HomeMy WebLinkAbout20192074.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
May 28, 2019
Dear Sir or Madam:
RECEIVED
JUN 03 2022
WELD COUNTY
COMMISSIONERS
On May 30, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Verdad Resources LLC - Warner 01N -64W-17 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.govlcdphe
John W. Hickenlooper, Governor
'2v31
(_011O 11c)
Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
cC.:PL(-cP) iILC.Yfl
p1.1•XS IERI Grk I CV
Col 31
2019-2074
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Verdad Resources LLC - Warner 01N -64W-17 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: Warner 01 N -64W-17 Production Facility
Well Production Facility
SESW of Section 17, 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 one (1) heater treater, four (4) 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 18WE1036, 19WE0249 Et
19WE0250 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
w.u�na enmmnm.x�
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
SESW
17
1N
64
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
9FF8
Warner 01N -64W-17 Production Facility
SESW quadrant of Section 17, 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
Parts( elate 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-VENTO1
Yes
18WE1036
1
Yes
Permit Initial
Issuance
Section 03 - Description cf Project
Verdad Resources LLC (Verdad) submitted an application requesting permit coverage for separator venting from one (1) three-phase heater treater 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.).
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?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
No
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
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)
5O2
No
Yes
NOx CO
VOC
No
NOx
PM2.5 PM10 TSP HAPs
CO VOC PM2.5 PM10 TSP HAPs
f
■
Separator Venting Emissions Inventory
005 Separator Venting
Facility AIRs ID:
123
County
9FF8
Plant
005
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Natural gas venting from one (1) heater treater during vapor recovery unit (VRU) downtime.
Emission Control Device Description: Enclosed Cornbustor(s)
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Natural Gas Vented
YP , meter wllI e Irtstnfed_within 180 days
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
0.7 MMscf per year
95
Requested Permit Limit Throughput =
0.9 MMscf per year Requested Monthly Throughput =
0 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU: Yes
Is VRU process equipment: ;Yes
0.9 MMscf per year
,controlled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
2157
143.47
Description
Btu/scf
scf/bbl
The two wells at this facility produce to one (1) inlet three-phase separator. Condensate from the three-phase separator is routed to one (1) three-phase heater treater 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 treater is captured using a vapor recovery unit and routed to the sales pipeline. During VRU downtime, gas from the three-phase heater treater is routed to the enclosed
combustor(s) to be controlled. A site -specific pressurized three-phase heater treater gas sample was obtained from the Warner O1N-64W-17 Production Facility on 03/01/19. The temperature and pressure of the sample are 120'F and 28 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
37.8903
Weight %
Oxygen/Argon
0.01
H2S
0.00
CO2
2.24
N2
0.09
methane
12.71
ethane
15.52
propane
29.47
isobutane
5.61
n -butane
17.19
isopentane
4.40
n -pentane
5.40
cyclopentane
0.41
n -Hexane
1.35
cyclohexane
0.33
Other hexanes
2.30
heptanes
0.95
methylcyclohexane
0.35
224-TMP
0.00
Benzene
0.19
Toluene
0.16
Ethylbenzene
0.02
Xylenes
0.08
Octanes
0.57
Nonanes
0.17
Decanes
0.47
Total
VOC Wt %
100.CC
69.43
Ib/Ib-mol Displacement Equation
Ex = Q' MW•Xx/C
Emission Factors
Separator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
69323.7734
3400.1337
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Benzene
194.5934
9.7297
Toluene
159.1492
7.9575
Ethylbenzene
24.5613
1.2281
Xylene
82.6697
4.1335
n -Hexane
1349.8731
67.4937
224 TMP
0.6989
0.0349
H2S
0.0000
0.0000
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
16.063
AP -42 Table 1.4-2 (PM1O/PM.2.5)
AP -42 Table 1.4-2 (PM1O/PM.2.5)
AP -42 Table 1.4-2 (50x)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
16.068
SOx
0.0006
1.269
NOx
0.0680
146.644
CO
0.3100
668.525
Heat Value Calculation
''1(Et!)iscf)
.. •1!-'t
hiHV (Btu/scf)
`
0
0
CO2
0
1.9259
0
N2
0
0.12
0
methane
909.4
30.0238
1C
1618.7
19.5613
176
ine
2314.E
25.3202
251F
...ane
?^^^ S
3.6544
,''
-butane
11.2035
- :ipentane
2.3084
-.:GG.9
I?entane
2.837
-41:0?
rclopentanE
0.2231
3763
/clohexane
0.1507
--==,
,,.banes (heating value of n -He .
1.0129
••atanes
0.3585
Q2.5
athylcyciohexar
ti.;CJ.:
0.1344
5215 9
:canes+
57%
0.1899
6?48.9
-manes
r-193.2
0.0503
'396.0
;^?^_C4.
''?.c
0.1256
7743
0.0946
3741.9
luene
4273.7
0.0656
4474.9
-nylbenzene
4970.4
0.0088
-
\vlenes (Avg of o. m• o xylem
4957.1
0.0296
_-
.-Hexane
4403 7
0.5945
4756
224-TMP (LHVIHI-IV of isooctane
577.
0.0002
5231.5
2J
58n.EE
0
537.1
Lower Heating Value of Gas
1954.487137 :ul_.:
Higher Heating Value of Gas
2128.886389 Btu/scf
K:\PA\2018\18WE1036.CP1
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutant.
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
0.07
0.05
0.05
0.07
0.07
11
31.20
25.30
1.27
31.20
1.56
265
0.30
0.24
0.24
0.30
0.30
51
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)
Actual Emissions
Uncontrolled Controlled
(tpy) (tpy)
Requested Permit Limits
Uncontrolled Controlled
(tpy) (tpy)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
H.,S
175.13
142.05
7.10
175.13
8.76
0.07102659
0.00355133
0.087567029
0.004378351
143.23
116.13
5.31
143.23
7.16
0.058089474
0.002904474
0.07161716
0.003580853
22.11
17.93
0.90
22.11
1.11
0.008964875
0.000448244
0.011052586
0.000552629
74.40
60.35
3.02
74.40
3.72
0.030174457
0.001508723
0.037201385
0.001860069
1214.89
985.41
49.27
1214.89
60.74
0.492703695
0.024635185
0.607442912
0.030372146
0.63
0.51
0.03
0.63
0.03
0.000255098
1.27549E-05
0.000314504
1.57252E-05
0.00
0.00
0.00
0.00
0.00
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 gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it 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? No
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.
-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? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to
exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored arocess oarameter is r t . al gas vented. The following auesticr Rio rot reauire an answer.
i
3 of 5 K:\PA\2018\18WE1036.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
1. Based on the application, two wells produce to this facility. The well names and API numbers are as follow: (i) Name: WarnerolN-64W-17-1H, API t$: 05-123-45162 and (ii) Name: Warner 01N -64W -17-2H, API it: 05-123-45163. According to COGCC
information, each of the wells was fractured in April of 2018 and began production in June 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.
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 heater treater 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 estimated 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 treater 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 treater is measured using a flow meter. This flow meter only measures the volume of gas that is routed to the enclosed combustor. The flow meter does not track any volume of gas that is routed tothe
sales 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 Warner 01N -64W-17 Production Facility on 03/01/2019. This sample was obtained within one year of application submission. Additionally, the
sample is site specific and the webs have not been modified since the sample was obtained. As a result, the permit will not contain 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 for 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 event 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 (2,156.5324 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 treater is 36.5 MMscf/year. Using this information, the GOR used to initially demonstrate compliance with the permit limits was calculated as follows: (36.5 MMscf/year)'(1,000,000
scf/MMscf)/(254,405 bbl/year) = 143.472 scf/bbl. Using the maximum requested liquid throughput (305,286), an assumed VRU downtime of 2% and the GOR, the gas vented from the heater is calculated as follows: (305,286 bbl/year)'(143.472
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 treater 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 to
permit 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 reviewed both documents and expressed they had no comments.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point N
005
Process q SCC Code
01 3-10-001-60 Flares
Pollutant Uncontrolled Emissions Factor Control % Units
PM10 16.07 0 lb/MMSCF
PM2.5 16.07 0 lb/MMSCF
SOx 1.27 0 Ib/MMSCF
NOx 146.64 0 lb/MMSCF
VOC 69323.77 95 Ib/MMSCF
CO 668.53 0 lb/MMSCF
Benzene 194.59 95 lb/MMSCF
Toluene 159.15 95 lb/MMSCF
Ethylbenzene 24.56 95 Ib/MMSCF
Xylene 82.67 95 Ib/MMSCF
n -Hexane 1349.87 95 lb/MMSCF
224 TMP 0.70 95 Ib/MMSCF
4 of 5 K:\PA\2018\18WE1036.CP1
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and 8 - APEN and Permit Requirements
ATTAINMENT
1 Are uncontrolled actual emissions from any criteria pollutants from this Individual source pester than 2 TPY (Regulation 3, Part A. Section 11.0.1-a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TRY. NOa greater than 10 TPY or CO missions greater than 10 TPY (Regulation 3, Part B, Section n 0.3)3
clot enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than S TPY or CO emissions greater Man 1(3 TPY (Regulation 3, Part R, Section u D 2j)
invite Is in the Non-Attainrnvnt Aran
Source requires a permit
Yes
Colorado Regulation 7. Section XVI(
I. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014)
Source is subjun to Regulut ion 7 y.;ct•on
Section XVI1.B2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Sect ion XVII.G • Emissions Control
Alternative Emissions Control (Optional Section'
a. Is this separator controlled by a back-up or alternate combustion device (I.e., not the primary control device) that Is not enclosed?
The control device for this up►rart or is not subject to Regweiion 7, Section XVIIS.2.e
Section 7MI.B.2.e-Alternative emissions control equipment
Disclaimer
This document assists operators wth determining applicability of certain requirements of the Clean Air Act. Ns implementing regulations. and Air Quality Control Commission regulations This document is not a
rule or regulation. and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law, regulation,
or any other legally binding requirement and is not legally enforceable In the event of any conflict beteeen the language of this document and the language of the Clean Ar Ad.. its implementing regulations.
and Air Quality Control Commission regulations, the language of the statute or regulation wE control The use of non -mandatory language such as 'recommend." "may, "-should,' and -can, • is intended to
describe APO() interpretations and recommendations. Mandatory terminology such as -must" and "required -are intended to describe controlling requirements under the terms of the Clean Air Act and Air
Quality Control Commission regulations, but this document does not establish legally binding requirements In and of itself
Yes
Yes
No
Source Requires an APEN. Go to the next question
Source Requires a permit
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 b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 18WE1036 Issuance: 1
Date issued:
Issued to: Verdad Resources LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Warner 01N -64W-17 Production Facility
123/9FF8
SESW SEC 17 T1 N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Equipment Description
Point Description
Emissions Control
HT-VENT01
005
Natural gas venting from one (1) heater
treater during vapor recovery unit (VRU)
downtime.
Enclosed
combustor(s) during
vapor recovery unit
(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.Qov/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
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Pubic Health Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.Qov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
I. F.4. )
4. 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 treater during vapor recovery unit downtime
and estimate the gas flow rate based on the standard cubic feet (scf) per barrel (bbl) of 143.5
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
---
---
1.6
---
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.
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
HT-VENT01
005
Emissions from the heater treater are
routed to an 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 site 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 treater and routed to
the enclosed combustor(s) using a continuous operational 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 Pubic Health b 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 £t 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 O€tM 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.)
• 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 & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; 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) shalt 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 E) Environment
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 History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Verdad Resources LLC
Permit for natural gas venting from one (1)
heater treater 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-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Facility
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
HT-VENT01
005
Benzene
71432
176
9
Toluene
108883
144
8
Ethylbenzene
100414
23
2
Xylenes
1330207
75
4
n -Hexane
110543
1,215
61
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 Heath B 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
69,323.77
3,466.19
Gas Analysis
110543
n -Hexane
1,349.87
67.49
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 120°F and 28 psig respectively. The VOC and HAP emission
factors were determined using the weight % values and gas molecular weight (37.8903
lb/lb-mol) from the gas sample analysis in conjunction with the EPA Emission Inventory
Improvement Program Publication: Volume II, Chapter 10 - 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.
7) This facility is classified as follows:
Applicable
Requirement
Status
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 b 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 #: 395122
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
SESW
17
1N
64
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
9FF8
Warner 01N -64W-17 Production Facility
SESW quadrant of Section 17, 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?
Carbon Monox de (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point 4
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001
Condensate Tank
TK01-04
Yes
19WE0249
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)
i
No
Yes
NOx CO
No
NOx CO
VOC
VOC
PM2.5 PM10 TSP HAPs
PM2.5 PM10 TSP HAPs
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
Facility AIRs ID:
123
County
9FF8
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Four (4) 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 =
254,405 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
254,405 Barrels (bbl) per year
Requested Permit Limit Throughput =
305,286 Barrels (bbl) per year
Requested Monthly Throughput =
25923 Barrels (tbl) 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 =
305,286 Barrels (bbl) per year
2302.88
34.878
Btu/scf
scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Pilot Light:
Pilot Light Rate: 30 scf/hr
Pilot Light Heat Content: 1458 Btu/scf
Annual Pilot Light Rate: 0.2622 MMscf/year
Requested pilot light Heat
content routed to
combustion device: 333.1621 MMBtu/year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Yes
E&P Tank Throughput =
254,405.00
bbi/year
Pollutant
Simulation
Emission Rate
VOC
352.874
tpy
Benzene
0.61
tpy
Toluene
0.404
tpy
Ethylbenzene
0.046
tpy
Xylene
0.112
tpy
n -Hexane
5.097
tpy
224 TMP
0.035
tpy
20,434 MMBTU per year
24,521 MMBTU per year
24,521 MMBTU per year
Emission Factors
Condensate Tank
Ernissior Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
2.77411
L337 E-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)
Benzene
4.796E-03
2.398E-04
Toluene
3.176E-03
1.588E-04
Ethylbenzene
3.616E-04
1.808E-05
Xylene
8.805E-04
4.402E-05
Site Specific E.F. (Includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
n -Hexane
4.007E-02
2.003E-03
224 TMP
2.752E-04
1.376E-05
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
5.98E 04
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
5.98E-04
NOx
0.0680
5.46E-03
CO
0.3100
22.49E-02
Pollutant
Pilot Light
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMscf) (lb/MMscf)
(waste gas
combusted)
(waste gas
combusted)
PM10
7.6000
10.86
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
10.86
NOx
100.0000
142.94
CO
84.0000
120.07
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
PM10
PM2.5
NOx
423.45
352.37
17.64
423.45
21.17
3596 _
0.09
0.08
0.08
0.09
0.09
16
0.09
0.08
0.08
0.09
0.09
16
0.85
0.71
0.71
0.85
0.85
145
CO
3.32
3.1E
3.13
3.92_
3.22
648
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
1464.00
1220.00
61.00
1464.00
73.20
Toluene
969.60
808.00
40.40
969.60
48.48
Ethylbenzene
110.40
92.00
4.60
110.40
5.52
Xylene
268.80
224.00
11.20
26&80
13.44
n -Hexane
12232.80
10194.00
509.70
12232.80
611.64
224 TMP
84.00
70.00
3.50
84.00
4.20
K:\PA\2019\19WEC249.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulatior 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, C3
Storage tank is subject to Regulatior 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 OOOO
Storage Tank Is not subject to NSPS OOOO
NSPS 0000a
Storage Tank is not subject to NSPS OOOOa
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 thar 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 rot 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.
N/A - operator developed site specific emission factors.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
1. Two (2) wells produce to this facility. According to COGCC data, these wells were fractured in April 2018 and have a reported first production date in June 2018. Please see the .\PEN 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 treater on 07/12/2018. The sample temperature and pressure are 93°F and 28 psig respectively.
3. NOx and CO emissions were calculated using a GOR of 34.878 scf/bbl and heat content of 2,302.88 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 1,458 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. < 230 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 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 #
001
Process #
01
SCC Code
4-04-003-11 Fixed Roof Tank. Condensate. working+breathing+flashing tosses
Pollutant
PM10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.01
0.01
0.13
66.1
0.60
0.11
0.08
0.01
0.02
0.95
0.01
Control %
0
0
0
95
0
95
95
95
95
95
95
Units
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
Ib/1,000 gallons
Ib/1,000 gallons
Ib/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\19WE0249.CP1
CondensateTank Regulat4ryAMlysls Worksheet
Imrna iIn the Ner.AtarnmentArea
NripINmpir
1. Are uncontrolled at4amanms from amtnterla pollutants from 4nl.,mtxau., source r. (ban 2 ITV 1Rewatba 3, Part., 5mlwu.0.1.a11
2. Js the ociutructIon ateaemlcodate)pbfto12/34/2w2 and not modmd A2412/31/2002 (See 7smano 03.01nennnbn112 and1142, 520. 2for addltwnl2aaanw on grandfather ap(4(222trli
3. Pretotal Nally uncontrolled woes misslou neater[harts in Nat greater than lomr or CO emasmns eieaterthan3orvv laewatfd3. Part 2,4madI.0.51i
11,6.62 rndhnedthat source la. die Nnn. mlmnontA,ea
C. Are uncontrolled emissions fa v ,Ilutantsfmmthtsu87(274lse areaterlbnl2vr/R2Nau0n 3,Part4 SmanI(4401?
2. Ismeaonvrmanmte(se samte) pr4nol2/30/2443 and not modndartru/al/2402 (See 25mmo05m0e2ntats732antl114 ana5aert 2 for additional guidance 2pandfatberapp2mu4g/
3. Aremalfeta-ny,maamlleivocenmam grater than 3 Tx, Nos greatert.n5 irtsm emwlma greater than1o1, 1asdatfu,3.Pang.5.1onHAW
142424. requiresaperm%
Colorado Resdaton 2, Sena n s2I2F
1. Isthtsanyetanktooted in the0lvoaone control am ararrtemnemnatmmnuarea oranalnment/mafntearrearea?
istM1b stomeetanktmtedatan dl and ear agora. and productanapmtw,s; natural easeernloeawrsutwn orrntunl gas dap mtrr?
3. tathhstem, tankfootedupstream era natural Pas OrmastnggaM2
minequfremena forAbPalwtan control Epmpment-Preventan of Leakage
.6. XII.. -Emission Estfroatfon Procedures
Section KILO -EmIssfons Control Pecograrnents
1. Is this storage tank looted mtbeg.lvmmne control area or am ozonenon.21-12inmentarea atammet4mamtearcearea. 2. Is this 3. Does m tn�ne mnaa d Ws ragl emtssua and have uncontrolled aotalemasbrs 2reaterthan repeal to x tun pavearvm
tae N,(e,.on
nta la 6204. 7.52ction AI.G
sa¢npnxRG1-Emerson atlmatan Procedures
Iw gnDomrdEpmprn -Prevent.
tranmbaron/sloragefacIllty?
2. Is Ws condensate stores tank. located al anal! and pas 'v7168607 and pmavalon o#eatlpn,wdl produdl. fadlity', natural gasumprrarsatan'ear natural gas processing plant,
condematestorage lank a fixed tank'?
9. Area stomge tank
coal to r greatertfanaton.perrear von
'lee Reemtat CI 443
Section WO -General or AlrPollutIon Control Eou
Salon XVII.C.1.-Emisslons Control a. hicntorlyProvialons
'6,o,==mw:dnegewfmnonN,sautmelquasi
kankaaubia¢mxwddon2,sadwxnb[E
of
40 CFR. Part 20. Subpart O.4adarda ofper>ormem farveatne Omadctimad s.arvimala
1. Is tlleIndhidval s rthan orrtual to 25 uba roam lm'l fen 36an
x. oar the fmwana uemftfon In 50.11160MP
a. less (Fan or equal 471522.2747,' 4122024001) used for hiroleum' r axenrd.prerd .., rtmateararto custody transfer' as defined In 60.11122
3. as Oilsrr4watertoma2212422 n olcapacity ed,r2 2(7404, or moalne0braebnmons e4an,6o.31 aarlury 23.1964?
a. Does the tank mm the den.. or staa2e Veil" In 60.1116,
5. Cm tbestoragevessel storea'wane uganlc (VOW'a.define+m64.11162
6. Do re ofthe blladng addtuanalah.Iaa4 :
a. mistbestmgevessd, pessun.essel aestaned to went. acrid 2049 kPa 43,2.7 mil and wtbm missions totheasmrpheal64.11ogd11211>:r
- m'rs5026a and ¢aasa lictOdwith a maximum tmevaprp:asureelestt6.n3.52Pa 160.110abnnr
cl - w¢rtbn w equal to 7s mien BBL) tam leastbn151m'r650 Sat] and stores a ltrntvIthamaimunaaenprprap,d lu than 15.6 koa(64.114Mo)12
44874/4/4/4'
rcellepubn an ADEN Gn to the nmeua-non
sure Requires a a permn.
Vas y I Yvr have lndleatei thesneamimnm¢ Dona m tile agm summaryskec.
sal a havefndbtedtheroc.tvoeontbeoalmsummaresheet.
Vas g.. Source Isugm
e 221 S f3detr attafmmt svtas an tlt2 Palm amnia ry ahce.
yma.ea amTankhnasuam to RewatM2.Scamsll.G-rauluvemNratedadlrbhpeonpniatsummaryshet.
No
h0
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Go to the nenquestion-You have Indicated hmity6l,..palct.r6m M1'shrt
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Source 6 sublet to parts &Regular. 0.4472444484271(74222(47
tMe: "aTst3lsrnat augur mall pawam dnegutmani. smartxvtl. satamame ex
Storage Tank I, not want t5P5 g6-mestorage.ea.d mead, abelawme awlkablemR0pu.
Subpart.,Generalem6ima
46o112b-Emtsaa Control Standards brVOC
4601136-Testlneand Procedures
§¢0.6156-RnvdnganagrmdkrW 22emiremems
660.2.26b-monto,bgefoprat..
e0 a . Part 60, Subpart0000, 5landadsel Pedrmam for Crude on and Natural Gas ProduNon TartanWton and oistramion
1. Isrds condensate rtoragevasel lout. at a adlby to the onshore oil and natural gas product774,2 em, natural gas prawssingsegmem or natural gas tranmlaron and MI., segment eft. Indutryi
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s. lethe .trageveasa.d12 2and 40740(2753arrwnnanathnenuhmenetarateagevessaa a e0CYRPan60 wwan66,40anpan635. rtxX?
I9am,m aea¢.6211 area
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able
40662 part60. Subpart 0000a Standards of parformanco for Crude on Zed Natural Ga. l< aIorwh2244en
rutinnmaabdon or Reconstruction Comm.. After sao4 tember13a15
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40 aft, Port63,2.a.tHLOCTIlltOll22 a d Gas 2aductpn ammo
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COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0249 Issuance: 1
Verdad Resources LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Warner 01N -64W-17 Production Facility
123/9FF8
SESW SEC 17 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
TK01-04
001
Four (4) 400 barrel fixed roof condensate
storage vessels connected via liquid
manifold.
Enclosed
bust
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 8 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.Rov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
TK01-04
001
--
---
21.2
3.9
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.
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
TK01-04
001
Enclosed Combustor(s)
VOC and HAP
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Pubiic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
TK01-04
001
01
Condensate
Throughput
305,286 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 roll'ng 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 Public 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 a MAINTENANCE REQUIREMENTS
15. Upon startup of this point, the owner or operator shall follow the most recent operating and
maintenance (0EM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7 )
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
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
Existing
Number
Emission Point
New Emission Point
Page 4 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
GP01
123/9FF8/001
123/9FF8/001
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 (NO,) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; 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, Section 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 & 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 is a 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 four (4) 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 b 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 anymalfunction 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
(Ib/yr)
Benzene
71432
1,464
74
001
Toluene
108883
970
49
Ethylbenzene
100414
111
6
Xylenes
1330207
269
14
n -Hexane
110543
12,233
612
2,2,4-
Trimethylpentane
540841
84
5
Note: All non -criteria reportable pot utants 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
2.49x10-2
2.49x10-2
AP 42 Chapter
13.5
VOC
2.77
1.39x10"1
EEtP Tank 3.0
71432
Benzene
4.796x10-3
2.398x10'4
108883
Toluene
3.176x10-3
1.588x10"4
1330207
Xylene
8.805x10-4
4.4x10-5
110543
n -Hexane
4.007x10-2
2.0x10-3
Note:
The controlled emissions factors for this point are based on the enclosed combustor(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 theheater treaters on 07/12/2018. The sample
temperature and pressure are 93°F and 28 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 34.878 scf/bbl and a heat content of 2,302.88 Btu/scf.
Actual COemissions 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
Ib/MMSCF
Source
CO
120.07
120.07
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 1,458 Btu/scf by
multiplying the AP -42 Chapter 1.4 Table 1.4-1 CO emission factor (84 lb/MMscf) by a ratio of
1,458 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 tight. 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 1O
COLORADO
Air Pollution Control Division
Department of Publ+c Heath & Envirorvne t
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 #: 395122
Received Date: 3/25/2019
Review Start Date: 4/4/2019
Section 01 - Facility Information
Company Name: Verdad Resources LLC
County AIRS ID: 123
Quadrant
Section
Township
Range
SESW
17
1N
64
Plant AIRS ID: 9FF8
Facility Name:
Physical
Warner 01N -64W-17 Production Facility
Address/Location: SESW quadrant of Section 17, Township 1N, Range 64W
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? n Carbon Monoxide (CO)
Weld County
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
,1
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
003
Liquid Loading
TL01
Yes
19WE0250
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? 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)
No
Yes
S02
Is this stationary source a major source?
If yes, explain what programs and which pollutants herE 5O2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
NOx
CO VOC PM2.5 PM10 TSP HAPs
No
NOx CO VOC PM2.5 PM10 TSP HAPs
H
Hydrocarbon Loadout Emissions I iventory
003 liquid Loading
Facility AIRs ID:
123
County
9FF8
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.
Yes
Requested Overall VOC & HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
100.0
95
95.CC
254,405 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
254,405 Barrels (bbl) per year
Requested Permit Limit Throughput =
305,286
Barrels (bbl) per year
Requested Monthly Throughput =
25928 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 =
Requested heat content of waste gas routed to combustion device =
305,286 Barrels (bbl) per year
2302.88 Btu/scf
0.554 MMscf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
1,275 MMBTU per year
1,530 MMBTU per year
1,530 MMBTU per year
Yes
Yom;
The state default emissions factors may be used to estimate emissions.
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
2.36E-01
1.18E-02
Condensate Loadout State E.F.
Benzene
4.10E-04
2.050E-05
Condensate Loadout State E.F.
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
Condensate Loadout State E.F.
224 TMP
0.00E+00
0.00E+00
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
PM10
0.0075
3.73E-05
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (SOx)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
3.73E-05
SOx
0.0006
2.95E-06
NOx
0.0680
3.41E-04
CO
0.3100
1.55E-03
2of4
K:\PA\2019\19WE0250.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
0.01
0.00
0.00
0.01
0.01
1
0.01
0.00
0.00
0.01
0.01
1
0.00
0.00
0.00
0.00
0.00
0
NOx
0.0520
0.0433
0.0433
0.0520
0.0520
9
VOC
36.02
30.02
1.50
36.02
1.8012
306
CO
0.2371
0.1976
0.1976
0.2371
0.2371
40
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Benzene
125.17
104.31
5.22
125.17
6.26
Toluene
0.00
0.00
0.00
0.00
0.00
Ethylbenzene
0.00
0.00
0.00
0.00
0.00
Xylene
0.00
0.00
0.00
0.00
0.00
n -Hexane
1099.03
915.86
45.79
1099.03
54.95
224 T M P
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 si.bmerged fill and loadout emissions must be routed to flare to satisfy RAG.
(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 outlet concentration sampling
Section 08 - Technical Analysis Notes
1. The heat input rate of loadout waste gas routed to the ECD was calcu:aced using the following equation: MMBtu/year = [Uncontrolled VOC (ton/year)] • [2000 Ib/ton)/[Molecular Weight (Ib/lb-mol)]*[379 scf/lb-
mol]*[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 41.11 Ib/Ib-mol and 2,302.88 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 #
01
5CC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 8.89E-04 0 lb/1,000 gallons transferred
PM2.5 8.89E-04 0 lb/1,000 gallons transferred
SOx 7.02E-05 0 lb/1,000 gallons transferred
NOx 8.11E-03 0 lb/1,000 gallons transferred
VOC 5.6 95 lb/1,000 gallons transferred
CO 3.70E-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 Ib/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\19WE0250.CP1
Hydrocarbon Loadoot Regulatory Analysis Worksheet
colomdo0 - APED end Permit Requirements
�seume k Intlte Naadu ebum nom.
MAINMINT,
1. uncontrolled actual emission from amcrIterle pollutants from this irdleldual source greater than 2 T12.Re n 3, Part A, Section 11.0.1.a1?
2. IsrMelwawtlam. atan Replant., and lola Men
site le.g well pod) 11O1n 3. Pert Dse tlon11D.1.1) 03
Is the Mar.. operation Iowans less than 10,000 milcre 138 Dad) df crude oil per day on en ennueleserege bests?
9. Is the loads,. operation loading less than 6,756 hale per year of condensate via splash till?
lathe loadout openadon loading lessthen 16,300able per year of condensate ale submerged all procedure?
6. Are Patel feelers uncontrolled WC emissions greater than O TP1,6., greeter Man 10710 or CO ends... greater than l6 iPY (Regulation 3, Part O, Section 11.0.3)?
IVou Iwo Wknr, that saurre k in the Nor,At eamentAroa
NOWATTAINIVIENT
1. Are uncontrolled emissions from any attach pollutants from this I12lvlaual source greater then 1100 (Regulatlon 3,13,1 A, Seer. LLo.1al?
2. Is the leaaout located at an exploration and produttlanslte le.g., well pad) )gegulatlon3, Part 0, SectlonlLD,1.l)?
3, Is the loads.operaaon lnaamg less than 30,000 gallons Rag 0041 of crude ell Per da0 On an annual average basis?
P. the loatloutoperatim loading Ina than 6.?36Idols per yearofmrdensate vie splash fill?
5.Is the 1o...operation lwaing less than 16,doa bats per year of mnaemamvla submerged ell procedure?
6. Are Meel feelers ..rolled Voc emissions lrom the greeter Mang 733, MN greaser than s Mlles CO marl., greeter den MTN(emulation, PartISource maul= pis
7. PAR- Are uncontrolled VOCe
2' met question..
N$'Pc Go to the next
tra9arN. Go to marques.,Pa
h15,1. x Go to nut question
Nam-b'a} Coto
The lwaou q p m.
10.4., fa
cloacae ion Pr
Man 10 toy en ion 3, Parc0,smMin 111.0.0,01
lead lc nluat be relavd 110l0ba 111NbN RA
Disclaimer
This document assists operators with determining appllcablllty of certain requirements of the Clean Alf Act, is Implemenling regulations, and Alr Quality Con. Commission regulations. This document Is not
a'Veer regulation, and the analysis if may not apply to a particular situation based upon the individual fad s'arc circumstances. This documentdoes no. change or substitute for any law, regulation,
or any otherlegally Waling requirement.. cl not legally enforceable. In the event erany cont., belweon the language a+thls document and the languaged the Chen AirAl(. Its implementing ragulatlnns,
andAlrOuallty Control Commission regulations, the language of the statute or regulation wlllconfrd Theme o/rrommardatoylanguage sltehas'recommend'"m3y.' rrO.UI,.. and tan"Islnterd3bO
describe AFCQ interpretation earl recommendations. Mandato,y terminology such as 'must" and "required are intended to describe controlling requirements under the terms oftlte Clean Air Act and Alr
Quality control eanmlasfon regulation, but this dacumentd:es not establish legally birdirg requiremenh 'nen,
he Ioaaout mast operatewllh submerged DI and loadout emissions must be round to maul Paaasfy PACT. If not controlled, a RAC7awlysls Is required and prorlde 22111ilPa In.ec0en 0.
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
19WE0250 Issuance: 1
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description: Well Production Facility
Verdad Resources LLC
Warner 01N -64W-17 Production Facility
123/9FF8
SESW SEC 17 TIN R64W
Weld County
Equipment or activity subject, to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TL01
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 & 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.Rov/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 shall not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOx
VOC
CO
TL01
003
---
---
1.8
---
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
TL01
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
TL01
003
Condensate Loaded
305,286 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 II.A.5.)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. This source is located in an ozone non -attainment or attainment -maintenance', area and is
subject to the Reasonably Available Control Technology (RACT) requirements of Regulation
Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged
fill 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 Pubilc Health & 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.):
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 Et MAINTENANCE REQUIREMENTS
14. 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 your 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
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 Health El 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
123/9FF8/003
123/9FF8/003
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 (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.
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 operationof 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 B 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 Public Heath @ 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: ihttps://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
126
7
n -Hexane
110543
1,099
55
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
V0C
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
1.8x10-4
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
MALT
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
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
ocsistri
Condensate Storage Tank(s) APE41 0
Form APCD-205 Stationary
Sourc®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:
1cWErvf9
AIRS ID Number: 123 / 9FF8 / 001
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Warner 01 N -64W-17 Production Facility
Site Location: SESW Sec 17 Ti N R64W
40.044704/-104.575548
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
' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
39511S
®� . COLORADO
1
Permit Number:
\ tUDEot4C\
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
AIRS ID Number: 123 / 9FF8 / 001
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
❑ 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 $250 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
- OR -
Et APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info £t 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: Condensate Storage Tanks
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 6/27/18
Normal Hours of Source Operation: 24 hours/day 7 days/week 52
Storage tank(s) located at:
✓❑ Exploration a Production (EEtP) site
weeks/year
❑ Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
o
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
13
Yes
•
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
O
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.0062-
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
•
p
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
12
■
k -k3 c 04.410 Ili
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
Permit Number:
��ll,c�eO AIRS ID Number: 123 / 9FF8 / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
I Condensate Throughput:
Actual Annual Amount
(bbl/year)
254,405
From what year is the actual annual amount?
projected
Average API gravity of sales oil: -40 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
Requested Annual Permit Limit4
(bbl/year)
305,286
RVP of sales oil: 7.6
❑ 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)
TK01-04
4
1600
06/2018
06/2018
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 45162
Warner 01N -64W -17-1H
Fl
05 - 123 - 45163
Warner 01 N -64W -17-2H
17
IN
■
■
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all welts that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.044704/-104.575548
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)
O Downward
❑ Other (describe):
❑r Upward
❑ Horizontal
O Upward with obstructing raincap
Indicate the stack opening and size: (check one)
E Circular Interior stack diameter (inches): 54
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
O Other (describe):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 3 1
BY
COLORADO
dyne, of
Permit Number:
lot pz41
AIRS ID Number: 123 / 9FF8 / 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:
Make/Model:
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOC/HAPs
Rating: MMBtu/hr (^ ('j
Make/Model: GCO ECD2000
Type: Enclosed Combustor
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
Constant Pilot Light:
N/A
95
98
Waste Gas Heat Content:
❑ Yes ❑ No Pilot Burner Rating:
2303
—2320
0.0437
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (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 a 3 -phase horizontal heated separator. From the separators, oil is
directed to a 3 -phase vertical heater treater for further separation and pressure reduction.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
Av COLORADO
bEn
Permit Number:
1a uEnt_y9
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
AIRS ID Number: 123 / 9FF8 / 001
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
(
Pollutant
Description of Control Method(s) '
Overall Requested Control
Efficiency
(% reduction in emissions)
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 Factor6
Actual Annual Emissions
Requested Annual Permit
a
Emission Limit(s)
Uncontrolled
Basis
Units
Source.
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions?
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
2.1-1-
lb/bbl
Site Specific
35t. $}
l l .t `i
`173.4 5
Zl. tl,
NOx
0.co5(p
lb/bbl
Calculated
9:790 0.1-1
9-;=6 0.1\
6-84 o..S
0.84 O•51.5
CO
O.O2.S
lb/bbl
Calculated
3-9-2 3.‘'3
3.123.4
37-7.5 3.V....
S.az
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled -
Emissions
(Pounds/year)
Controlled
Emissions7
(Pounds/year)
Benzene
71432
`-l.`bylo3
lb/bbl
Site Specific
l,7to
Lo1
Toluene
108883
3•1SKIo 3
lb/bbl
Site Specific
`-bk.)"
1--to.y
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
"l•(-)tXlo z
lb/bbl
Site Specific
lottyy
509.1
2,2,4-
Trimethylpentane
540841
VN. c-.'cs 0,_n1Z co.. --b01(. _
a 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 Ii -it.
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. °Lt10 t G 1
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
COLORADO
5IAN4�Sh S 2r.•^.'�nment
Permit Number:
ICIL�t���
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
AIRS ID Number: 123 / 9FF8 / 001
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.
4,41
Signature of Legalt orized Person (not a vendor or consultant)
3/t2/1c1
Date
Michael Cugnetti EH&S Manager
Name (print)
Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit
registration fee of $250, 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
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-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
COLORADO
6I •V
Y.baltn_ b Enr..nnmam
Hydrocarbon Liquid Loading APEN - Form APCD-208 it)ary
Air Pollutant Emission Notice (APEN) and SSA
oes
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if
the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on
the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
I q titIE0z5O AIRS ID Number: 123 /9FF8 / 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: TL01
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Verdad Resources LLC
Site Name: Warner 01N -64W-17 Production Facility
Site Location: SESW Sec 17 T1 N R64W
40.044704/-104.575548
Mailing Address:
pCode1401 17th Suite 925
(Include Zip Code) Street,
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
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-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 1 I
395l2
AY
COLORADO
ocuaztumAtof v,W,
Permit Number:
AIRS ID Number: 123 /9FF8 /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)
❑ Change fuel or equipment ❑ Change company name
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: APEN Update - Cancel GP07 w/ 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: 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 2 I
O Yes O No
❑ Yes i] No
❑ Yes i] No
O Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes (] No
AVCOLORADO
vci. En k unmeni
Permit Number: 1au5l0ZSt7 AIRS ID Number: 123 /9FF8/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: (] Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume
Loaded4:
3os, z
Bbl/yr
Actual Volume
Loaded:
251, X105
Bbl/yr
4 Requested values will become permit Limitations. Requested limit(s) should consider future process growth
This product is loaded from tanks at this facility into: trucks
(eg, "rail tank cars" or "tank trucks")
pedi eA.Pl:C,aVc.)v•- •
NOS
oLk 0 -tin
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature
of bulk liquid loading:
°F
True Vapor
Pressure
Psia 60 °F
Molecular weight of
displaced vapors
Lb/lb mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Bbl/yr Actual Volume
Loaded : 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
®
COLORADO
3 I
Permit Number:
lei tADE 1- D
AIRS ID Number: 123/9FF8/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.044704/-104.575548
Operator ".
Stack ID No.
Discharge Height
Above Ground Level
: (Feet) ...
Tem
' (7)
o t 1
(ACFM)>
- s:
Velocity
"<4 .
EC01
20
1000
25
0.026
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
❑r Upward
❑ Horizontal
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
O Loading occurs using a vapor balance system:
Requested Control Efficiency .95- ICS
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 -"f' Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0.0437 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
COLORADO
HP,. ii,vitonmem
Permit Number:
IQuoEdZr] AIRS ID Number: 123/9FF8/003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
Sox
NOx
CO
VOC
vapor balance / t(
la /95
HAPs
vapor balance f si.:- U)
(0O 195
Other:
,Ai; t-5 ?v/ a.l?i'v cc ,±
❑✓ Using State Emission Factors (Required for GP07) VOC
El Condensate 0.236 Lbs/BBL
❑ Crude 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:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions :
Requested Annual Permit:
s
Em7551Oi L�mtt(s)
:.._
Uncontrolled
(Tons/year)
Controlled5
(Tons/year)
Uncontrolled
(Tons/year) .
Controlled
(Tons/year)
PM
SOS
NOX
0.00034-
lb/bbl
Calculated
0.043 `
0.043
•
0.052
,
0.052 •
VOC
0.236 -
lb/bbl
CDPHE
30.02
1.50
36.02
1.80
CO
0.0016 '
lb/bbl
Calculated
0.20 _
0.20
,
0.24
-
0.24
Benzene
0.00041 •
lb/bbl
CDPHE
0.052
0.0026
0.063
0.0031
Toluene
Ethylbenzene
Xylenes
n -Hexane
0.0036 •
lb/bbl
CDPHE
0.46
0.023
0.55
0.027
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
5I
COLORADO
D:parntolPatl1c
4�e��n o r..v.rcn�ni.ni
Permit Number:
IGt0EOZSv AIRS ID Number: 123/9FF8/003
[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.
Signature of Legally u orized Person (not a vendor or consultant)
Michael Cugnetti
Date
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
6IMCOLORADO
'`,:2°o2;rt.
RECEIVED
SEP 1 Zti18
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
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.
APCD
Stationary
'ap�r�eK
Permit Number: /EWE I05& AIRS ID Number: / 2 3 /9 FFg/ DOS
[Leave blank unless APCD has already assigned a permit k and AIRS ID]
Company equipment Identification: HT-VENTO1
(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: Warner 01N -64W-17 Production Facility
Site Location: SESW Sec 17 T1 N R64W
40.044704/-104.575548
Mailing Address:
(Include Zip Code) 1401 17th Street, Suite 925
Denver, Colorado 80202
E -Mail Address2: bganong@verdadoil.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Brad Ganong
Phone Number: 720-845-6918
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
®- COLORADO
Permit Number:
1�upe 1O �� AIRS ID Number: �FFg aDS
[Leave blank unless APCD has already assigned a permit = and AIRS ID]
Section 2- Requested Action
El NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment El Change company name El Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
OR -
APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Initial Application
' 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.
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: variable hours/day variable days/week variable weeks/year
Heater Treater venting during VRU
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
O Yes
❑ Yes
Form APCD-211 -Natural Gas Venting APEII - Rev 0312017 2 I
❑ No
El No
AY
L.paxtrrtertt of Pub,
COLORADO
Permit Number:
(&ta7l,1O AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
/9f -T% / cDoJ
Section 4 - Process Equipment Information
E Gas/Liquid Separator
❑ Well Head Casing
O Pneumatic Pump
Make: Model:
O Compressor Rod Packing
Make: Model:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
O Blowdown Events
# of Events/year: Volume per event: MMscf/event
❑Q 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:
E No
LtSte.S
Maximum Vent
Rate:
342477.
SCF/hr
Vent Gas
Heating Value:
2320
BTU/SCF
Requested:
0.90
MMSCF/year
Actual:
.076.0 0A3
MMSCF/year
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:
31 Nvic.lib-v."0 j
VOC (mole %)
yc6.3e
VOC (Weight %)
lel.'-(S
Benzene (mole %)
0,,vgL{b
Benzene (Weight %)
O. lgKq
Toluene (mole %)
0.0cDSb
Toluene (Weight %)
p. (S1`{
Ethylbenzene (mote %)
0.00V12,
Ethylbenzene (Weight %)
0. °7,4 k -a
Xylene (mole %)
0.ov
Xylene (Weight %)
0.o"6L`b
n -Hexane (mole %)
0.sg4S
n -Hexane (Weight %)
(.352
2,2,4-Trimethylpentane
(mole %)
°'tZ
2,2,4-Trimethylpentane
(Weight %)
��
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 it n -Hexane, temperature, and
pressure)
V-\'.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/201!
,• ,), 61:c` te, a tcop oo . wb.LLria\5
pp COLORAD'Cbo0.S/511c1t
3 I m� ;..„ `�;�.;°.,
Permit Number:
1E✓ 117co AIRS ID Number: \-L3 /Ii=FonS-
[Leave blank unless APCD has already assigned a permit A and AIRS ID)
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.044704/-104.575548
Operator
Stack ID No ,:
Discharge i
Above,GroundHeLevghtel
(Feet)
Temp.
F
(' )
Flow-RateACFM)
Velocity
(ft/sec)
EC01
20
1000
25
0.026
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
El Upward
❑ Horizontal
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
❑ 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
MMBtu/hr
hr
95
98
Ckik
Minimum Temperature: N/A Waste Gas Heat Content ••2320 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0.0437 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
8`f upd k� ' � s
®� COLORADO
4
O�I1� I10
Permit Number:
1Sgu L173b AIRS ID Number:
[Leave blank unless APLD has already assigned a permit # and AIRS ID)
I22 'qFi b' cos -
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 l describe the control equipment AND state the overall control efficiency (% reduction):
yes, p ease
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NOX
VOC
Enclosed Combustor
95
CO
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
N/A
Use the following table to report the criteria pollutant emissions from source:
- r
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source'
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
•Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NO),
0.0v) 3
lil
AP -42
o.DS
o.oS
O,D.-
0.01-
VOC
b\,323:1-4-
151",,...scF
A`, �\yy,5
L5.'j
1.LI-
31.x,
1. SID
CO
O.'S1
t Imo, i;,
AP-LIZ
0.u't
0.2'1
0.3
0.3
Benzene
Ici-1.5°I
t�blirrw"54
Ava1j
0. CI
V. OVA
0,01
o.00`I
Toluene
159
i I.15 wiwm'c4
Ate\\kS6
O.olc
0.003
0, 0}
0. oo`l
Ethylbenzene
Y
2N. Slo
I'' mrvn� �
C'° -
A�tys�s
�.ot7�
0• 0 174
o. of
i7, dCoc°
Xylenes
`Gt • ll
l9wim5cc
(-"tA,:NAlS,5
0. 0,11
0 • COL
O. 0'A
O. aoz
n -Hexane
13y9.$1-
1elvrm5c.f
alt5;S
D. 41
O•0L5
O. col
o.O3
2,2,4-
Trimethylpentane
t°'�X'° I
II rr
1�l""'-mt
ASINA\Si5
0. COOS
0.00001
o. 1
O.oc'SoZ
Other:
TIVA.V••••r..,5 pc.,r cJtk. •
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. 4 `")
Form APCD-211 -Natural Gas Venting AFRO - Rev 03/2017 5 I AY
COLORADO
,1, i• E : of P-e4cc
Permit Number:
vq)u.:1--la 3b AIRS ID Number:
[Leavee blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that alt information contained herein and information submitted with this application is complete, true
and correct.
V21/1/
Signature of Legally horized Person (not a vendor or consultant) Date
Michael Cugnetti
EH&S Manager
Name (please print) Title
Check the appropriate box to request a copy of the:
❑� Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-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
A
WI COLORADO
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