HomeMy WebLinkAbout20192076.tiffCOLORADO
Department of Public
Health b 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
May 28, 2019
Dear Sir or Madam:
RECEIVED
JUN 03 2019
WELD COUNTY
COMMISSIONERS
On May 30, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Verdad Resources LLC - Brnak 01N -64W-10 Production 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 Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor
ic%C Vie
(s)/1O11O%
I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
GC: •PL(-vP), VkL(3-O,
PWC PA ietkicHIcY�
2019-2076
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Verdad Resources LLC - Brnak 01N -64W-10 Production Facility - Weld County
Notice Period Begins: May 30, 2019
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Verdad Resources LLC
Facility: Brnak 01N -64W-10 Production Facility
Well Production Facility
NWNW of Section 10, Township 1N, Range 64W
Weld County
The proposed project or activity is as follows: The operator is requesting permit coverage for natural gas
venting from two (2) heater treaters, eight (8) condensate storage vessels and condensate loadout at a new
synthetic minor oil and gas well production facility located in the ozone non -attainment area.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1034, 19WE0247 Ft
19WE0248 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:
Harrison Slaughter
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
1 I � , 14 6 eAvi etme
': n.m�ns enmmn�
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Harrison Slaughter
Package #: 388088
Received Date: 9/21/2018
Review Start Date: 2/19/2019
Section 01- Facility Information
Company Name: Verdad Resources LLC
County AIRS ID: 123
Quadrant
Section
Township
Range
NWNW
10
1N
64
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
9FF7
Brnak 01N -64W-10 Production Facility
NWNW quadrant of Section 10, Township 1N, Range 64W
Weld County
Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? I I Carbon Moioxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
005
Separator Venting
HT-VENT01
Yes
18WE1034
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Verdad Resources LLC (Verdad) submitted an application requesting permit co✓erage for separator venting from two (2) three-phase heater treaters at a new synthetic minor
oil and gas well production facility located in the ozone non -attainment area.
This source is APEN required because uncontrolled VOC emissions from the source are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section II.B.3.a.). Additionally, the
source is permit required because uncontrolled VOC emissions from all APENrequired sources at the facility are greater than 2 tpy (CO AQCC Regulation 3, Part B, Section
II.D.2.a.).
Public comment is required for this source because new synthetic minor limits are being established at the facility in orderto avoid other requirements. Additionally, the
change in emissions as a result of this project are greater than 25 tpy.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
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 -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)
No
Yes
SO2 NOx CO VOC
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)
No
NOx CO
PM2.5
PM10 TSP HAPs
VOC PM2.5 PM10 TSP
HAPs
Separator Venting Emissions Inventory
005 Separator Venting
Facility AIRs ID:
123
County
9FF7
Plant
005
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Natural gas venting from two (2) heater treaters during vapor recovery unit (1.RU) downtime.
Enclosed Combustors)
Limited Process Parameter
Gas meter
Natural Gas Vented
Yes, meter will be installed wit"180 da
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
0.7 MMscf per year
Requested Permit Limit Throughput =
0.900 MMscf per year
Requested Monthly Thres.ghput =
0 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU: Yes
Is VRU process equipment: Yes t. s s Uncontrolled and controlled emissions used to establish -equested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
0.9CO MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas High Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
2000 Btu/scf
113.8 scf/bbl
Description
The three wells at this facility produce to two (2) inlet three-phase separators. Condensate from the three-phase separators is routed to two (2) three-phase heater treaters for further separation. The gas from the three-phase separators is always routed to a
sales pipeline. During normal operation gas from the three-phase heater treaters is captured using a vapor recovery unit and routed to the sales pipeline. During VRU downtime, gas from the three-phase heater treaters is routed to the enclosed combustor(s)
to be controlled. A site -specific pressurized three-phase heater treater gas sample was obtained from the Brnak 01N -64,N-10 Production Facility on 03/01/19. The temperature and pressure of the sample are 110`F and 17 psig respectively. The weight %
values and gas molecular weight from this sample along with the displacement equation (shown below) were used to estimate emissions from this source.
MW
35.2037
Weight °•A
Oxygen/Argon
0.04
H25
0.00
CO2
2.61
N2
0.26
methane
15.74
ethane
17.36
propane
30.84
isobutane
5.11
n -butane
15.10
isopentane
3.51
n -pentane
4.17
cyclopentane
0.34
n -Hexane
1.03
cyclohexane
0.27
Other hexanes
L88
heptanes
0.66
methylcyclohexane
0.26
224 -TM P
0.00
Benzene
0.16
Toluene
0.11
Ethylbenzene
0.01
Xylenes
0.03
Octanes
0.28
Nonanes
0.03
Decanes
0.19
Total
VOC Mole %
100.00
63.937
Ib/Ib-mol
Displacement Equation
Ex=Q*MW"Xx/C
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
Emission Factor Source
(lb/MMscf) (Ib/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
59356.5922
2967.8296
Extended gas analysis
Benzene
144.3036
7.2402
Extended gas analysis
Toluene
100.9265
5.0463
Extended gas analysis
Extended gas analysis
Ethylbenzene
8.9980
0.4499
Xylene
26.7159
1.3358
Extended gas analysis
Extended gas analysis
Extended gas analysis
≤.. ; a Extende I gas analysis
n -Hexane
956.2976
47.8149
224 IMP
0.3711
0.0186
H; S
0.0000
0.0000
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(Ib/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
14.893
AP -42 Table :4-2 (PM10/PM.2.5)
AP -42 Table 2.4-2 (PM10/PM.2.5)
AP -42 T?,ble 1.4-2 (SOx)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 133 Industrial Flares (CO)
PM2.5
0.0075
14.893
SOx
0.0006
L176
NOx
0.0680
135.966
CO
0.3100
619.847
Heat Value Calculation
Ccr-
1':- tFtj/scfl
!•: (.5t.L1,/4:Cf)
Vi:
0
4:
2.089
t.
:
0.3254
C
-nethant:
909.L
34.529
1010
.=thane
1612 :
20.3287
1769.7
`ronane
2c:..
24.623
2516.:
sobuta^e
SCOC.•4
3.0947
325_
-butane
3010.S
9.1481
31Y:. .
,eoentane
'F=='
1.7149
4C:
n -pentane
3?''
2.0354
4005.7
0ycF pentan•
351;
0.1706
3763.6
;ycichexane
4179.'
0.1137
•--':'..1.,
-!exanes cheating value cf n -Hexane`:
:-1:13.3,
0.7667
.:756
~,entanes
f .IC-i
0.2315
5502.5
`dlethylcyclohexsne
4 • •
0.093
5215.S
.Jctanes+
=7�-
0.0853
6248.9
'';onares
6493.:
0.0091
.'6.::
-}ecanes+
7189.E.
0.0478
-74.
3enzene
3590.E
0.0704
3741.E
-aluene
4273.'
0.0416
4474.9
Ethylbenzene
4970.-1
0.0032
522:
!:t;le nes iAyq of a. M. !; xylene)
4957..
0.0095
20S 7
titans,.
4403.`.
0.4211
.:75C.
`V. , _ -iV/HHV of iscectanei
5? .
0.0001
cc.._
0
,_ow er Heating Value of Gas
1313.528915 Etu/sct
-tighter Heating Value of Gas
1977.784.832 Btu/set
2of5
K:\PA\2018\18WE1034.CP1
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
sox
NOx
VOC
CO
0.01
0.01
0.01
0.01
0.01
1
0.01
0.01
0.01
0.01
0.01
1
0.00
0.00
0.00
0.00
0.00
0
0.06
0.05
0.05
0.06
0.06
10
26.71
21.67
1.08
26.71
1.3355
227
0.23
0.23
0.23
0.28
0.23
47
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibis/year) (lbs/year)
Actual Emissions
Uncontrolled Controlled
(tpy) (tpy)
Requested Permit Limits
Uncontrolled Controlled
(tpy) (tpy)
Benzene
Toluene
130.32
105.71
5.29
130.32
6.52
0.052853323
0.002642666
0.065161631
0.003253082
90.33
73.63
3.63
90.23
4.54
0.036338191
0.00184191
0.045416947
0.002270847
Ethylbenzene
8.10
6.57
0.33
8.10
0.40
0.003284287
0.000164214
0.004049121
0.000202456
Xylene
24.04
19.50
0.98
24.04
1.20
0.009751286
0.000487564
0.012022133
0.000601107
n -Hexane
860.67
698.10
34.90
860.67
43.03
0.349048628
0.017452431
0.430333925
0.021516696
224 TMP
0.33
0.27
0.01
0.33
0.017
0.000135435
6.77173E-06
0.000166974
8.3487E-06
H25
0.00
0.00
0.00
0.00
0.000
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a as sample to estimate emissions? Yzs
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the
facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis
to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
No'
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point?
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to
exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (sc/bbl) value in section 03.
No
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 cf the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer
3 of 5 K:\PA\2018\18WE1034.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
1. Based on the application, three wells produce to this facility. The well names and API numbers are as follow: (i) Name: Brnak 01-64-10-1H, API #: 05-123-45000, (ii) Name: Brnak 01-64-10-2H, API #: 05-123-44996 and (iii) Name: Brnak 01-64-10-3H, API #: 05-123-
44997. According to COGCC information, each of the wells was fractured in February of 2018 and began production in Ju-ie 2018. The wells have not been re -fractured, re -completed or modified in any way since they first began production. Additionally, no new wells
have been drilled or brought on-line at this facility. Since the wells began production after 08/01/2014, the gas coming off the separation equipment is subject to CO AQCC Regulation 7, Section XVII.G.
-, Tt�a✓R SS M".� 1x0.. E t S1 1 -... � <"' ..._: r..f: F Y...• .. �N�..: ., .tL.. R.....S .^ f ti� .:L 5 �
. _, ...,.. ..sfs,.......�..?@...�..;&..a ..,...,.,, v;?;:.:. ..... s, .v>,. .... , �....<..:.. .,. .; ..,: <. sr .. �:.... s .,,;..5 ..,. ,,.., w.,., ,.....:,r :•;> �r.;:. ,.:
2. According to the operator, a flow meter is not currently installed and operational at the facility. Until the flow meter is installed, the operator will be required to monitor and record condensate produced through the heatertreaters during vapor recovery unit
downtime and estimate the gas flow rate based on the standard cubic feet (scf) of gas per barrel (bbl) of condensate est mated in the permit application and listed in Section 03 above. The operator has 180 days to install the flow meter required by the permit.
According to the application, the flow meter will measure the total heater treater gas that is routed to and controlled by the enclosed combustor.
3. During normal operation, gas vented from the heater treaters is sent to a vapor recovery unit (VRU) that directs the gas to a sales pipeline. During VRU downtime, heater treater gas is routed to and controlled by an enclosed combustor. The volume of gas that is
routed to the enclosed combustor from the heater treaters is measured using a flow meter. This flow meter only measu-es the volume of gas that is routed to the enclosed combustor. The flow meter does not track any volume of gas that is routed to the saks
pipeline via the VRU. Since the volume of gas measured by the flow meter is independent of VRU downtime, the operator will not be required to track VRU downtime to demonstrate compliance with the permit limits.
4. The sample used to establish emission factors and calculate emissions for this source was obtained from the Brnak 0=N -64W-10 Production Facility on 03/01/2019. This sample was obtained within one year of application submission. Additionally, the sample is
site specific and the wells have not been modified since the sample was obtained. As a result, the permit will not contair an initial test requiring the operator to obtain a site specific sample to demonstrate initial compliance.
5. N -Hexane is the only HAP that has reportable emissions (i.e. greater than 250 lb/year). As a result, it is the only HAP fir which an emission factor is included in the permit.
6. The O&M plan submitted for this source indicates visible emission observations will occur on a weekly basis. In the ent smoke is observed during the visible emissions observation, the operator is required to either shut in and conduct repairs immediately or
conduct a formal method 22 opacity test. In the event the operator chooses to conduct a method 22 and visible emissions are observed, the operator is required to conduct repairs immediately or shut in until repairs can be completed. Since this is the Division
approved methodology for demonstrating ongoing compliance with the opacity requirements, the permit will not contain periodic opacity testing.
7. The heat content provided by the lab on the gas analysis (1,999.506 Btu/scf) was used to calculate combustion emissions. The heat content calculation in this analysis simply provides a reference for the heat content calculation methodology.
8. According to the application, the total gas produced by the heater treaters is 36.5 MMscf/year. Using this informatior, the GOR used to initially demonstrate compliance with the permit limits was calculated as follows: (36.5 MMscf/year)'(1,000,000
scf/MMscf)/(320,835 bbl/year) = 113.766 scf/bbl. Using the maximum requested liquid throughput (385,002), an assumed VRU downtime of 2% and the GOR, the gas vented from the heater is calculated as follows: (385,002 bbl/year)*(113.766
scf/bbl)'(0.02)/(1,000,000 scf/MMscf) = 0.88 MMscf/year. This calculation simply demonstrates the specified GOR correlates to the requested gas throughput based on the requested liquid throughput. In practice, the operator will track the volume of liquid
produced through the heater treaters during vapor recovery downtime and multiply this volume by the GOR to demonstrate compliance with the throughput limit in the permit. This calculated volume is then multiplied by the emission factors in the notes topermit
holder section to demonstrate compliance with the emission limits. This calculation methodology will only be used until the gas meter required by the permit is installed.
9. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator ret iewed both documents and expressed they had no comments.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
005
Process # SCC Code
01 3-10-001-60 Flares
Pollutant Uncontrolled Emissions Factor Control% Units
PM10 13.tiO 0 Ib/MMSCF
PM2.5 14.90 0 Ib/MMSCF
SOx 1.18 0 lb/MMSCF
NOx 135.97 0 Ib/MMSCF
VOC 59356.59 95 Ib/MMSCF
CO 619.85 0 Ib/MMSCF
Benzene 144.80 95 Ib/MMSCF
Toluene 100.93 95 Ib/MMSCF
Ethylbenzene 9.00 95 ib/MMSCF
Xylene 26.72 95 Ib/MMSCF
n -Hexane 956.30 95 lb/MMSCF
224 TMP 0.37 95 lb/MMSCF
4 of 5 K:\PA\2018\18WE1034.CP1
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation3 Parts A and B - APEN and Permh Requirements
1
t source is in tha Non. At elnmunt Area
ATTAINMENT
1. Are uncontroled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3. Part A, Section II 0.1.a(7
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TRY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section I1.0.3)'
You hew Indicated that source is in the flan -Attainment Area
NON -ATTAINMENT
Are uncontroled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section II 0.1 alt
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOr greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B. Section II.D.2N
Ye;
Yes
Source requires a pelmet
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 20147
'Source Is subject to Regulation 7. Section XVII.B.:, G
Section XVI.B1—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XV II.G - Emissions Control
Alternative !TWO'S one Control (Optional sect long
a. Is this separator controlled by a back-up or alternate combustion device ll.e., not the primary control device) that Is not enclosed?
lb. control rievicit for this separator is not whoa to Rq;utatlon 7. Section SVii.8.2.e
Section XVIl.81.s - Alternative emissions control equipment
Disclaimer
This document assists operators wth determining applrcablrty of certain requirements of the Clean Air Act its implementing regulations, and Air Quality Control Commission regulations This document
is not a rule or regulation, and the analysis rt contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any
law regulation or any other legally binding requirement and rs not legally enlonuabb. In the event of any coedit! beMeen the language of this document and the language of the Clean At Act., its
ntpiementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation rill control The use of non -mandatory language such as -recommend. "may.'
'should.' and -can,' is intended to describe APCD interpretations and recommendations Mandatory terminology such as -must- and -required' are intended to describe controlling requirements under
the terms of the Clean Arr Act and Air Quality Control Cormxsscon regulations but this document does not establish legally binding requirements in and of itself
Source Requires an APEN. Go to the ne.t question
Source Requires a permit
yes l source is subject go to next question
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE 1034 Issuance:
Verdad Resources LLC
1
Facility Name: Brnak 01N -64W-10 Production Facility
Plant AIRS ID: 123/9FF7
Physical Location: NWNW SEC 10 T1 N R64W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS `
Point
Equipment ' Description
Emissions Control.
Description
HT-VENT01
005
Natural gas venting from two (2) heater
treaters during vapor recovery unit (VRU)
downtime.
Natural gas is routed
to and controlled by
enclosed
combustor(s) during
VRU downtime
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1 YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit: Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
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.)
F.4. )
4. Within one hundred and eighty days (180) after issuance of this permit, the operator shall install
a flow meter to monitor and record volumetric flow rate of natural gas vented from each heater
treater covered by this permit. Until the flow meter is installed, the operator shall monitor and
record condensate produced through the heater treaters during vapor recovery unit downtime
and estimate the gas flow rate based on the standard cubic feet (scf) per barrel (bbl) of 113.8
scf/bbl estimated in the permit application.
5. 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.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (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
HT-VENT01
005
---
---
1.4
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Compliance with the annual limits, for criteria pollutants, shall be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
based on the previous twelve months' data. The permit holder shall calculate actual emissions
each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Heath fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
HT-VENT01
005
Natural gas from the heater treaters is
routed to the enclosed combustor(s)
during vapor recovery unit (VRU)
downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to. the Division for inspection upon request. (Regulation Number 3, Part B, Section
II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
HT-VENT01
005
Natural Gas Venting
0.9 MMSCF
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 ite or at a local field office with site responsibility, for Division
review.
10. Upon installation of the flow meter, the owner or operator shall continuously monitor and
record the volumetric flow rate of natural gas vented from the heater treaters and routed to
the enclosed combustor(s) using an operational continuous flow meter. The owner or operator
shall use monthly throughput records to demonstrate compliance with the process limits
contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation from
any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either
be routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING a MAINTENANCE REQUIREMENTS
15. Upon startup of this point, the owner or operator shall follow the most recent operating and
maintenance (OEM) 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 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
Section II.C.)
.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
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
Whenever new control equipment is installed, or whenever a' different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health 8 Envc01anent
Dedicated to protecting and improving the health and environment of the people of Colorado
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
Harrison Slaughter
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Permit for natural gas venting from two (2)
heater treaters at a new synthetic minor oil and
gas well production facility.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Facility
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
HT-VENT01
005
Benzene
71432
131
7
Toluene
108883
91
5
Ethylbenzene
100414
9
1
Xylenes
1330207
24
2
n -Hexane
110543
861
43
2,2,4-
Trimethylpentane
540841
1
0.1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
VOC
59,356.59
2,967.83
Gas Analysis
110543
n -Hexane
956.3
47.81
Gas Analysis
Note: The controlled emissions factors for this point are based on the enclosed combustor
control efficiency of 95%. The VOC and HAP emission factors listed above are based on
a site specific heater treater gas sample obtained on 03/01/2019. The sample
temperature and pressure are 110°F and 17 psig respectively. The VOC and HAP emission
factors were determined using the weight % values and gas molecular weight (35.2037
lb/lb-mol) from the gassample analysis in conjunction with the EPA Emission Inventory
rriprovement Program Publication: Volume II, Chapter 1Q- Displacement Equation= (10.4-
3
6) In accordance with ,C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days, before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.,E
7) This facility is classified as follows:
Applicable
Requirement
Si
atus
Operating Permit
Synthetic Minor Source of: VOC
PSD and 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
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Harrison Slaughter
Package #: 395127
Received Date: 3/25/2019
Review Start Date: 4/2/2019
Section 01 - Facility Information
Company Name: Verdad Resources LLC
County AIRS ID: 123
Quadrant
Section
Township
Range
NWNW
10
1N
64
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
9FF7
Brnak 01N -64W-10 Production Facility
NWNW quadrant of Section 10, Township 1N, Range 64W
Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? I I Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001
Condensate Tank
TK01-08
Yes
19WE0247
1
Yes
Permit Initial
issuance
Cancel GP01 w/
permit
Section 03 - Description of Project
Verdad Resources LLC (Verdad) submitted an application requesting permit coverage for condensate storage vessels at a new synthetic minor oil and gas well production
facility located in the ozone non -attainment area.
This source is APEN required because uncontrolled VOC emissions from the source are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section II.B.3.a.). Additionally, the source is permit
required because uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC Regulation 3, Part B, Section II.D.2.a.). With this application, the
operator is requesting to cancel the GP01 coverage for this source upon issuance of the individual permit.
Public comment is required for this source because new synthetic minor limits are being established at the facility in orderto avoid other requirements. Additionally, the change in emissions
as a result of this project are greater than 25 tpy.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement:
Was a quantitative modeling analysis required? 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)
SO2
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)
No
Yes
NOx CO
No
NOx CO
i _
VOC PM2.5
PM10 TSP HAPs
VOC PM2.5 PM10 TSP HAPs
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
Facility AIRs ID:
123
County
9FF7
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Eight (8) 400 barrel fixed roof condensate storage vessels connected via liquid manifold.
Enclosed Combustor(s)
95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
320,835 Barrels
(bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
320,835 Barrels (bbl) per year
Requested Permit Limit Throughput =
385,002 Barrels
(bbl) per year
Requested Monthly Throughput =
32699 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput
Secondary Emissions - Combustion Device(s)
Heat content of waste gas
Volume of waste gas emitted per BBL of liquids
produced =
385,002 Barrels
2288.32 Btu/scf
28.7486 scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
(bbl) per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Pilot Light:
Pilot Light Rate: 30 scf/hr
Pilot Light Heat Content: 1454 Btu/scf
Annual Pilot Light Rate: 0.268 MMscf/year
Requested pilot light Heat
content routed to
combustion device: 32 .1112 MMBtu/year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
E&P Tank Throughput =
320,835.00
bbl/year
Pollutant
Simulation
Emission Rate
VOC
353.33
tpy
Benzene
0.591
tpy
Toluene
0.39
tpy
Ethylbenzene
0.054
tpy
Xylene
0.111
tpy
n -Hexane
3.81
tpy
224 TMP
0.043
tpy
21,106 MMBTU per year
25,328 MMBTU per year
25,328 MMBTU per year
Emission Factors
Condensate Tank
Emission Factor Source
Uncontrolled Controlled
Pollutant
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
2..LDD.S
1.101E-01
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Benzene
3.684E-03
1.842E-04
Toluene
2.431E-03
1.216E-04
Ethylbenzene
3.366E-04
1.683E-05
Xylene
6.919E-01
3.460E-05
n -Hexane
2.375E-02
1.188E-03
224 TMP
22.681E-04
1.340E-05
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMBtu) (lb/bbl) i
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
4.90E-04
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table L4-2 (PM10/PM.2.5)
AP -42 Chapter 13.S industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
4.90E-04
NOx
0.0680
4.47E-03
CO
0.3100
2.04E-02
Pollutant
Pilot Light
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMscf) (Ib/MMscf)
(waste gas
combusted)
(waste gas
combusted)
PM10
7.6000
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-1 (NOx)
AP -42 Table 1.4-1 (CO)
PM2.5
7.6000
NOx
100.0000
CO
84.0000
_. -.,' .
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
424.00
353.33
17.67
424.00
21.20
3601
PM10
0.10
0.08
0.08
0.10
0.10
16
PM2.5
0.10
0.08
0.08
0.10
0.10
16
NOx
0.88
0.74
0.74
0.82
0.33
149
CO
3.94
3.29
3.29
3.94
3.94
670
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 IMP
1118.40
1182.00
59.10
1418.30
70.92
936.00
780.00
39.00
936.00
46.30
129.60
108.00
5.40
129.60
6.48
266.40
222.00
11.10
266.40
13.32
9144.00
7620.00
381.00
9144.00
457.20
103.20
86.00
4.30 _
103.20
5.16
2 of 4
K:\PA\2019\19WE0247.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 06 - Regulatory Summary Analnsis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
NSPS 0000a
Storage Tank is not subject to NSPS 0000a
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
N/A - operator developed site specific emission factors.
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
1. Three (3) wells produce to this facility. According to COGCC data, these wells were fractured in February 2018 and have a reported first production date in June 2018. Please see the APEN submitted
on 03/25/19 for a list of the well names and API numbers.
2. The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with E&P Tank 3.0. The pressurized liquid sample was obtained from the
outlet of the heater treaters on 07/12/2018. The sample temperature and pressure are 96'F and 30.5 psig respectively.
3. NOx and CO emissions were calculated using a GOR of 28.7486 scf/bbl and heat content of 2,288.32 Btu/scf. The heat content and GOR were obtained from the E&P tank simulation used to estimate
site specific emission factors. It should be noted that total NOx and CO emissions calculated in this analysis include emissions associated with pilot light combustion. The pilot light is rated at 30 scf/hr.
The heat content used for pilot light combustion emissions calculations is 1,454 Btu/scf. Since pilot light combustion contributes to the total CO emission limit, the permit will contain a process limit on
pilot light combustion as well as emission factors for calculating emissions associated with pilot light combustion.
4. Ethylbenzene and 224 TMP emissions are below APEN reporting thresholds (i.e. < 250 lb/year). As a result, emission factors for these pollutants will not be included in the permit.
5. The operator was provided with a draft permit to review prior to public comment. The operator reviewed the draft and expressed they had no comments.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
001
Process #
01
SCC Code
404-003.11 Fixed Root Tank, Condensate, working+breathing+flashing losses
Pollutant
PM10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethyl benzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.01
0.01
0.11
52.4
0.49
0.09
0.06
0.01
0.02
0.57
0.01
Control %
0
0
0
95
0
95
95
95
95
95
95
Units
lb/1,000 gallons
lb/1,C00 gallons
lb/1,000 gallons
lb/1,C00 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
3 of 4 K:\PA\2019\19WE0247.CP1
Condensate Tank Regulatory An*. Worksheet
Gatorade Regular". 3 Parts ft ond - MEN and ?emit frarettrarrento
'Seam fmthe Namntta,nre...
ATrAINMENT
1. Azeureontmlld actual eNzzlaafram ay corms pollutants from twmdramual seureereate,hen 2rvf lPegu6uons, parts, Seamrll.O.tali
2. Is the carob-erten u lre^Idate)', 1a/30/2002 ner12/21/2002 Gees gurdanceen®anaa,F pp 10817
3. Aretetal fammancanmldaoeemraa)Ragreater tmnsTPY, no. ,man mTprarCOemlssma titUtxIXan10TPY'xegul 'Regulation tetionIl�o additional
NOIGATIAINIVIENT
Z. Are unnmmlldmistan from any rotes p= adz barn Ibis rderauarso a ,.than l my(RegulO A. sat.,))sash
2. Is the constructron date faevrcedate)erew12/3rylnua and not muddied after 12/11/2002 Gee PSMemaosaa nxlmrall anda.aaand srcran Voradanronal gulaance ganMaMerappllrabory)>
ererotal fad, uncontrolledarcs greater than 2Try, NOz greater than s der or DO emission greater than IOTEV tPaubtten3.Part .P,sation
'Source exedras
1. Colorado
tank leered In tihe GermanemMal area erany Waite non...tr... area°rat.. metama
2. Is star,. tanIcIocatecl at an all and gm wploratran and prduat elan,naturalgas co,npressor,taeonarnawmlgas drip station-,
3. 1st. storageank loud upstram,a natural as p ecessrncdantt
sedan XltP-PemNkeeprnga,b Report.,
Colorado 'Mon Section XII.G
. is tNssterage tank located eta natural as nmmsaeng plant?
3. Does 'Flash' nenslaMltd),Lids) emesmnu and balm uncontrolled actual emesbn gra[etran agraka2 tans oevarvoci
M1b I Storager.ia nItsuigeet RegulattonT.seroan Xn.G
Sect., -Gene, Rep. -erne. Oar PfrPollutton Control Equipment -PravertOon Leatrage
,lore
on/ao
2. I.Its cander,ate.aragetanO•lacatetl at an a an.. gas loa[bn and p udl operation wdlproduction faallry,natural gas comaasaahtton ocnwmlgazprsasrng paNi
3. Is this cantlematestoragetank Ned reastarageiank?
Yes
AMC
yea
Continue -You Fare determined siltyet[alnmentstatusen[be Protect summar/dor,.
StorageTanklsootauhrect to Regulation T.snlonwl.G-you Fare indicated fade, type on protect summon. sheet.
0611*
a
Sadden trelt.G.1 -Pkisslons Control and Itioneorted Provisions
S. ooes[he condensate smagetankanarmmrybgl,iz ^!M.!T
Ica rkassubronmaeg.wlen,SeNana^m:e2
Section XVll.e.2-.pure and Manhunnr}cosorageTa W.sfmd with a'rpollutbn.nd eautpme,t
40 Part 60,Subaart . Standards of Perrarmarm for valaN.deaNcuamdsumm vessel.
1. Is the drvrdual mngevessel opaelty goterman arenual to 7s alb metes fm) ra>353LO
H. meet the fogawma emptbmn 60.a1blduX)7
3. FbDoes theversa ms a ddgn macity less than arcequal b 1,se3.®a m [-10.060 660 used marpetmeums or anansate:teed. processed, errtreated priorto custody tender as defined b 60.111,,
wsdew ank, nd lseedellnnronsaO 46, 0.2)ak lulvae, R 7
r, oaettbemnkmeet meaefInklon ar,torage vessel'iin 60.1.11,.
6. Does thestorageyasel facet anyoneatherollowing adltaonalamptbu:
a. Is Me storaegvessd a e designer! Pa[2a tip and nron atmosphere f60.120b1d1¢11.or
ms�PO Baldan reeales Va [60.21ayb))t: or
c merleen apacky is grea,ertbn or equal to>s ma ra>a PPtl but less r3s0 BBL] and aonnalle NwttM1 a maxim...rue vapor pressure' less[han16.0 kpaf60.110b@lli
IStorageTank 2. 3322.22 22. 22 3PM Kb
§60.222,-6dssbn Control Standards heyo0
4.0.1136-Testrno ndamadares
ee0.2ab . P opening met Renrekemmg Rmmrements
§60.116,-MongOang ofoperaans
cF, Parts, subpart ease. standee, of dermas m.crude on and Natural Gas Proauarar ltarr sionandDist.,wan
1. ..15 condensate .0r,, vsel located at a fr,bty rn the onshore ml and ....alga Production seen e,t, naturll gas pre... segment arc v Aa l gas t anm'ssin a d staaCe MM.,* rnd,etq,'
2. was this candansatert.ragev¢sel constructed, a nd)see sOal,awa got x3,2011 an xptm,a1e,20ss7
3. Arepotenffal e=aesdheintl uarstaro „ raterMan
°req.lato6ren per year, sseltt per 302
s. la the �uaattoand rord,ored�n accordance.. le Iremetsfantera eves. 40RR.a60Sub art Kb orXOcm Partbssmwrtxry
Ig rmlea
pa§s2saa,Table3
§ensus eralssm Tantral Standards foryM
§.0.5413 -Torero and Procedure
§s0.s3aslrd-R uakawngaequraments
§6n.6416fcl-.,AarnCtseed Vent systmmwnnadng Regmaments
00.5417 ...naDevice Monitenng vegalremernz
Mat.., subject NSP:0000due ta emissiom.0mm a, Pew Vacan, pp bR'tydetomantbndaa. it should ram...bier:no rars moaner ,3aueu2)
even if Pa mal�acminaoreeropbelowwr6tam par yearl
rm d(me derrnItans CR, 601) aftereeptmber 1L20137
2. Does thilx condensate sterageuesselmeet:betlef arua'stoage...se!' per 3w7
s bat,. In get p esng segment or natural gas tansmbsln and ssmsesegm tofthe and r,
4. potential voce, em'ssfrom todtndWuaataageversel grearetman or Buz to 6 w.nperrca,a
6. Istheetaageveeal zuhieatto and umrated InaueNancewith r"urrementz forstorage vessels rn qO RRPan w Subpart Xaar 40C.Part GasubpartHM
IstamgeTexua,etsubiaatta RPVRomo.
OUR. Part 63.6uhpart µOCT FN. Oa and tles
1. Is the s an elland naamPat omdudornfarnetythat meets etherofthefollowlnacatena:
a. Arac3l,ythapmaessa, pgadne,stnreshydrcoarbo r r1s3.T63fVIRll:O3
b. mow muasse, upgrades orstares natural Ras paarwthe Ppinta, vbkhnataol gas enters .tile natural gas transmission annsteagesauRa1eaarverrsdel.erdtea rroled rserla3.T6g1a11am
hclIfty tmV is matorferHAPKT
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4. Does tbetank meet [...nit.of•storeevaselwkbtbepaetbl!calash ...dona•ax �617
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Disclaimer
Thu RV/3document assists operators wM determining ...Mayor req...&MeClean AtrAclt Ps implement. rreg... and Hir.Handy Ca7tml Commtrsionttguladau. This document
is a 'e.g... and Oman.. it CWlmdns ma....toa rail... 'Walton basedthe. ...at Xaets antlgimumzfarces. This dsurrwnt does not charge a so.atore for any
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dageTankts no, suaet HPps 16-Thestaage vessel opacity's below [heappgabethremb.
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COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE0247 Issuance: 1
Date issued:
Issued to: Verdad Resources LLC
Facility Name: Brnak 01N -64W-10 Production Facility
Plant AIRS ID: 123/9FF7
Physical Location: NWNW SEC 10 T1 N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK01-08
001
Eight (8) 400 barrel fixed roof condensate
storage vessels connected via liquid
manifold.
Enclosed
Combustor(s)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1 YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
Page 1 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
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
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ` ID
AIRS
Point
Tons Per Year
Emission
Type
PM2.5
NO ,t
VOC
CO
TK0108
001
---
---
21.2
4.0
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria 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.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK01-08
001
Enclosed Combustor(s)
VOC and HAP
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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, Section
II .A.4. )
Process Limits
Facility
Equipment
ID
AIRS
Point
Process
Process Parameter
Annual Limit
TK01-08
001
01
Condensate
Throughput
385,002 barrels
02
Combustion of pilot
light gas
0.3 MMSCF
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all
applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Section XII.C.) (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.17; 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
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Pubic Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available
to the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
15. Upon startup of this point, 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
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
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. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Permit
Number
Existing
Emission Point
New Emission Point
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
G P01
123/9FF7/001
123/9FF7/001
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or activity;
or
Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B).
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit isa material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shalt constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter
Permit Engineer
Permit History
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Permit for eight (8) condensate storage vessels
at a new synthetic minor oil and gas well
production facility.
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder 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
1,419
71
Toluene
108883
936
47
Ethylbenzene
100414
130
7
Xylenes
1330207
267
14
n -Hexane
110543
9144
458
2,2,4-
Trimethylpentane
540841
104
6
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Process 01: Condensate Throughput
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
CO
2.04x10"2
2.04x10-2
AP -42 Chapter
13.5
VOC
2.2
1.1x10"1
EttP Tank 3.0
71432
Benzene
3.68x10-3
1.84x10-4
108883
Toluene
2.43x10-3
1.22x10-4
1330207
Xylene
6.92x10"4
3.46x10"5
110543
n -Hexane
2.375x10-2
1.188x103
Note: The controlled emissions factors for this point are based on the enclosed cornbustor(s) control
efficiency of 95%. The site specific emission factors for this source were developed using a site
specific pressurized liquid sample in conjunction with EftP Tank 3.0. The pressurized liquid
sample was obtained from the outlet of the heater treaters on 07/12/2018. The sample
temperature and pressure are 96°F and 30.5 psig respectively. Actual VOC and HAP emissions
are calculated by multiplying the emission factors in the table above by the total condensate
throughput. The AP -42 Chapter 13.5 CO emission factor (0.31 lb/MMBtu) in the table above was
converted to units of lb/bbl using a GOR of 28.75 scf/bbl and a heat content of 2,288.32 Btu/scf.
Actual CO emissions are calculated by multiplying the emission factor in the table above by the
total condensate throughput.
Process 02: Combustion of pilot light gas:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/MMSCF
Controlled
Emission Factors
lb/MMSCF
Source
CO
119.74
119.74
AP -42 Chapter
1.4 Table 1.4-1
Note: The CO emission factor in the table above was converted to a heat content of 1,454 Btu/scf by
multiplying the AP -42 Chapter 1.4 Table 1.4-1 CO emission factor (84 lb/MMscf) by a ratio of
1,454 Btu/scf to 1,020 Btu/scf. Actual emissions are calculated by multiplying the emission factor
in the table above by the total fuel combusted by the pilot light. Pilot light fuel is based on a
constant rate of 30 scf/hr.
Total actual CO emissions are obtained from the sum of CO emissions resulting from the combustion
of storage vessel waste gas which is a function of condensate throughput (process 01) and the
combustion of pilot light gas (process 02).
Page 9 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR and PSD
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
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
Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Harrison Slaughter
Package #: 395127
Received Date: 3/25/2019
Review Start Date: 4/3/2019
Section 01 - Facility Information
Company Name: Verdad Resources LLC
County AIRS ID: 123
Quadrant
Section
Township
Range
NWNW
10
1N
64
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
9FF7
Brnak 01N -64W-10 Production Facility
NWNW quadrant of Section 10, Township 1N, Range 64W
Weld County
Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
003
Liquid Loading
TL001
Yes
19WE0248
1
Yes
Permit Initial
Issuance
Cancel GP07 w/
permit
Section 03 - Description of Project
Verdad Resources LLC (Verdad) submitted an application requesting permit coverage for condensate loadout at a new synthetic minor oil and gas well production facility located in the ozone
non -attainment area.
This source is APEN required because uncontrolled VOC emissions from the source are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section II.B.3.a.). Additionally, the source is permit
required because uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC Regulation 3, Part B, Section II.D.2.a.). With this application, the
operator is requesting to cancel the GP07 coverage for this source upon issuance of the individual permit.
Public comment is required for this source because new synthetic minor limits are being established at the facility in orderto avoid other requirements. Additionally, the change in emissions
as a result of this project are greater than 25 tpy.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement:
Yes
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2
No
Yes
NOx CO
Is this stationary source a major source? No
If yes, explain what programs and which pollutants herE 5O2 NOx CO
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
I
VOC
VOC
PM2.5 PM10 TSP HAPs
PM2.5
I
11
PM10 TSP HAPs
Hydrocarbon Loadout Emissions Inventory
003 Liquid Loading
'Facility AIRs ID:
123
County
9FF7
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Condensate loadout from storage vessels to tank trucks using submerged fill.
Emissions from this source are captured and routed to enclosed combustor(s) using vapor balance.
Requested Overall VOC & HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
Yes
100.0
95
95.00
320,835 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
320,835 Barrels (bbl) per year
Requested Permit Limit Throughpu
t=
385,002 Barrels (bbl) per year
Requested Monthly Throughput =
32699 Barrels (bbl) per month
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device
385,002 Barrels (bbl) per year
2288.32
Btu/scf
0.704 MMscf/year
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
1,612 MMBTU per year
1,934 MMBTU per year
1,934 MMBTU per year
The state default emissions factors may be used to estimate emissions.
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Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(Ib/bbl) (lb/bbl)
(Volume Loaded)
(Volume
Loaded)
Emission Factor Source
VOC
2.36E-01
1.18E-02
Benzene
4.10E-04
2.050E-05
Toluene
0.00E+00
0.00E+00
Ethylbenzene
0.00E+00
0.00E+00
Xylene
0.00E+00
0.00E+00
n -Hexane
3.60E-03
1.80E-04
224 IMP
0.00E+00
0.00E+00
Condensate Loadout State E,F.
Condensate Loadout State E.F.
Condensate Loadout State E.F.
Emission Factor Source
Pollutant
Control Device
Uncontrolled Uncontrolled
(lb/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
PM10
0.0075
3.74E-05
PM2.5
0.0075
3.74E-05
SOx
0.0006
2.96E-06
NOx
0.0680
3.42E-04
CO
0.3100
1.56E-03
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1A-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (SOx) •
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
2 of 4
K:\PA\2019\19WE0248.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
SOx
NOx
VOC
0.01
0.01
0.01
0.01
0.01
1
0.01
0.01
0.01
0.01
0.01
1
0.00
0.00
0.00
0.00
0.00
0
0.0658
0.0548
0.0548
0.0658
0.0658
11
45.43
37.86
1.89
45.43
2.27
386
CO
0.2998
0.2498
0.2498
0.2998
0.2998
51
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
157.85
131.54
6.58
157.85
7.89
Toluene
0.00
0.00
0.00
0.00
0.00
Ethylbenzene
Xylene
n -Hexane
224 IMP
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1386.01
1155.01
57.75
1386.01
69.30
0.00
0.00
0.00
0.00
0.00
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
RACT - Regulation 3, Part B, Section III.D.2.a
The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT.
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and oLtlet concentration sampling
Section 08 - Technical Analysis Notes
1. The heat input rate of loadout waste gas routed to the ECD was calculated using the following equation: MMBtu/year = [Uncontrolled VOC (ton/year)]*[2000 lb/ton)/[Molecular Weight (lb/Ib-mol)]*[379 scf/lb-
molj*[Heat Content (Btu/scf))\[1,000,000 Btu/MMBtu). The molecular weight and heat content used in this equation were obtained from the total emission stream as estimated by the E&P Tank simulation used to
estimate condensate tank emissions at this facility. The specific values for molecular weight and heat content are 40.74 lb/lb-mot and 2,288.32 Btu/scf respectively. When the state emission factors are used to
estimate emissions, a molecular weight of 65 lb/lb-mol and heat content of 2,255 Btu/scf are typically used in this equation to estimate the heat input rate. In this instance, the values used by the operator result in a
conservative heat input and thus a conservative estimate of combustion emissions. As a result, the operator provided calculations were deemed acceptable for permitting purposes.
2. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
003
Process U
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 8.91E-04 0 lb/1,000 gallons transferred
PM2.5 8.91E-04 0 lb/1,000 gallons transferred
SOx 7.04E-05 0 lb/1,000 gallons transferred
NOx 8.13E-03 0 lb/1,000 gallons transferred
VOC 5.6 95 lb/1,000 gallons transferred
CO 3.71E-02 0 lb/1,000 gallons transferred
Benzene 9.76E-03 95 lb/1,000 gallons transferred
Toluene 0.00E+00 95 lb/1,000 gallons transferred
Ethylbenzene 0.00E+00 95 lb/1,000 gallons transferred
Xylene 0.00E+00 95 lb/1,000 gallons transferred
n -Hexane 8.57E-02 95 lb/1,000 gallons transferred
224 TMP 0.00E+00 95 lb/1,000 gallons transferred
3 of 4 K:\PA\2019\19WE0248.CP1
Hydrocarbon Loadout Regulatory Analy5ls Worksheet
Were. MA pA
colon am oPs AP6 amend pami enu.ments
�Somse b En Noo-A eau ant m.
ASTAIISMENT
I. Are uvontrdled actual emissions from any acteda pollutants from this irdNWisl soars greater th.nrit, Igegulation3,Part A,5ectlon 11.0.1.12
2. fs the wt located et an exgoed. and productions. (e.&,well pad) (geguba 03. Mut B, seta, LD.1.11T
3. Is the Indoor operation losding less than 10,000 gellom 1338 BBLs)o(aWe dl par. Doan annual avenge bads?
Is the loadour operation loading less than 6,730 bbls per year of mMemsm via splash fill?
Is the load. operation Iotlng less than 16,305 labia per year of condensatevie submerged III' praetlum?
6. Aretotal facility uncontrolled vac emissions greeter mans itrA N. Amster than to TPY a c0 embeons greet.thane) TPY IReeuletlan 3, Pan 6, 1...11.0.311
(You have intl.. (bet source b int. Non.Atminmant Ana
21oNAT,AINM6Nr
L Are uncontrolled emissbn)om aayalmde pollutants from this Individual source greater tImn11PY (Regulation 3, Par[ A, Section 11,13.1.02
2. 3. Me toed05 Icmmd et an exploration and productions -Pe (e.g., well pad) (Regulation 3, Part B, Seoion II.0.L11?
Is the Ioadtt operation leading less than 10,000 gallons (338511.1 of cr. oil per day on an annual average basis?
Istla load001 operation loading less than 6,250 Mils per year ofm via splash III12
5. Is the loss. operation loading less Man 16,308 blahs pet year of condensate vie submerged fill procedure?
6. Are cot Warty uncontrolled VoCemisdans ham Me greeter Man 2 TM No -s greater than 5 TAY orm emissions greeter Man to iPY iliegulatlon 3, PartB, Seaton llb.31?
ISeume equirn a Permit
1. PAcf-. emotes°.VOCemlaioanom the loadoutepoatlo, greater than 20 tpy(Re301871 n 3, Pan ,1? 6. Section 1100.3.�ihe badoutmuu snommwhh submmgsa mean, bedem emimbn must Se routed au flare. smith PACT.
Disclaimer
This document assists 0perelos with delarminlrg applicability of carfare mquiremenfs of the Clean Per Pct its Implementing reguidroen, 200Alr quality Connor Commlsslotr2Swa(lono This cremumanfis eel
a rWen regulation, and the analysis ',contains may notarmly roe particular siltation based upon the Wicksel (solaced almumslances. Ma document does ro( change or subsea. for any lass, reglba0bn,
orany other regally binding re ime:meet end Is not legally edw0,0ble. In Sleeved danycongkf betweenlhe languagedlhls accumentard lee language verbs Clean Air Act„ its Implementing modallga,
end NrOlrallra Cmnd Commission regblaticns,Ihslarguagedtha stature or regulation will contrd, The usadrunmeMaldy language such as .recenmed,e'may."siadd; ad7an. Is lntere to
describe AACDida0pretsti0ns and ren0amemlafloa. MaMafaylenninokgy such es•musr en',sue, are into der/ todscrtbacogrdIlrg requirements under the terms d(,e Crvan A/rest at eMr
Query Control Commission regulations, 0070331 dee msd does rW establish legally Wading requirements. am desalt
A0
1,10
Go Lion.
Go to Me nestqueslon
Go to next question
Go to next question
The load. requires a permit
ins hoodoo( must operate.. submerged no end load,. emission must. rated to control msadsry RACE. If
controlled,. eARaneves Is required at provide discuss...ton B.
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0248 Issuance: 1
Verdad Resources LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Brnak 01N -64W-10 Production Facility
123/9FF7
NWNW SEC 10 T1 N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TL001
003
Loadout of condensate from storage
vessels to tank trucks using submerged
fill.
Vapor balance and
enclosed combustor(s)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1 YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
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 shallnot exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Tons per Year
Emission
Type
Point
PM2.5
NO.
VOC
CO
TL001
003
---
--
2.3
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Compliance with the annual limits for criteria pollutants shall be determined on a rolling twelve
(12) month total. By the end of each month a new twelve month total is calculated based on
the previous twelve months' data. The permit holder shall calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
6. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
TL001
003
Vapor Balance and Enclosed
Combustor(s)
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate shall be maintained by the owner or operator and made
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
available to the Division for inspection upon request. (Regulation Number 3, Part B, Section
II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TL001
003
Condensate Loaded
385,002 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
8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%
opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section 11.A.5.)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. This source is located in an ozone non -attainment or attainment -maintenance area and is
subject to the Reasonably Available Control Technology (RACT) requirements of Regulation
Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged
fill and emissions shall be controlled by a flare. (Regulation Number 3, Part B, Section III.D.2)
11. 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. (Regulation Number 3, Part B, Section III.E.)
12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to
the atmosphere including, but not limited to (Regulation Number 3, Part B, Section III.E.):
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. Inspections of all
compartment hatches at the facility (including thief hatches) shall occur at least
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Pubitc Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
monthly. Each inspection shall be documented in a log available to the Division on
request.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers shall be weighted and properly seated.
d. Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs shall be set to release at a pressure that will ensure flashing, working
and breathing losses are not vented through the PRD under normal operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of status,
a description of any problems found, and their resolution.
13. For this controlled loading operation, the owner or operator shall follow loading procedures
that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation
Number 3, Part B, Section III.E.):
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks and route the vapors to the
enclosed combustor(s) listed in the Emission Limitations and Records section of this
permit.
Include devices to prevent the release of vapor from vapor recovery hoses not in use.
Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless
the vapor collection equipment is in use.
Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
OPERATING a MAINTENANCE REQUIREMENTS
14. Upon startup of this point, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
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.
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
17. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Permit
Number
Existing
Emission Point
New Emission Point
GP07
123/9FF7/003
123/9FF7/003
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) � tons per year or more, above the level reported on the last APEN, or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. 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 actualemissions of
five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter
Permit Engineer
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Permit for condensate loadout at a new
synthetic minor oil and gas well production
facility.
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Pubhc Heath E. Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria 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
158
8
n -Hexane
110543
1,386
70
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
VOC
2.36x10-1
1.18x10-2
CDPHE PS
Memo 14-
02
Benzene
71432
4.1x10"4
2.05x10-5
n -Hexane
110543
3.6x10"3
1.8x1O4
Note: Controlled emission factors are based on the enclosed combustor efficiency of 95% and a
collection efficiency of 100%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR and PSD
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
Page 9 of 9
Condensate Storage Tank(s) APENviceivED
Form APCD-205
Air Pollutant Emission Notice (APEN) and
00 15i 9
Application for Construction Permit APO)
Stationery
S°urC°s
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
/9WFe29-7
AIRS ID Number: 123 / 9FF7 / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Brnak 01N -64W-10 Production Facility
Site Location: NWNW Sec 10 Ti N R64W
40.072546/-104.541654
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
E -Mail Address2: bganong@verdadoil.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
395124
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
Permit Number:
AIRS ID Number: 123 / 9FF7 / 001
[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
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $25O 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 name
O Change permit limit O Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Revised APEN - Cancel GP01 with issuance of Construction Permit
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
For existing sources, operation began on:
Condensate Storage Tanks
For new or reconstructed sources, the projected start-up date is: 6/27/18
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week
0 Exploration Et Production (E&P) site
52
weeks/year
O Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
GI
•
Are Flash Emissions anticipated from these storage tanks?
Yes
No
p
•
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
Yes
No
GI
■
If "yes", identify the stock tank gas -to -oil ratio:
0.0051
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
■
is
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualGI
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
COLORADO
2 I AV v"�`e s..,.. �. ,
Permit Number:
fkv9 e,O1-k-1--
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
AIRS ID Number: 123 / 9FF7 / 001
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bb(/year)
Requested Annual Permit Limit4
(bbl/year)
I Condensate Throughput:
320,835
From what year is the actual annual amount?
projected
Average API gravity of sales oil: -40 degrees
❑ Internal floating roof
Tank design: E Fixed roof
385,002
RVP of sales oil: -8.5
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in .
Storage Tank (month/year)
Date of First
Production
(month/year)
TK01-08
8
3200
06/2018
06/2018
Wells Serviced by this Storage Tank or Tank Battery5 (EFtP Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 45000
Brnak 01-64-10-1H
0
05 - 123 - 44996
Brnak 01-64-10-2H
0
05 - 123 - 44997
Brnak 01-64-10-3H
0
■
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.072546/-104.541654
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
EC01
20
1000
25
0.026
Indicate the direction of the stack outlet: (check one)
❑� Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑� Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): 54
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
�W COLORADO
3 I Mil
Permit Number:
\quOZNn-
AIRS ID Number: 123 / 9FF7 / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: MMBtu/hr
h r
Type: Enclosed Combustor
Make/Model: GCO ECD2000
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A
Waste Gas Heat Content: -2280 Btu/scf
Constant Pilot Light:❑ Yes ❑ No Pilot Burner Rating: 0.0436 MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
0 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)? —30 psig
Describe the separation process between the well and the storage tanks: produced fluids from the
wells are directed to two 3 -phase horizontal heated separators. From the separators, oil is
directed to two 3 -phase vertical heater treaters for further separation and pressure reduction.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
4 I�V COLORADO
Permit Number:
AIRS ID Number: 123 / 9FF7 / 001
[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
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combustor
95
NOx
CO
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data? projected
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
4
Emission Limit(s)
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/ ear
(Tons/year)
Controlled
Emissions?
`(Tons/year)
Uncontrolled
Emissions
Tons/ ear
(Tons/year) )
Controlled
Emissions
(Tons/year)
(Tons/ ear
VOC
2.20 •-
lb/bbl
Site Specific
353.33 -
17.67 -
424.00 -
21.20"
NOx
0.0046 .
lb/bbl
Calculated
0.74 •
0.74 '
0.88 -
0.88 '
CO
0.020 •
lb/bbl
Calculated
3.29 •
3.29 •
3.94 .
3.94 '
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service CAS
(CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Bans
Units
Source
(AP -42,
Mfg. etc)
4
Uncontrolled
Emissions
Pounds/ ear
(Pounds/year) )
Controlled
Emissions 7
(Pounds/year)
Benzene
71432
0.0037'
lb/bbl
Site Specific
1,182.00 '
59.10 '
Toluene
108883
0.0024 •
lb/bbl
Site Specific
780.00'
39.00 -
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.024 _
lb/bbl
Site Specific
7,620.00 •
381.00 •
2,2,4
Trimethylpentane
540841
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 5
AV
COLORADO
o.w..nen. c.r
h Crvv',eon me III
Permit Number:
AIRS ID Number: 123 / 9FF7 / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is
and will be operated in full compliance with each condition of the applicable General Permit.
Signature of Legally Au i5orized Person (not a vendor or consultant)
Date
Michael Cugnetti
EH&S Manager
Name (print)
Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit For more information or assistance call:
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017
6
ngB J COLORADO
Hydrocarbon Liquid Loading APEN - Form APCD-20Wj
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit MAR 2 5 2019
APcD
All sections of this APEN and application must be completed for both new and existing facilities, including APENStatioa y
updates. An application with missing information may be determined incomplete and may be returned or result igources
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if
the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on
the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
WF 244 g AIRS ID Number:
123 /9FF7 /003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: TL001
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Brnak 01N -64W-10 Production Facility
Site Location: NWNW Sec 10 Ti N R64W
40.072546/-104.541654
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 72O-845-6918
'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on
all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
395125
®Y COLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017
Permit Number: IQu OLi{C AIRS ID Number: 123 /9FF7 i 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
❑ 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 $250 must be submitted
along with the APEN Filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment ❑ Change company name
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
- OR
• APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: APEN Update - Cancel GP07 w/ issuance of Construction Permit
s For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Hydrocarbon Truck Loadout
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
06/ 27 /2018
/ /
Will this equipment be operated in any NAAQS nonattainment area?
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Does this source load gasoline into transport vehicles?
Is this source located at an oil and gas exploration and production site?
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Does this source splash fill less than 6750 BBL of condensate per year?
Does this source submerge fill less than 16308 BBL of condensate per year?
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
O Yes O No
❑ Yes O No
2i AV
Yes
Yes
O
No
No
Yes O No
Yes ❑ No
Yes
COLORADO
No
Permit Number:
V.5C pLt-k% AIRS ID Number: 123 /9FF7/ 003
[Leave blank unless APCD has already assigned a permit At and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume
Loaded4:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Bbl/yr
Actual Volume
Loaded:
2o, 35- Bbl/yr
This product is loaded from tanks at this facility into: trucks
(eg, "rail tank cars" or "tank trucks")
por
\OS Oy3 l %q
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature
of bulk liquid loading:
,F
True Vapor
Pressure
Asia @ 60 °F
Molecular weight of
displaced vapors
Lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Actual Volume
Loaded5: Bbl/yr Loaded:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Bbl/yr
Product Density: Lb/ft3
Load Line Volume: ft3/truckload Vapor Recovery Line Volume
ft3/truckload
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
®Y COLORADO
Permit Number: 'cALADE-O q AIRS ID Number: 123/9FF7/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.072546/-104.541654
Operator
Stack.ID.No
,
Discharge Height
Above Ground Level
(Feet)
Temp.
('F)
Flow Rate
(ACFM)
Yeloctty
(f00C)
EC01
20
1000
25
0.026
Indicate the direction of the stack outlet: (check one)
E Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
54
Section 6 - Control Device Information
✓❑ Loading occurs using a vapor balance system:
Requested Control Efficiency
95- 100,6
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPS
Rating:
Type: Enclosed Combustor Make/Model: GCO ECD2000
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
n/a
MMBtu/hr
95
98
Waste Gas Heat Content —2280 Btu/scf
Constant Pilot Light: El Yes ❑ No Pilot burner Rating
0.0436
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
,\; -( O, tico. ok.
NcS c7 -k1 -03I 11
®Y COLORADO
Permit Number:
IcktzEotAS
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
AIRS ID Number: 123/9FF7/003
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOx
NO.
CO
VOC
vapor balance/ CC,
10O/95
HAPs
vapor balance/EC
10095
Other:
1-Nc,1i.,C, pc/
appVccaiu,k•
1}]S
O`{g0.3I101
0 Using State Emission Factors (Required for GP07) VOC
❑ Condensate
❑ Crude
0.236 Lbs/BBL
0.104 Lbs/BBL
Benzene
0.00041 Lbs/BBL
0.00018 Lbs/BBL
n -Hexane
0.0036 Lbs/BBL
0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,5
Mfg. etc)
Actual Annual Emissions
" `
Requested Annual Permit
Emission Limit(s'5
.. - -•
Uncontrolled Tons/year)
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
Sox
NO
0.00034 '
lb/bbl
Calculated
0.055.
0.055 •
0.066 '
0.066 .
VOC
0.236.
lb/bbl
CDPHE
37.86 '
1.89 •
45.43 •
2.27 •
CO
0.0016 ,
lb/bbl
Calculated
0.25 '
0.25 .
0.30 -
0.30
Benzene
0.00041.
lb/bbl
CDPHE
0.066 •
0.0033-
0.079 •
0.0039.
Toluene
Ethylbenzene
Xylenes
n -Hexane
0.0036 •
lb/bbl
CDPHE
0.58 •
0.029 •
0.69 •
0.035 •
2,2,4-
Trimethylpentane
Other:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
Si AV
COLORADO
Permit Number:
AIRS ID Number: 123 /9FF7/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will
be operated in full compliance with each condition of the applicable General Permit.
3%2Z lq
Signature of Legally Authorize person (not a vendor or consultant) Date
Michael Cugnetti
EH&S Manager
Name (print)
Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General
Permit registration fee of $250 as applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
®Y COLORADOc
6 I
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
RECETD
SEp 2 1 2018
5cq Pcz)
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.Rov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: is INE /439- AIRS ID Number: 123 /?FF7/ o6S
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: HT-VENT01
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Verdad Resources LLC
Brnak 01N -64W-10 Production Facility
Site Location: NWNW Sec 10 Ti N R64W
40.072546/-104.541654
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address': bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
388081
(p� COLORADO
1m� _;nnon,
Permit Number:
Ictu91:103`-{ AIRS ID Number: 17-b /9FPI- 00S -
[Leave blank unless APCD has already assigned a permit d and AIRS ID]
Section 2- Requested Action
r❑ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info £t Notes: Initial Application
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
compressor downtime.
Heater Treater venting during VRU
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
06 / 27 / 2018
/ /
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation:
variable hours/day variable days/week variable weeks/year
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
0 Yes ❑ No
El Yes E No
Form APCD-211 -Nature] Gas Venting APEN - Rev 03/2017
COLORADO
2 I ///�7�
�3 '
Permit Number:
1%u)E low{
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
AIRS ID Number:
tVS'9►=Fl- OnS
Section 4 - Process Equipment Information
t1 Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
Serial #:
Capacity: Gal/min
❑ Compressor Rod Packing
Make: Model: # of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
# of Events/year: Volume per event: MMscf/event
j Other
Description: During VRU compressor downtime, gas from the heater treaters is directed to the enclosed combustor.
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
tikloks, .1r
2 No
Maximum Vent
Rate:
SCF/hr
Vent Gas3424.77.
Heating Value:
2288
BTU/SCF
Requested:
I p.c(
MMSCF/year
Actual:
CHM 01, MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
35. z-- ihttb w,0t
VOC (mole %)
LIZ, Log)
VOC (Weight %)
153 clad
Benzene (mole %)
0.01.-0L{
Benzene (Weight %)
o,LSt,I
Toluene (mole %)
a.0yt(0
Toluene (Weight %)
o.1015$
Ethylbenzene (mole %)
e,00'3t_
Ethylbenzene (Weight %)
b.cO91—
Xylene (mole %)
o o09 S
Xylene (Weight %)
0.07-g.S
n -Hexane (mole %)
0.4.01
n -Hexane (Weight %)
1,o 9
2,2,4-Trimethylpentane
(mole %)
o.a001
2,2,4-Trimethylpentane
(Weight %)
O'000Lf
Additional Required Information:
Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APBs' - Rev 03/2017
O��dt;r c ty( Jf:01,a-k_e_A Qom►;cat io& wa.Ec.r;ot .
COLORADO
3 1 m `N�.
Permit Number:
kq.u3 lO-9-k AIRS ID Number:
[Leave blank unless APCD has already assigned a permit 4 and AIRS ID]
1 /9Ff}/
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.072546/-104.541654
Operator _
Stack ID Nor-
Discharge Height
Above Ground Level
(Feet)
Temp.
('F)
Flow Rate _
(ACFM)
. Velocity
e
(ft/sec)
ECO1
20
1000
25
0.026
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
O Upward with obstructing raincap
54
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make /Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating:
Type: Enclosed Combustor Make/Model: GCO ECD2000
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
N/A
MMBtu/hr
95
98
%
Waste Gas Heat Content 8-- Btu/scf
Constant Pilot Light: ❑,r Yes ❑ No Pilot burner Rating 0.0436 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
IL,cdvs 1)1)4A -tea Ts COLORADO U
4 Kos
O3jr4la(
Permit Number:
lt7"Sy AIRS ID Number:
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
IL\ /9FF1- / 005 -
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO.
NOx
VOC
Enclosed Combustor
95
CO
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
N/A
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual
Emission Ltmit(s)s
-Permit
Controlled
(Tons/year)
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
PM
SOx
NO.
0. (34,1
ib(m✓a j
A? --I U '
0.05
0.05
0.O\0
b. OtP
VOC
5a,35b.5q
L9
Aa„wiy5i�
Zl.la}
t•Og
V.'•"\
\.3t-{
CO
o.'Sl
'Slwyttr4)
AP -41_
0.4.'5
0.1.7S
o• IS
0.2-q
Benzene
1VL{.s
tbtmwiScc
rzo`ls(S
0.0S
0.003
0.o}
0.003
Toluene
loaci
`bImrMsct
A, sk cS
,&
a .o`1
o .0Ot
0.05
o.a0t
Ethylbenzene
9.0.
ibiwt ^Sc,C
0.003
b 0002-
0.00'4
u.000'L
Xylenes
ZIo:1-L
19m✓nsct
A„a15 S 0.01
0 .0)0 5-
0.01
0. oc ov,
n -Hexane
9lsco.3
tlwvo
A-eals(sis '•NS
o.00,-
O.
o.Oti
2,2,4-
Trimethylpentane
o 3�
t�(
I rrlYt-
cxeS
^KatiSi5
0.0001.
o.aM1
0..7001-
,,.a 00k
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. ADS
Form APCD-211 -Natural Gas'✓enting APEN - Rev 03/2017 5 I
AV
COLORADO
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031011
Permit Number:
le?) u3C1c3Lt AIRS ID Number:
[Lea ie blank unless APCD has already assigned a permit " and AIRS ID]
IZ3 /9FF -' coS
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
Signature of Legally Authorized Person (not a vendor or consultant)
Michael Cugnetti
q/2//r
Date
EH&S Manager
Name (please print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
E Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form .APCD-211 -Natural Gas Venting APED - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
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