crude Oil Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolimi actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? If kzsr h„ pafmlxryl)I Cadtiin an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 003 01 Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.0144 0 lb/1,000 gallons crude oil throughput PM25 0.0144 0 lb/1,000 gallons crude oil throughput NOz 0.1316 0 lb/1,000 gallons crude oil throughput VOC 76.1905 95 lb/1,000 gallons crude oil throughput CO 0.6001 0 lb/1,000 gallons crude oil throughput Benzene 1.0952 95 lb/1,000 gallons crude oil throughput Toluene 95 lb/1,000 gallons crude oil throughput Ethylbenzene 95 lb/1,000 gallons crude oil throughput Xylene 95 Ib/1,000 gallons crude oil throughput n -Hexane 5.8333 95 lb/1,000 gallons crude oil throughput 224 TMP 95 Ib/1,000 gallons crude oil throughput 3 of 6 K:\PA\2018\18WE0947.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Mallard Exploration, LLC County AIRS ID 123 Plant AIRS ID 9FED Facility Name Anderson Facility History File Edit Date Ozone Status 3/4/2019 Non -Attainment - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 GP02 Cummins GTA855P1, sn: 0.2 0.2 26.3 0.7 6.3 0.3 0.2 0.2 2.2 0.7 4.3 0.3 new GP02 Aug 2018 002 18WE0944 Loadout of crude oil to trucks 19.9 0.3 19.9 0.3 Default EFs accepted 003 18WE0947 Crude oil tanks (3000 bbl) 0.1 0.1 1.1 612.8 4.8 55.7 0.1 0.1 1.1 30.6 4.8 2.8 Default EFs accepted; sampling req'd 004 18WE1180 Produced water tanks (1000 bbl) 0.0 0.0 0.3 27.2 1.5 3.0 0.0 0.0 0.3 1.4 1.5 0.2 Default EFs accepted, no sampling req'd APEN-Exempt / Insignificants Fugitives 0.1 0.0 0.1 0.0 From Aug 2018 Form 102 FACILITY TOTAL 0.3 0.3 0.0 0.0 27.7 660.6 0.1 12.6 59.3 0.3 0.3 0.0 0.0 3.6 52.6 0.1 10.7 3.5 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hex & Total ZZZZ: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 27.7 660.6 0.0 12.6 59.3 0.3 0.3 0.0 0.0 3.6 52.6 0.0 10.7 3.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.3 0.3 0.0 0.0 3.6 52.6 0.0 10.7 Pubcom required based on new syn minor limits for NANSR Note 1 Total VOC Faci ity Emissions (point and fugitive' (A) Change in Total Permitted VOC emissions (point and fugitive 52.7 Facility is eligible for GP02 because < 90 Project emissions less than 25/50 tpy 52.6 Application was revised multiple times. The entries above reflect the March 4 2019 revised APENs. Note 2 Page 4 of 6 Printed 3/4/2019 Company Name County AIRS ID Plant AIRS ID Facility Name Mallard Exploration, LLC 123 9FED Anderson Facility COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Emissions - uncontrolled ( p Ibs er POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene NI f Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TO (tPY)TAL 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Cummins GTA855P1, sn: 253286' 343 47 44 26 51 0.3 002 18WE0944 Loadout of crude oil to trucks 69 613 0.3 003 18WE0947 Crude oil tanks (3000 bbl) 17618 93835 55.7 004 18WE1180 Produced water tanks (1000 bbl) 1454 4571 3.0 APEN-Exempt / Insignificants Fugitives 0.0 TOTAL (tpy) 0.2 0.0 0.0 9.6 0.0 0.0 0.0 49.5 0.0 0.0 0.0 0.0 59.3 `Total Reportable = all HAPs where unenntmlIeri emissions > rte minim le via lr roe Red Text: uncontrolled emissions < de minimus • emissions wuin controls (IDS per year) _ POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Cummins GTA855P1, sn: 253286' 343 47 44 26 51 0.3 002 18WE0944 Loadout of crude oil to trucks 69 613 0.3 003 18WE0947 Crude oil tanks (3000 bbl) 881 4692 2.8 004 18WE1180 Produced water tanks (1000 bbl) 73 229 0.2 5 18WE0947.CP1 3/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Mallard Exploration, LLC 123 9FED Anderson Facility I I APEN-Exempt / Insignificants Fugitives 0.0 TOTAL (tpy) 0.2 0.0 0.0 0.5 0.0 0.0 0.0 2.8 0.0 0.0 0.0 0.0 3.5 6 18WE0947.CP1 E0947.CP1 3/4/2019 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: Poona d;E,toi.,rat ,q, r1.C County AIRS ID: 123 Plant AIRS ID: FED Facility Name: Physical Address/Location: SESW quadrant of Section 31, Township 9N, Range 59W County: Type of Facility: What industry segment?''C Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Carbon Monoxide (CO) 1p tc'd 2/28/19; further revision 3/5/19 'Weld County Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Quadrant Section Township Range SESW 9 Ozone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 iP, ) it `�,' laturai Gas RICE Yes GPO? No ) �„ ,- :_ .,.,3.. 002 " '. :., , Liquid Loading No :. 18W 0944 rP1 ':Yes 003 V t3 tL j wY $U✓20947 004 P€odic '. ,.._., ., 1 131180 CPti Section 03 - Description of Project Appl€cattts'eonsuttantemailed a confirmation on 11/8,18 that the facility is Vithini compete revision of all APEN5, recd2/2a/19 (and further revised on 3/5/19}, upon Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? boundaries of the ozone non attairim, ch the permits/analysis are based: Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review(NANSR) `.j Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs NOx CO VOC PM2.5 PM10 ❑ El TSP HAPs ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory 004 Produced Water Tank Facility AIRs ID: ,mgeMS f;11JIIII,r,,;.004 County Plant Paint Section 02 - Equipment Description Details Detailed Emissions Unit ,,Two (2) 50 —Phi fixed roof produced water store Description il(ut€:"=_,'11111111'iit111J'fk3�Uilt hug,,,, 99udixi Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency 56: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput =. Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= ,u .14 6Ij Btu/scf Volume of waste gas emitted per BBL of liquid produced= I�� 3scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating= Requested Monthly Throughput = 17646 Barrels (bbl) per month Barrels (bbl) per year 8,028 MMBTU per year 9,636 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 9,636 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Produced (Produced Water Water Throughput) Throughput) VOC 0.262:" 0.01. Benzene Toluene 0.000 0.000 0.000 0.000 Ethylbenzene Xylene n -Hexane 224 TMP 0,022. 0.00 0.000 Control Device Pollutant Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Produced water Throughput) PM10 PM2.5 .0575 0.0003 0.0003 0.0032 0.0144 NOx CO Section 05 - Emissions Inventory Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 27.2 22.7 1.1 27.22 1.36 231 0.0 0.0 0.0 0.04 0.04 6 0.0 0.0 0.0 0.04 0.04 6 0.3 0.3 0.3 0.33 0.33 56 1.5 1.2 1.2 1.49 1.49 254 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 1454 1212 61 1454 73 4571 3808 190 4571 229 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 2 of K:\PA\2018\18W E1180. CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 004 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.0082 0 lb/1,000 gallons liquid throughput PM2.5 0.0082 0 lb/1,000 gallons liquid throughput NOx 0.0751 0 lb/1,000 gallons liquid throughput VOC 6.2381 95 lb/1,000 gallons liquid throughput CO 0.3423 0 lb/1,000 gallons liquid throughput Benzene 0.1667 95 lb/1,000 gallons liquid throughput Toluene 95 lb/1,000 gallons liquid throughput Ethylbenzene 95 lb/1,000 gallons liquid throughput Xylene 95 lb/1,000 gallons liquid throughput n -Hexane 0.5238 95 lb/1,000 gallons liquid throughput 224 IMP 95 lb/1,000 gallons liquid throughput 3 of 6 K:\ PA\2018\18 W E1;180. CP 1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Mallard Exploration, LLC County AIRS ID 123 Plant AIRS ID 9FED Facility Name Anderson Facility History File Edit Date Ozone Status 3/4/2019 Non -Attainment NS - Uncontrolled (tons aer year EMISSIONS With Controls (tons per year POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 GP02 Cummins GTA855P1. sn: 0.2 0.2 26.3 0.7 6.3 0.3 0.2 0.2 2.2 0.7 4.3 0.3 new GP02 Aug 2018 002 18WE0944 Loadout of crude oil to trucks 19.9 0.3 19.9 0.3 Default EFs accepted 003 18WE0947 Crude oil tanks (3000 bbl) 0.1 0.1 1.1 612.8 4.8 55.7 0.1 0.1 1.1 3D.6 4.8 2.8 Default EFs accepted; sampling req'd 004 18WE1180 Produced water tanks (1000 bbl) 0.0 0.0 0.3 27.2 1.5 3.0 0.0 0.0 0.3 1.4 1.5 0.2 Default EFs accepted, no sampling req'd APEN-Exempt / Insignificants Fugitives 0.1 0.0 0.1 0.0 From Aug 2018 Form 102 FACILITY TOTAL 0.3 0.3 0.0 0.0 27.7 660.6 0.1 12.6 59.3 0.3 0.3 0.0 0.0 3.6 52.6 0.1 10.7 3.5 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hex & Total ZZZZ: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 27.7 660,6 0.0 12.6 59.3 0.3 0.3 0.0 0.0 3.6 52,6 0.0 10.7 3.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.3 0.3 0.0 0.0 3.6 52.6 0.0 10.7 Pubcom required based on new syn minor limits for NANSR Note 1 Total VOC Faci ity Emissions (point and fugitive (A) Change in Total Permitted VOC emissions (point and fugitive 52.7 Facility is eligible for GP02 because < 90 Project emissions less than 25/50 tpy 52.6 Application was revised multiple times. The entries above reflect the March 4 2019 revised APENs. Note 2 Page 4 of 6 Printed 3/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Mallard Exploration, LLC 123 9FED Anderson Facility Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP 1..12.5 TOTAL (WY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Cummins GTA855P1, sn: 253286' 343 47 44 26 51 0.3 002 18WE0944 Loadout of crude oil to trucks 69 613 0.3 003 18WE0947 Crude oil tanks (3000 bbl) 17618 93835 55.7 004 18WE1180 Produced water tanks (1000 bbl) 1454 4571 3.0 APEN-Exempt / Insignificants Fugitives 0.0 TOTAL (tpy) 0.2 0.0 0.0 9.6 0.0 0.0 0.0 49.5 0.0 0.0 0.0 0.0 59.3 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus emissions witn controls (1Ds per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP 1..125 TOTAL (tpY) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Cummins GTA855P1, sn: 253286' 343 47 44 26 51 0.3 002 18WE0944 Loadout of crude oil to trucks 69 613 0.3 003 18WE0947 Crude oil tanks (3000 bbl) 881 4692 2.8 004 18WE1180 Produced water tanks (1000 bbl) 73 229 0.2 5 18WE1180.CP1 3/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Mallard Exploration, LLC 123 9FED Anderson Facility APEN-Exempt / Insignificants Fugitives 0.0 TOTAL (tpy) 0.2 0.0 0.0 0.5 0.0 0.0 0.0 2.8 0.0 0.0 0.0 0.0 3.5 6 18WE1180.CP1 3/4/2019 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0944 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Mallard Exploration, LLC Anderson Facility 123/9FED SESW Section 31 T9N R59W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description --- 002 Truck loadout of crude oil by submerged fill. None 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, ty 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 'COLORADO Air Pollution Control Division Ceparsme nt of Public Health ¢ Environment Page 1 of 8 how to self -certify compl x eq • •y th' ' • it m •y'' obtai -d online at www.colorado.•ov/cd•he it-� ifi tione•u ,lion Num€ r 3, Part B, Section I II.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 riot complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO --- 002 --- --- 19.9 --- 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. PROCESS LIMITATIONS AND RECORDS 6. 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) COLORADO Air Pollution Control Division x:. Nalt.h "v En,ironhert. Page 2 of 8 Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit --- 002 Crude Oil Loaded 383,000 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.D.2) 9. 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. 10. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. ;COLORADO Air Pollution Control Division reeve, of Pta,lea Health E, Em5rcrnert. Page 3 of 8 e. Document annual i oecti • o h hatc .and D ith a : ndication of status, a descripti OPERATING Ft MAINTENANCE REQUIREMENTS 11. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 12. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 13. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 14. 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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. COLORADO Air Pollution Control Division (1s:;.arman; ,f 2i l r. NeaPth 6 F.mfrcrmenst. Page 4 of 8 GENERAL TERMS AND CONDITI 15. 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. 16. 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. 17. 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. 18. 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. 19. 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. 20. 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. 21. 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. COLORADO Air Pollution Control Division Sment rt r'h;bLr Neatth b Environment. Page 5 of 8 By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Mallard Exploration, LLC. COLORADO Air Pollution Control Division E`,�„' r,tienc s1 ₹'ublic Health F E chrcninere. Page 6 of 8 Notes to Permit Holder at the ti 1) The permit holder is require ees -' he - :. : sin • his pe An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: //www.colorado.gov/ pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 69 N/A - Not Controlled n -Hexane 110543 613 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 002: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.104 0.104 Default for Crude Oil Loadout Benzene 71432 0.00018 0.00018 n -Hexane 110543 0.0016 0.0016 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 ICOLORADO Air Pollution Control Division 1 Mpartrnent (2f i Heals a. b Environmoni. Page 7 of 8 APEN expiration date for eac questions regarding a specific 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC and HAPs (total and n -hexane) 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 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 COLORADO Air Pollution Control Division tXspartment n; F sFsl r. Hea?t^. s,* Fnvirtar>rwq. Page 8 of 8 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0947 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Mallard Exploration, LLC. Anderson Facility 123/9FED SESW Section 31 T9N R59W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description --- 003 Six (6) 500 barrel fixed roof storage vessels used to store crude oil. 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, l 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 :COLORADO Air Pollution Control Division Dtpartmenc of Public Heakh 8 ErAlrorment. Page 1 of 8 It in •cats • f the •ermit. A self certification form and guidance on ertif as r iuired by this permit may be obtained online at of ra.go /cd a/:fir-permi self -certification. (Regulation Number 3, Part B, 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO --- 003 --- 1.1 30.6 4.8 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division F'eaith Z".7 Enirornvnt. Page 2 of 8 c • E i • t cm Control Device Pollutants Controlled --- 003 Enclosed Flare (Cimarron 48" HV) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit --- 003 Crude Oil throughput 383,000 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/9FED/xxx) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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. 12. 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 COLORADO Air Pollution Control Division De^„ar:x enc ni'uMr Healch b Env ronru nt. Page 3 of 8 rbons except where the combustion device has y 1, 2014. The source shall follow the inspection umber Section XVII.C.1.d. and maintain records of the year 1 ade available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 14. 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 OEtM 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 15. The owner or operator shall complete site specific sampling including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site - specific sampling and analysis shall be submitted to the Division as part of the self - certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: COLORADO Air Pollution Control Division E-,^.arrncnt rt ?ubtE;. Health E Environmeel. Page 4 of 8 100 tons per year, a change in actual emissions , 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 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. COLORADO Air Pollution Control Division Ck:rartT.enc } Pubtz Wealth c Ern r 1fnt. Page 5 of 8 22. Unle s�: '� ally ed • a=a : ise the general and specific conditions contained in the APCD to be necessary to assure compliance .5(7)(a), C.R.S. 23 a e • `di `': is p- is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Mallard Exploration, LLC. !COLORADO Air Pollution Control Division € martmen, rf -3 Jac i4eat ^Env;ronmfmt Page 6 of 8 Notes his p mit issuance: 1) T p.` fee or the processing time for this permit. An invoice fo ' the , fe l b iss d er the -rmit is issued. The permit holder shall pay the i •` wi 3 of t voice. 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 17,618 881 n -Hexane 110543 93,835 4,692 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: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0055 0.0055 AP -42 Ch. 13.5 CO 0.0252 0.0252 VOC 3.20 0.16 APCD Default Emission Factors for Weld County Crude Oil 71432 Benzene 0.046 0.0023 110543 n -Hexane 0.245 0.01225 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. NOx and CO emission are based on the state default heat content of 3535 Btu/scf and GOR of 23 scf/bbl (per PS Memo 14-03.) COLORADO Air Pollution Control Division P.7.artnvg. t Pubic Health ' Entihronment Page 7 of 8 6) In as by y 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: Air Pollutant Emission Notice (APEN) erm of five years from the date it was received bmitted no later than 30 days before the five - recent annual fee invoice to determine the Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs (total and n -hexane) NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://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 COLORADO Air Pollution Control Division Page 8 of 8 h & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE 1180 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Mallard Exploration, LLC Anderson Facility 123/9FED SESW Section 31 T9N R59W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description --- 004 Two (2) 500 barrel fixed roof storage vessels used to store produced water. 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 ;COLORADO Air Pollution Control Division Department cf u * Health e e'.nvecranent. Page 1 of 8 It in •cats`"• f the •ermit. A self certification form and guidance on ertif r- plias r; wired by this permit may be obtained online at of ra go: /cd. ; e/.'r-permi self -certification. (Regulation Number 3, Part B, 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO --- 004 --- --- 1.4 --- 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 shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division c^.epartni rttcg >uI-,Icc ;;=ea≥t^ Envi:"ronrrvm:. Page 2 of 8 E i • - i t I' of Control Device Pollutants Controlled --- 004 Enclosed Flare (Cimarron 48") VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit - - 004 Produced Water throughput 207,773 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/9FED/xxx) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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; 12. 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 COLORADO Air Pollution Control Division rtm nt oaf Pubit Neaith a rEnvror:tnem. Page 3 of 8 rbons except where the combustion device has y 1, 2014. The source shall follow the inspection , Section XVII.C.1.d. and maintain records of the year ; ade available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. 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 a MAINTENANCE REQUIREMENTS 14. 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 O8M 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 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or COLORADO Air Pollution Control Division :iF,r I"T32n� 3i ?iiP, `rdeaith c e':nsrcrrrumt. Page 4 of 8 le pollutant: or five (5) tons per year, whichever is less, above EN 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 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it 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. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. !COLORADO Air Pollution Control Division r4par,:nertt of PubItt:. Health & Emimn3nent. Page 5 of 8 23. es that all sources required to file an Air Pollution nnual fee to cover the costs of inspections and is to be discontinued, the owner must notify the ation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Mallard Exploration, LLC. COLORADO Air Pollution Control Division Mranms,,n' of P;b14c?=ealtn e Fnvironm m t. Page 6 of 8 Notes Pe it t • "-r at tim his p mit issuance: 1) T fee or the processing time for this permit. An invoice fo . the fe t b iss , v d . er the rmit is issued. The permit holder shall pay the 31 • :' ''' o •`"' oft voice. 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) 004 Benzene 71432 1,454 73 n -Hexane 110543 4,571 229 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 004: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0032 0.0032 AP -42 Ch. 13.5 CO 0.0144 0.0144 V0C 0.262 0.0131 APCD Default for Weld County Produced Water 71432 Benzene 0.007 0.00035 110543 n -Hexane 0.022 0.0011 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. N0x and CO emissions are based on the state default produced water heat content of 1496 Btu/scf and GWR of 31 scf/bbl (per PS Memo 14-03.) 'COLORADO Air Pollution Control Division Department t „f Mask, Hiatt a Envircn-v:nt. Page 7 of 8 1, e.=': h Air Pollutant Emission Notice (APEN) for a erm of five years from the date it was received hall be bmitted no later than 30 days before the five - the 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, HAPs (total, and n -hexane) 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 ;COLORADO 3 Air Pollution Control Division ra;;allment.a# Public Healthy E, iron!: rnt. Page 8 of 8 • -t Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 1g vvf-dg'ILI AIRS ID Number: /2. 3 /6/F,6 / d o t [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Namet: Mallard Exploration, LLC Site Name: Anderson Facility Site Location: SESW 31 9N59W 40.701705, -104.023666 Mailing Address: (Include Zip Code) 1400 16th Suite 300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Erin Mathews Phone Number: 7205437959 E -Mail Address2: Emathews@mallardexploration.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source 0 Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- Q MODIFICATION to existing permit (check each box below that applies) 0 Change fuel or equipment 0 Change company name3 ❑✓ Change permit limit 0 Transfer of ownership4 0 Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Increasing Throughput 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: 5/15/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? p Yes p No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • IS Does this source load gasoline into transport vehicles? • Yes p No Is this source located at an oil and gas exploration and production site? Yes No p ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No p ■ Does this source splash fill less than 6750 bbl of condensate per year? Yes No p ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No p ■ Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 2 I A� t�ep 7,-,7lr, is VVV H«,en.;„„KM 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 Loaded5: 383,000 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: Tank Trucks (e.g. "rail tank cars" or "tank trucks") 333,903 bbl/year 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: Psia ® 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 Loaded5: NA bbl/year Actual Volume Loaded: NA bbl/year Product Density: NA lb/ft3 Load Line Volume: NA ft3/truckload Vapor Recovery Line Volume: NA ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 © ,COLORADO 3 1 ��:e�, X9YL{tr�nv114NngN 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) 40.701705, -104.023666 ` Operator' Stack ID No. Discharge Height Above Ground Level �� (feet), �, r . Temp _ ( F) ��t - 10 a .� v m NA Unknown Unknown Unknown Unknown Indicate the direction of the stack outlet: (check one) ❑✓ Upward 0 Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): Other (describe): ❑ Upward with obstructing raincap Unknown 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: 0 Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: Rating: MMBtu/hr Type: Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: 0 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I COLORADO •!tl!E E'rvAY9!L;.. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) . Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC HAPs Other: 0 Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane O Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0✓ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Criteria_Pallutant.Emissions.nxen ._ ..... Pollutant_..:.:..:_......: ...... .. _. ___.. __ `-=-: '- ' ' - � . ':.Emission:Factor-_•-. : ":_ ... :.:_"ActualAnnual.Emissions. :----:- e __ a nnua-Permit :- � ; E is•sion L mif s rva ( ) ........_ ..•.. Uncontrolled-____....—.:_----=-_ .� Basis---:•-- .. _ �. :-: - Units_:_ � ... __.._ __ _Sourde-=.:._ •,_, -(4.-"P42;-7':._----. /� f$'r, etc. f -• _. '"Uncontrolled — Emissions_•..."_Emissions (tonslyedr). • :. _.. -' +-Controlled .. . _:..IJnCOntTOll2dl=--=.Controlled:==-: - --..-,..Controlled.:_;-,.. _— ..:..: ... (tons/year)—. ,_. Emissions-�:__ " •- (fonslyear) . : Emissions_ �� :.: ' (tbrisiyeur) _`. PM SOx NO. CO VOC 0.104 Ibs/bbl PS memo 14-02 17.4 19.9 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical . Abstract Service (CAS) Number Emission Factor • . Actual Annual Emissions Uncontrolled Basis Units . Source • (AP -42, Mfg., etc.) Uncontrolled. Emissions .. (pounds/year) . Controlled Emissions (pounds/year) Benzene 71432 0.00018 lbs/bbl PS memo 14-02 69 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0036 Ibs/bbl PS Memo 14-02 613 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 AV COLORADO 5 1LxgratrnentofPua,: 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 General Permit GP07. John Tonello Digitally signed by John Tonello Date: 2019.03.04 14:58:53 -07'00' Signature of Legally Authorized Person (not a vendor or consultant) Date John Tonello CEO Name (print) Title Check the appropriate box to request a copy of the: g✓ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe /apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 6 =o „.ri;< Crude Oil Storage Tank(s) APEN Form APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: te(4/0TLf-7 AIRS Number: ID `2. 3 o o3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] -- Section 1 - Administrative Information Company Namet: Mallard Exploration, LLC Site Name: Anderson Facility Site Location: SESW 31 9N59W 40.701705, -104.023666 Mailing Address: (Include Zip Code) 1400 16th St Suite 300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Erin Mathews Phone Number: 7205437959 E -Mail Address2: Emathews@mallardexploration.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 ,COLORADO ,n7Y.EEnet Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 ❑✓ Change permit limit O Transfer of ownership4 0 Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - - ADDITIONAL PERMIT ACTIONS - El 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: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): Crude Oil Storage Tanks Crude Oil Tanks 1-6 For existing sources, operation began on: 5/15/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 0 Exploration a Production (E&P) site weeks/year 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? p Yes • No Are Flash Emissions anticipated from these storage tanks? • Yes ■ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No U O Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLORADO 2 tee, Hau?!a€=mum Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits' (bbl/year) Crude Oil Throughput: 333,871 383,000 From what year is the actual annual amount? 2018-2019 Average API gravity of sales oil: 34.7 degrees 0 Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 0 External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage_Vessel in Storage Tank (month/year) " Date of First Production (Month/year) 6 x 500 bbl Crude Oil Tanks 500 April 2018 May 2018 API Number:. 05 - 123 -41008 Wells Serviced by this Storage Tank or Tank Batteryb.(E£tPSites Only)_ Name of Well Shull Fed 31-32-1HN Newly Reported -'Well 05 -123 -41011 Shull Fed 31-32-2HC 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EFtP 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 orUTM); Operator Stack ID No. - Discharge Height Above Ground Level (feet) Temp. co Flow Rate !" - (ACFM) Velocity . - (ft/sec) NA UNK UNK UNK UNK Indicate the direction of the stack outlet: (check one) ❑✓ Upward 0 Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): 0 Upward with obstructing raincap UNK Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 iCOIORADO 3 _ o« M, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor 0 Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: Rating: 12.0 MMBtu/hr Type: Make/Model: Cimmaron 48" HV Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: VOC, HAP 95 99 Waste Gas Heat Content: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? Varies psig Describe the separation process between the well and the storage tanks: HLP Separator Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 --,COLORADO AV 4I lo4 Benzene Permit Number: AIRS ID Number: i [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant VOC NOx CO Description of Control Method(s) ECO Overall Requested. Control Efficiency (% reduction in emissions) 95 HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Projected Pollutant VOC NOx Criteria Pollutant Emissions Inventory Emission Factor? , --Actual Annual Emissions-=- Controlled =: Emissions (tons/year), _. Uncontrolled Basis 3.20 0.068 Units Ibs/bbl Ib/MMbtu Source (AP -42, Mfg.; etc.)`[ APCD AP -42 Uncontrolled Emissions (tons/ year) 534.2 0.9 Controlled Emissions$ (tons/year) 26.7 0.9 Uncontrolled Emissions (tons/year),' 6 OCl2, 1.1 ' a21 1.1 CO 0.31 lb/MMbtu AP -42 4.2 4.2 4.8 4.8 on -Criteria Report able Pollutant Emissions Invento Chemical Abstract Service (CAS) Number 71432 Emission Factor?- uai Annual: Emissions Uncontrolled Basis 0.046 Units Ibs/bbl = Source (AP -42, Mfg., etc.) APCD ncontrolled Emissions (pounds/year) 17618 Controlled, Emissionsa (pounds/year)--- 881 Toluene 108883 Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 0.245 Ibs/bbl APCD 93835 4692 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLORADO 5 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit At and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. John Tonello Digitally signed by John Tonello Date: 2019.03.04 14:58:23 -07'00' Signature of Legally Authorized Person (not a vendor or consultant) Date John Tonello CEO Name (print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 A® COLORADO =1=wni Produced Water Storage Tank(s) APEN - Form APCD-207 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 produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www,colorado.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: iew.e II go AIRS ID 12-3 Number: 9F E,b 1 0011 — [Leave blank unless APCD has already assigned a permit # and AIRS ID] -- - Section 1 - Administrative Information Company Hamel: Mallard Exploration, LLC Site Name: Anderson Pad Site Location: SESW 31 9N59W 40.701705,-104.023666 Mailing Address: (Include Zip Code) 1400 16th St Suite 300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Erin Mathews Phone Number: 7205437959 E -Mail Address2: Emathews@mallardexploration.com t Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 of AV COLORADO HCNy. tr{m^.,om�Ml 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 0 GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) O Change in equipment 0 Change company name3 ❑✓ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Requesting Higher Throughput 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage Tanks 5/15/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 ❑✓ Exploration 8 Production (EEtP) site weeks/year 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? / Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ✓ Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes ❑ No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ❑ Yes No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 2 Depanstanivi bEnrtw,un, Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl /year) 173,111 Requested AnnualPermit Li mit5 (bbl/year) 207,773 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof Projected ❑ Internal floating roof ❑ 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 g _ storage Tank (month/year) Date of First - - Production (month/year) 2 x 500 BBL 500 April 2018 May 2018 Wells Servicedby th sStorage.Tank or Tankigatteryb (EaP,Sites 0:nlyr 3 : API .Number Name of Well. Newly. Reported Well 05 -123 -43664 Shull Fed 31-32-1HN 05 -123 -46663 Shull Fed 31-32-2HC 5 Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 6 The EftP 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) 40.701705, -104.023666 Operator Stack ID No. Discharge Height Above Ground Level (feet) _ Temp. (°F) Flow Rate . (ACFM) Velocity (ft/sec)" NA UNK UNK UNK UNK Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal O Downward ❑Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): Unknown ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 Ale7 COLORADO 3 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control•Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑✓ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 12.0 Type: MMBtu/hr Make/Model: Cimmaron 48" Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 99 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: O Yes 0 No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? Varies psig Describe the separation process between the well and the storage tanks: HLP Separator Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 4 I VOC Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN forme. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Description of Control Method(s) ECD Overall Requested Control Efficiency (% reduction in emissions) 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? Pollutant Source - (AP -42," Mfg., etc.) Criteria: Pollutant. Emissions Inventory Actual'Annual Emissions ':: Requested Annual, Permit Emission Limits) Uncontrolled; Basis Units Uncontrolled Emissions ._ (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions '. (tons/year) VOC 0.262 Ibs/bbl APCD ,8271. NOx 22 - v 2.. I-kr CO Chemical Name Benzene Non -Criteria Repo table.Pollutant Emissions_Invento y _ Chemical Abstract Service (CAS) Number 71432 Emission Factor7-- Uncontrolled Basis 0.007 Units Ibs/BBL Source (AP -42, -Mfg., etc.) APCD Actual AnnuahEmissions--; Uncontrolled Emissions (pounds/year) 1454 Controlled Emissions$ (pounds/year) --- - 73 Toluene 108883 Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 0.022 lbs/BBL APCD 4571 229 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 5 14,COLORADO v' „i" .;,, 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 GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. John Tonello Digitally signed by John Tonello Date: 2019.03.04 14:56:19 -0700' Signature of Legally Authorized Person (not a vendor or consultant) Date John Tonello CEO Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 6j CORADO wLO �-..�.... R. � w� tecey-. Cat- �: We rP \OV Hello