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Home My WebLink About20192507.tiffa COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 June 26, 2019 Dear Sir or Madam: RECEIVED JUL 012019 WELD COUNTY COMMISSIONERS On June 27, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Synergy Resources Corporation - Fagerberg 33-12 Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe PubO is cVitti.) oel aco I 1 `1 Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director cc: HLCUT) , PLC TM, OGC3m), Pw(0-mfIR!cHicK) 6/Iq/l9 2019-2507 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Synergy Resources Corporation - Fagerberg 33-12 Pad - Weld County Notice Period Begins: June 27, 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: Synergy Resources Corporation Facility: Fagerberg 33-12 Pad Oil and Gas Compressor Station SWSW Section 12 T6N, R66W, Weld County, Colorado Weld County The proposed project or activity is as follows: Condensate storage and truck loadout of condensate at a well pad. Source has been transferred from Synergy Resource Corporation to SRC Energy Inc, LLC., but is being issued to the original owner, Synergy Resources Corporation. 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): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid othe 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 17WE0050 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: Christian Lesniak Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 gel r COLORADO Depattrnent of Public Health 6 Environme#tt Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Christian Lesniak Package #: 357419 Received Date: 1/17/2017 Review Start Date: 4/1/2019 Section 01 - Facility Information Company Name: Synergy Resources Corporation Quadrant Section Township Range County AIRS ID: 123 SWSW 12 EN 66 Plant AIRS ID: Facility Name: Physical Address/Location: County: 9F08 Fagerberg 33-12 Pad SWSW quadrant of Section 12, Township 6N, Range 66W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? n Carbon mess (CO) a Particulate Matter (PM) ❑ Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit ti Issuance # Self Cert Required? Action Engineering Remarks Condensate Tank Tank -1 1, _, 17WE00S0 3' s Permit Initial Issuance Liquid Loading 17WE00S i 1 Ye 7 Permit Initial nuance Section 03 - Description of Project Source submitted updated emissions for condensate tanks that lower facility -wide emissions below 50 tons per year of VOC. Source also submitted cancellations for 3 engines, bringing N0x and CO emisisons below 50 tons per year as well. Company has since changed name to "SRC Energy, Inc." but this will be issued to Synergy Resources Corporation, since the company name change was completed as streamlined name change, resulting in a letter crediting this and other sites to the new company name. 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) Is this stationary source a major source? If yes, explain what programs and which pollutants her( SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Yes 5O2 NOx i CO VOC PM2.5 PM10 TSP HAPs DODD D ■ Colorado Air Permitting Project Title V Operating Permits (OP) Non Attainment New Source Review (NANSR) i ❑_❑8❑ ❑❑❑ ( Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 9F08 001 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Eight (8) 400 BBL fixed -roof tanks for storage of condensate liquids Enclosed Combustors Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 124,323 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 124,323 Barrels (bbl) per year Requested Permit Limit Throughput = 149,212 Barrels (bbl) per year Requested Monthly Throughput = 12673 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput 149,212 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2442 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 125.3424658 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 51.24 Mscf/day waste gas 38,054 MMBTU per year 45,672 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 45,672 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 4.117 0.206 Site Specific E.F. (includes flash) Benzene 8.52E-03 4.26E-04 Site Specific E.F. (includes flash) Toluene 7.30E-03 3.65E-04 Site Specific ES. (includes flash) Ethylbenzene 5.19E-04 2.60E-05 Site Specific E.F. (includes flash) Xylene 3.36E-03 1.68E-04 Site Specific E.F. (includes flash) n -Hexane 6.30E-02 3.15E-03 Site Specific E.F. (includes flash) 224 TMP 1.35E-03 6.76E-05 Site Specific E.F. (Includes flash) Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/bbl) Emission Factor Source (waste heat combusted) (Condensate Throughput) PM 10 0.0075 0.0023 AP -42 1 able 1.4-2 (PMIO/t M.2.5) PM2.5 0.0075 0.0023 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) NOx 0.0680 0.0208 CO 0.3100 0.0949 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 NOx CO 307.2 255.9 12.8 307.2 15.4 2609 0.2 0.1 0.1 0.2 0.2 29 0.2 0.1 0.1 0.2 0.2 29 1.6 1.3 1.3 1.6 1.6 264 7.1 5.9 5.9 7.1 7.1 1202 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 1271 1059 53 1271 64 0.64 Toluene Ethylbenzene 1090 908 45 1090 54 0.54 0.04 0.25 4.70 0.10 77 65 3 77 4 Xylene n -Hexane 224 TMP 501 418 21 501 25 9407 7838 392 9407 470 202 168 8 202 10 Section 06 - Regulatory Summary Analysis 0.03 0.03 0.002 0.01 0.24 0.01 Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, CA & 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 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 3 of 8 K:\PA\2017\17WE00SO,0051.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Source modeled emissions in Promax, including working and breathing. Sample was taken 11/21/2016, within one year of source application submittal. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # 01 SCC Code Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.05 0 lb/1,000 gallons condensate throughput PM2.5 0.05 0 lb/1,000 gallons condensate throughput NOx 0.50 0 lb/1,000 gallons condensate throughput VOC 98.0 95 lb/1,000 gallons condensate throughput CO 2.26 0 lb/1,000 gallons condensate throughput Benzene 0.20 95 lb/1,000 gallons condensate throughput Toluene 0.17 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput Xylene 0.08 95 lb/1,000 gallons condensate throughput n -Hexane 1.50 95 lb/1,000 gallons condensate throughput 224 TMP 0.03 95 lb/1,000 gallons condensate throughput 4 of 8 K:\PA\2017\17WE0050,0051.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B • APEN and Permit Re uirements _ Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 WY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area Yes NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit No Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section XII.C- Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII C.2 - Emission Estimation Procedures Section XII.D - Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section XII.G Section XII G.2 • Emissions Control Requirements Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C.2 - Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions'' of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII, B, C.1 & =.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVILC.2 - Capture and Monitoring for Storage Tanks frtted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) [`472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ['10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.11lb? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi] and without emissions to the atmosphere (60.11ob(d)(2))?; or b. The design capacity is greater than or equal to 151 m' (-950 BBL) and stores a liquid with a maximum true vapor pressures less than 35 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' (-472 BBL) but less than 151 m3 (-950 BBL) and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b))? Yes Yes Yes Yes }([S No Yes r -Jo Yes Yes Yes No Source Req Go to next Source Req Continue -' Continue-' Source is st Continue - Storage Tar Source is st Continue -' Go to the n Go to then Source is st Source is st Storage Tar Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements 560.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §605425 Table 3 §60.5395 - Emissions Control Standards for VOC 460.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements (Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities I. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPS? 3. Does the tank meet the definition of "storage vessel'' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? S. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subject to MACT HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting Yes No RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act,. its implementing regulations. and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as "recommend," -may." "should," and 'can." is intended to describe APCD interpretations and recommendations Mandatory terminology such as "must" and "required- are intended to describe controlling requirements under the 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 Conhnue storage Tar CtinUnue- Storage Tar Hydrocarbon Loadout Emissions Inventory 002 Liquid Loading Facility AIRs ID: 123 County 9108 Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Loadout of condensate in tanker trucks 0.00 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = No 96,912 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = Requested Permit Limit Throughput = 14,921 Barrels (bbl) per year Requested Monthly Throughput = 1267 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = Secondary Emissions - Combustion Device(s) 14,921 Barrels (bbl) per year Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46*S*P*M/T MMBTU per year MMBTU per year MMBTU per year Barrels (bbl) per year The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 Chapter 5.2 Table 5,24 Submerged Loading: Dedicated Normal Service (S=0.6) P True Vapor Pressure 7.5 psia Graphed from AP -42 Figure 7.1-13a at temp = 76 F and RVP 8.5 M Molecular Weight of Vapors 68 Ib/Ib-mol From AP -42 Table 7.1-2 at RVP = 8.3 T Liquid Temperature 508 Rankine From source L Loading Losses 7.505433071 lb/1000 gallons 0.315228139 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.004021 0.001267533 lb/bbl Mass fraction from light oil site -specific sample Toluene 0.013037 0.00410963 lb/bbl Mass fraction from light oil site -specific sample Ethylbenzene 0.00305 0.000961446 lb/bbl Mass fraction from light oil site -specific sample Xylene 0.020924 0.006595835 lb/bbl Mass fraction from light oil site -specific sample n -Hexane 0.025937 0.008176074 lb/bbl Mass fraction from light oil site -specific sample 224 TMP 0.001696 0.000534627 lb/bbl Mass fraction from light oil site -specific sample Emission Factors Hydrocarbon Loadout Emission Factor Source Pollutant Uncontrolled Controlled w (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC 3.15E-01 3.15E-01 Site S:poet:ific= AP -42: Chapter 5.2 , I. qs.u:-iii ,i:.t Site Specific .. AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42; Chapter 5.2, Equation 1 Site Specific- AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific- AP -42: Chapter 5.2, Equation 1 Benzene 1.27E-03 1.27E-03 Toluene 4.11E-03 4.11E-03 Ethylbenzene 9.61E-04 9.61E-04 Xylene 6.60E-03 6.60E-03 n -Hexane 8.18E-03 8.18E-03 224 IMP 5.35E-04 5.35E-04 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.00E+130 PM2.5 0.00E+00 SOx 0.00E+00 NOx 0.00E+00 CO _ 0.00E+00 6 of 8 K:\PA\2O17\17WEOOSO,OO51.CP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.S SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 2.35 15.27 15.27 2.35 2.35 399 0.00 0.00 0.00 0.00 0.00 0 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) 0.06 0.20 0.05 0.32 0.40 0.03 Benzene Toluene 19 123 123 19 19 61 398 398 61 61 Ethylbenzene Xylene n -Hexane 224 TMP 14 93 93 14 14 98 639 639 98 98 122 792 792 122 122 8 52 52 8 8 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 Ioadout must be operated with submerged fill to satisfy RACT. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements You have indicated above the source is not controlled. The following question does not require an answer. Section 08 - Technical Analysis Notes Source originally submitted with a low emission factor from Promax and no control. I updated emission factor to match AP -42 and tripled emissions. Source originally submitted in 2017 with actual throughput of 96,912 BBL/yr and requested of 115,935 BBL/yr. After speaking with source, source has updated condensate throughput and emissions, and has specified that site LACT limits loadout throughput to 10% of condensate throughput for tanks. Source has asked to update requested throughput to 14,912 BBL/yr. This has resulted in a large drop in emissions, and emissions are no longer near a threshold (thought they were slightly below at the recalculated 18 tpy VOC) that we would require control for RACT, source has specified no control, and given the greatly lowered throughput, this point is not a large concern to require control. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # 01 SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 Ib/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 7.5 0 lb/1,000 gallons transferred CO 0.00 0 lb/1,000 gallons transferred Benzene 0.03 0 lb/1,000 gallons transferred Toluene 0.10 0 lb/1,000 gallons transferred Ethylbenzene 0.02 0 lb/1,000 gallons transferred Xylene 0.16 0 lb/1,000 gallons transferred n -Hexane 0.19 0 lb/1,000 gallons transferred 224 TMP 0.01 0 lb/1,000 gallons transferred 7 of 8 K:\PA\2017\17WE0050,0051.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2.. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Y.. No No `i e.S Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? No The loadout must be operated with submerged fill to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should, " and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the 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. Go to next Go to the n Go to next Go to next Go to next The loadou The loadou COLORADO Air Pollution Control Division Depamrent of Pt:b'tc Health & 6nv;renment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 17WE0050 Issuance: 1 Date issued: Issued to: Synergy Resources Company Facility Name: Fagerberg 33-12 Pad Plant AIRS ID: 123/9F08 Physical Location: SWSW Sec. 12 T6N R66W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment ' Description Emissions Control Description TANK -1 001 Eight (8) 400 BBL fixed -roof tanks for storage of condensate liquids Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 9 COLORADO Air Pollution Control Division Ctep3mnent of Pt b' c Health 6. 6rmionment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4. ) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits:. Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TANK -1 001 0.0 1.6 1.5.4 7.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limit< Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 9 COLORADO Air Pollution Control Division Depa rnent of rt b''tc Health f, 6nmranmenr Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TANK -1 001 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4,) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TANK -1 001 Condensate throughput 149,212 barrels Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • 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) Page 3 of 9 COLORADO Air Pollution Control Division bepanment of rib _c Health , En , riment Dedicated to protecting and improving the health and environment of the people of Colorado 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 must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank •covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must 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 must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 9 COLORADO Air Pollution Control Division Department at PLblic Health 8 6na9ranment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C. • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) 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 1OO tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not 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. Page 5 of 9 COLORADO Air Pollution Control Division Depa' m nt o€ Pt:b'ic Health ft tnv tonment Dedicated to protecting and improving the health and environment of the people of Colorado 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any 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: Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation Page 6 of 9 COLORADO Air Pollution Control Division Department of FLb';c Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air, pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 1271 64 Toluene 108883 1090 54 Ethylbenzene 100414 77 4 Xylenes 1330207 501 25 n -Hexane 110543 9407 470 2,2,4- Trimethylpentane 540841 202 10 Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0208 0.0208 AP -42 Chapter 13.5 Industrial Flares (N0x) Page 7 of 9 COLORADO Air Pollution Control Division DepaTre nt of Pt b'dc Health S Env5ranment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source CO 0.0949 0.0949 AP -42 Chapter 13.5 Industrial Flares (CO) VOC 4.117 0.206 Site -Specific EF from Promax 71432 Benzene 8.52E-03 4.26E-04 Promax 108883 Toluene 7.30E-03 3.65E-04 Promax 1330207 Xylene 3.36E-03 1.68E-04 Promax 110543 n -Hexane 6.30E-02 3.15E-03 Promax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This 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, CO, NOx, HAP PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Page 8 of 9 COLORADO Air Pollution Control Division Department of rt:h'ic Health fr En; ronnment Dedicated to protecting and improving the health and environment of the people of Colorado Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.883O Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 COLORADO Air Pollution Control Division llepetrn nt of Pt:htsc Health Es Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number. Date issued: Issued to: CONSTRUCTION PERMIT 17WE0051 Issuance: 1 Synergy Resources Company Facility Name: Plant AIRS ID: Physical Location: County: Description: Fagerberg 33-12 Pad 123/9F08 SWSW Sec. 12 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment' Description Emissions Control Description LOAD 002 Truck loadout of condensate None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission, and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO LOAD 002 - - 2.4 Point Page 1 of 7 COLORADO Air Pollution Control Division Department of Pt b tc Health ft Fnt ronment Dedicated to protecting and improving the health and environment of the people of Colorado Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. PROCESS LIMITATIONS AND RECORDS 4. This source must be limited to the following: maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Equipment ID AIRS Point Process Parameter Annual Limit LOAD 002 Condensate Loaded 14,921 barrels Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 5. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must 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.) 6. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 7. 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 Page 2 of 7 COLORADO Air Pollution Control Division Depamnent of P .b'-ic Health b trr,vonrnent Dedicated to protecting and improving the health and environment of the people of Colorado Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill. (Reference: Regulation 3, Part B, III.D.2) All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 8. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. The owner or operator must 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 must occur at least monthly. Each inspection must be documented in a log available to the Division on request. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. Inspect pressure relief! devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. OPERATING Et MAINTENANCE REQUIREMENTS 9. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 10. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 11. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 12. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 3 of 7 COLORADO Air Pollution Control Division Department of Fi.bGc Health ft rrw onment Dedicated to protecting and improving the health and environment of the people of Colorado For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. 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; Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 13. 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. 14. 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. 15. 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 4 of 7 COLORADO Air Pollution Control Division Department of tvb?tc Health t rnv;ror menf 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. 16. 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. 17. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any 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. 18. 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. 19. 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. Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation Page 5 of 7 COLORADO Air Pollution Control Division Oepamxent n[ t-Lh'rc Health & t.nv enment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Benzene 71432 19 Toluene 108883 61 002 Ethylbenzene 100414 14 Xylenes 1330207 98 n -Hexane 110543 122 2,2,4-Trimethylpentane 540841 8 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/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: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Source VOC 3.15E-01 Source The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 7.5 psia Page 6 of 7 COLORADO Air Pollution Control Division Department o€ Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado M (vapor molecular weight) = 68 lb/lb-mol T (temperature of liquid loaded) = 508 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx HAP PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC, NOx 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 UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD 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 7 of 7 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1 Permit Number: 17tt1E1,tp5o Facility Equipment ID: TK-1 — TK-8 Section 01— Administrative Information Company Name: Synergy Resources Corporation [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 12.3 / /Fib I DO [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Source Name: Fagerberg 33-12 Pad NAICS, or 211111 SIC Code: Source Location: SWSW Sec. 12 T6N R66W Mailing Address: 5400 W. 11th Street, Suite C Greeley, CO County: Weld Elevation: 4,799 Feet ZIP Code: 80634 Person To Contact: Jerry Brian Phone Number: (720) 616-4300 E-mail Address: jbrian@syrginfo.com Fax Number: (720) 616-4301 Section 03 — General Information For existing sources, operation began on: This Storage Tank is ® Exploration & Production Located at: (E&P) Site Will this equipment be operated in any NAAQS nonattainment area? Is actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? / / ❑ Midstream or Downstream (Non-E&P) Site ® Yes ❑ No ® Yes ❑ No Section 02 Requested Action (Check applicable request boxes) ® Request for NEW INDIVIDUAL permit ❑ Request for coverage under GENERAL PERMIT O GP01 ❑ GP08 O Request MODIFICATION to. existing INDIVIDUAL permit (check boxes below) ❑ Change process or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership ❑ Other ❑ APEN Submittal for Permit Exempt/Grandfathered source ❑ APEN Submittal for update only (Please note blank APEN's will not be accepted) Addl. Info. & Notes: For new or reconstructed sources, the projected startup date is: 10 / 19 / 2016 Normal Hours of Source Operation: 24 Are Flash Emissions anticipated at these tanks If "yes", identify the stock tank gas -to -oil ratio: ► Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ► Are you requesting ≥ 6 ton/yr VOC emissions, or are uncontrolled actual emissions ≥ 6 ton/yr? General description of equipment purpose: Storage of condensate from production wells Section 04 — Stora!e Tank(s) Information Requested Permit Limit: 19-9 7.1'). bbl/year Actual: bbl/year Average API Gravity of Sales Oil: degrees Tank Design: Fixed Roof: Condensate Throughput: Internal Floating Roof: 0 Actual While Controls Operational: RVP of Sales Oil External Floating Roof: I/year 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) 8 3,200 9/2016 10/2016 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 43180 Fagerberg 6C -7-M El 05 -123 -43181 Fagerberg 15N -7A -M ►5 05 - 123 - 43182 Fagerberg 6N -7C -M El 05 - 123 - 43183 Fagerberg I IN -7A -M ►4 05 -123 - 43184 Fagerberg 3C -18-M ►5 hours/ day 7 days/ 52 weeks/ week year ® Yes ❑ No .005 m3/liter Yes ❑ No Yes ❑ No Colorado Department of Public Health and Environment Air Pollution Control Division (APCD)This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 per APEN for non- E&P, midstream and downstream sources or $152.90 for up to five (5) APENs for E&P sources and $250 for each general permit registration to: Colorado Department of Public Health & Environment\ APCD-SS-BI 4300 Cherry Creek Drive South f Denver, CO 80246-1530 For guidance on how to complete this APEN form: ' Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: http://www.colorado.gov/cdphe/oilgasAPENS Application status: http://www.colorado.gov/cdphe/permitstatus. FORM APCD-205 357412 Page 1 of 2 AP Form-APCD-205-Condensate-Tanks-APEN (96.5%):doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)' Permit Number: ction 05 — Sta , _ t , u + t: t n For Midstream sites onl )perator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (fl/sec) Moisture (%) 'irection of stack outlet (check one): 0 Vertical 0 Vertical with obstructing raincap xhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) = ction 07 — Control Device Information Emission Source AIRS ID: I Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/l.ong Horizontal Datum (NAD27, NAD83; WGS84) UTM Zone (12 or 13) UTM fasting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) NAD83 -104.734126 40.498896 COGCC ❑ Horizontal 0 Down 0 Other: Length (inches) _ 0 Other (Describe): Width (inches) ] Vapor Recovery Unit (VRU) used for control of the Storage Tank(s) Size: Make/Model: Requested VOC & HAP Control Efficiency: Annual time that VRU is bypassed (emissions vented): ?� ] Closed loop system used for control of the storage tank(s) Description: Combustion Device used for control of the Storage Tank(s) Type: (3) Enclosed Combustors Make/Model VOC & HAP Control Efficiency: Requested: 96.5 % Minimum temp. to achieve requested control °F Constant pilot light? ® Yes ❑ No Describe Any Other: Rating: MMBtu/hr Project Consultants- 7', 7.5' & IES- 8' Manufacturer Guaranteed: 98 Waste gas heat content: Btu/scf Pilot burner rating: MMBtu/hr ction 08 — Gas/Liquids Separation Technology Information (E&P Sites Only) Vint is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 29 lease describe the separation process between the well and the storage tanks: (14) 48" Leed 3 -phase separators, (2) 48" Worthington 2 -phase separators (gas busters) ction 09 — Emissions Inventory Information & Emission Control Information psig Emission Factor Documentation attached Data year for actual calendar pr. emissions below & throw h�put in Sec. 04 (e.e. 2007): 2016 (5L co I2y (19 Pollutant Emission Factor Actual Calendar Year Emission2 Requested Permitted Emissions Emission Factor Data Source Uncontrolled Basis Units Uncontrolled (Tons/Year) (Tons/Year) Tons/Year) (Tons/Year) Tons/Year) Controlled (Tons/Year) ) 0.068 Ib/MMBtu N/A N/A l • Co AP -42 VOC (4 , 111- lbs/bbl '503-2' 15 • 4 ProMax CO 0.310 Ib/MMBttt N/A N/A -4 . i AP -42 Benzene qi , 61E-3 lbs/bbl , (04 . 0 ProMax Toluene 1,1,o -.5 lbs/bbl . 5(-1 • v'5 ProMax Ethylbenzcne 5,(9 6- 4 lbs/bbl ,pllr , OcY), ProMax Xylenes .b ?%fa a -3 Ibs/bbl _ . 7,5 . o I PmMax n -Hexane 622 , 022O e.-), ^ lbs/bbl 9•, '70 .2-� ProMax ',2,4-Trimethylpentane ( • � 5 r,'3 lbs/bbl . ► U . D I ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to re fort o�ilutants not listed above. ction 10 —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 yerag t to a neral permit GP0I or GP08. I further certify that this sot rce is an 1l will be operated in full compliance with each condition of the applicable general permit. t 1 l 7 Jerry Brian Mgr. Environmental and Health mature of Prson Legally Authorized to Supply Data Date Name of Legally Authorized Person (Please print) Title You may be charged an additional APEN fee for APEN re -submittal due to incorrectly filled -out APEN or missing information. Annual emissions fees will be based on actual emissions reported here. additional Information tequired: Cig FORM APCD-20 Attach a pressurizcdpre-flash condensate extended liquids analysis, RVP & API analysis of the post -flash oil Attach E&P Tanks input & emission estimate documentation (or equivalent simulation report/test results) Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses Page 2 of 2 0 Check box to request copy of draft permit prior to issuance. Check box to request copy of draft permit prior to public notice. AP_Form-APCD-205-Condensate-Tanks-APEN (96.5%).doc E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Synergy Resources Corporation Source Name: Fagerberg 33-12 Pad Emissions Source AIRS ID2: / / Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 41847 Fagerberg 36C -7-M 05 - 123 - 41848 Fagerberg 25N -7B -M r 05 - 123 - 41849 Fagerberg 11C -7-M L 05 - 123 - 41850 Fagerberg 28N -18B -M I 05 - 123 - 41851 Fagerberg 25N(S)-7B-M r 05 - 123 - 41852 Fagerberg 23N -7C -M 05 -123 - 41853 Fagerberg 36N -7B -M @ 05 -123 - 41854 Fagerberg 25N -7C -M @ 05 -123 - 41855 Fagerberg 11N -7B -M I - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 AP FormAPCD-212-EP-StorageTank-APEN-Addendum.docx Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy. your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17 L/ E0/0 s I AIRS ID Number: (2.3 /gF08/ b02 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Synergy Resources Corporation Site Name: Fagerberg 33-12 Pad Site Location: SWSW Sec. 12 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Greeley, CO 80634 E -Mail Address': jbrian@syrginfo.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Jerry Brian Phone Number: (720) 616-4300 i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 12/2016 357414 „ATI?" COLORADO • 1 I M*.Ithb n,flr, Hwal�t� b Envennrnavu Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit A and AIRS ID] sip Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source Request coverage under traditional construction permit -OR - ❑ Request coverage under General Permit GP073 ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 In addition to the APEN filing fee ($152.90), a General Permit fee of $250.00 will be assessed. a For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Contingency truck load out of condensate from storage tanks. Facility equipment Identification: LDG-1 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 10 /19 / 2016 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 12/2016 ❑✓ Yes ❑ No ❑ Yes 0 No ❑ Yes ❑✓ No ✓❑ Yes ❑ No ❑ Yes ❑✓ No ❑ Yes 2 No ❑ Yes 2 No COLORADO Mn 2 I Ai °' bepartmertd Rabbis Hutch E Ertwnnmem ii;' Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the followin: cC 2,016 4d-Ua Requested Volume Loaded5: ' Requested values will become permit limitations. Requested limit(s) should consider future process growth 1'4,9 D-1 Bbl/yr 96,912 Bbl/yr Actual Volume Loaded: This product is loaded from tanks at this facility into: tank trucks (eg, "rail tank cars" or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: �.6 Average temperature of bulk liquid loading: q p O ° F True Vapor Pressure: ' Psia 60 ° F Molecular weight of displaced vapors: P to Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth Bbl/yr Actual Volume Loaded: 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 12/2016 3 I AVCOLORADO H��,�t= Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.498896, -104.734126 Operator` Stack ID No. Discharge Height Above Ground Level (Feet) Tem p ('F) Flow Rate (ACFM) Velocity {ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward El Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): El Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: Rating: Type: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu / hr Make/Model: % Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes El No Pilot burner Rating: Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: 0/0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 4 1 ��COLORADO Fr�wb� �= Permit Number. AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑✓ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (%reduction in emissions) PM SO„ NOx CO VOC HAPs Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate 0 Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: 2016 Pollutant Uncontrolled Emission - Factor - Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual -Annual Emissions - _ __.. r., .._._ Requested Annual Permit Em ssiori t(s) ion L tmit(s Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM Sax NOx CO VOC $.15F-1 Ibs/bbl Pe -4-2 \f7 -?-.\5.a-3- . • `'I a .i Benzene Ibs/bbl Toluene 9,116-3 0. 0. -O De.A,n Ethylbenzene Xylenes Co. (o06-3 O. - 0 ,3`)- be pt(C) n -Hexane 8.11E-5 lbs/bbl O.Lto G, Li0 Pew -el 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 .I' 5 I ®V, COLORADO id I;I Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit rY and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature ofLegally Authorized Person (not a vendor or consultant) Date Jerry Brian Mgr. Environmental and Health Name (print) Title Check the appropriate box to request a copy of the: El 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 COLORADO Form APCD-2O8 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 Hello