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Home My WebLink About20194968.tiffCOLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 3, 2019 Dear Sir or Madam: On December 4, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Verdad Resources, LLC - HDI KF 01-65-10 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 Ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pvbl;c CG: PL-(TP) WL(Lb , Pt4(sr+/ER/cN/CK', OG (p' 11/09/141 2019-4968 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Verdad Resources, LLC - HDI KF 01-65-10 Pad - Weld County Notice Period Begins: December 4, 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: HDI KF 01-65-10 Pad Oil and gas well production facility SESE Section 10, T2N, R65W Weld County The proposed project or activity is as follows: Applicant proposes to operate a new oil and gas well production facility servicing production from eight (8) newly producing wells. Permitted equipment includes storage tanks, condensate loadout to tanker trucks, and flaring of gas from separators during gas recovery system downtime. 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 19WE0916 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 COLORADO Department of Public Haaittt & Environment Denver, Colorado 80246-1530 2 COLORADO Department of Public Health & Environment COLORADO Air Pollution Control Division Department of Publtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0916 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County:. Description: Verdad Resources LLC HDI KF 01-65-10 Pad 123/A088 SESE Sec 10 T1 N R65W Weld County Well Production Facility Equipment or activity, subject to this permit: 1 Facility Equipment ID AIRS Point Eq• uipment Description Emissions Control Description TK01-08 001 Eight (8) 538 barrel fixed roof condensate storage vessels connected via liquid manifold. Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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 8 COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section 11.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO TK01-08 001 -- 1.5 24.4 6.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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 8 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 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 TK01-08 001 Enclosed Combustor 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 TK01-08 001 Condensate Throughput 1,275,000 barrels The owner or operator must monitor monthly process rates based on the calendar month. 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 8 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 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 upon installation of the combustion device. 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 permt 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 Et MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Divisions in order to demonstrate compliance on an ongoing basis withthe 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. 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: Page 4 of 8 COLORADO Air Pollution Control Division Department of Pubitc'Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility 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 20. The requirements of Colorado Regulation No. 3, Part D must 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 7a'' 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4/V.A.7.B). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not 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 Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health & 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. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ob 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. B Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources, LLC Synthetic minor permit at new well production facility Page 6 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing ail 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 2,142 107 Toluene 108883 1,462 73 Ethylbenzene 100414 119 6 Xylenes 1330207 371 19 n -Hexane 110543 16,150 808 2,2,4- Trimethylpentane 540841 34 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0022 0.0022 AP -42 Chapter 13.5 and ProMax CO 0.0102 0.0102 VOC 0.7628 0.0381 ProMax and site - specific sampling 71432 Benzene 0.0017 8.4E-05 Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment 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 108883 Toluene 0.0011 5.7E-05 1330207 Xylene 0.0003 1.5E-05 110543 n -Hexane 0.0127 6.3E-04 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 Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listedbelow: http: //www.ecfr.Rov/ 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 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package It Received Date: Review Start Date: Bradley Cedes,' 416163 9/5/20W 1-. 11/1/2919 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Expl�ration & 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? SESE quadrant of Section 10, Township 18, Range 65W Weld County Section 02 - Emissions Units In Permit Application Fine (NOx & VOC) Quadrant Section Township Range SESE 10 1 65 AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks eA) Condensate Tank TK01-08 yes " 19vvE0916 1 Permit Initial issuance Permit Initial Issuance. Permit Initial • Prote'F`Tank PW01-04_. 9WE0917 _. yes id Loading TL01 19WE091s. Separator Venting I-A/ENV) 191/1/F0919 -` Yes P 005 VRT-VENiTO1 9WE0920 Issuance Section 03 - Description of Project Applicant propses tooperate a new oil andgas well pad servicing production from eight (8) newly producing NNSR purposes. is requesting synttjet minor VOCI mits for Production from eight wells flows to eight (8) horizontal 3 -phase heated separators. Gas from this stage of separation is routed directly to the sales pipeline, water is routed to produced water tanks and condensate flows to one (1) vertical heated 3 -phase senator. Gas from the vertical separator is routed toil -of 2 NG;RiCE powered compression unitsend into the sales gas pipeline. Water is.directed to the produced water tanks and condensate flows,to one (1) vaporrecoverytower (VRT). Gas from the VRT it routed to a separate NGRICE pouiered eompressoruiiit and Tinto the:sales gas pipeline. Condensate flows to eight (8) condensate storage tanks. During=VRU (i.e. NG RICE powered compression units). downtime, gas is directed -to two (2) enclosed combustors. Applicant provided APEN addendums and revised calculations on 11/14119 to reflect updated operating conditions of the VRT (revised from 5 psig to ll psig). This increases emissi n• rofile fore ,u, .. .. .. g p t'anksanddeaeasesthQproFileforURT 1{Jitht(alsrevision appllcantalsoupdatedrequested'emtssmns,,i The application indicates that produced water tanks qualify for categorical exemption in Regulation.3 (as of 11/25/19) . However, after discussion wi email (rec'd 11/22/19), applicant will request a permit forthis point. he applica Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? RequestiagSynthetic Mieor Permif. 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: 502 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, indicate programs and which pollutants: SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) .. NOx NOx _ No .. Yes CO — _, CO _ VOC — VOC _ P PM2.5 J '1 PM2.5 PM10 • PM10 TSP HAPs — U Q TSP HAPs _ • • Condensate Storage Tankers; Em:ssiens inventory Ipa rarnSlo: _ section. • Equipment nmmwlnn Gnaw DevicefedaMsotor' nen... On.. WC. H. moo. Mick, kr section. -.mks Rote lydomeuon for Ern.... Estimates kinwrykolulons-Starszerank0 Actual ntueaput Iflesuested Pan. Skratihrounksaan rental m En.(rrEl“ndemam rdmu�:put d ba rre I O.6 narvmr rm.00. Barrels N. per year ', rnsmf- Barrels (ben per yeer Secondary misslons -Combustion...Ira Heat content.... acts= W produced .gas emdmd px 0tor Actual Matron...waste nes routed to tlondevice ...rested hencontent ekes. pas routed...hustler.... Req ds,.onttmvouµput. tp.V Barehas. Per monm I 'Modes Van C.0:10.0 INARISU per.. Eotendal mEM[(rrElbeetcontent ofumte ass routed m wmLusdon device= rk.09A.4 INNIFISU per year Control... rniks err... are reported and tracked separately aeon We If karat... seotko-PmlvloneFactors ®nr tnodoigres enissknst Pollutant IIMMI MIME E ME ME II iME IIEMMEM MIrE EOM MIWIMEMM r U ®.. w u Ina M1eat knell ERB knission Sector.... mumrstimEnmmmm,, minammi =moor Sodon Inventors Crtede vollotann VOC PINIO Potendal Fmk Uncontrolled yr-sheen Controlled Uncontrolled (tons/year) Requested Dolled pct Uncontrolled (tons/yea. Sanaa Peon.. Montt. tarn Controlled (ms/monml 262-9. Hazardous Air Polk.. ueNbenaene xvim Potential Acural Emissions Uncontrolled Controlred Peglanted Dolled Controlledpe rr (mdr.-n plapearl 2192 110 .150 etn eeule or um r n s • Regulation 3, Parts A. 0 liendatIon Peaubmn],sxMn vI.G,C uFUWon"1.5eeWn 1,2.0. CA. C.3 Sour. own.. n. pankit e uw on.aktekk...rikSercnr.G't4C3 knrsantarkk soak ers ...Ono knack. ...non 6..0. ran.Suepartae Revlon. b, kink.. w bpert 0000 NSF5.1,3rt 00008 Regulation nrlavta, Ism msulavorvaialIusdky*sheaf. dot.. am.. storm. Tank iSnrrItut... OCOE, :mrr a:V \ 0SWE.aa<PI_am Condensate Ste Took(s) Erorsnlens ineaotery seen rn - Imdsl end vmed,c sa mping and Tcodna Requirements Dees do camper', use Posh. Ieultemmlons factors Wed.. amhslom, Ilya, cradle uncontrolled att. or requmred emissions a.ma.d cohe greater Nan or equal m go tons VOL permart ranNaN Mm , the permit., condo aelnlhal Compliance'.stins reoutrementto develop a sI. rpm. emistons Irmr bad on outdate. In Ps Memo dsa1. Does Me company use aelte specMc emssions factor m est..e a..? yos and IrMere ere dash emOrlancrarens factors based one preaurhed Mold sample drawn atthe rybei ng permttrtdtThisaeub mpMhe [moldered repuen.tluen penendy means site -specific and colleMed thin oneyear e mo.. um received x f tier It Me leak Fm not been mar.. le.g, no neemeells dmughtonilllelfMerl 'MeV apprapdam to use en oldetel.zpe.tc moper dm, doper-m.1C contain en 'Initial Compliance'pstlnt requirement to demi, asbespwific emlsskm factor based on guldennes efficiency grealetNan.%bra threw combustion dolled dyes, the pemit W A con. con. andlti9 CompNnce wtcomMon m d ema mgzm the dmbuoion edlkhemy err the combustion d n#a based on Inlet and cutler concmbadon amollna section re- invernomocc Ceding and Mans Metom AIRSPaIMP Pmeesg s¢eme _ _ wir of -..._ .rv....�. ... y....,,,,„,,.. .. Uncontrolled Pane PM. 110e COS VOC CO Pemene Toluene thvlene ylene CO b/1. 00 plans condor.. Mmughuc b/1.tm pio nscondens. th rough pu t IMI.rmpllonscondenno throughout b/t.ao gallons condense. throughput b/i.cmfnapnscondenoteMrougnour bty.mpaons condensate throlltdenue b/L. 0plans condenvrte throughput en 00olim� condensate b/S,cmPallons condensatenthroughout bn.00D pl=m con denote throughput 3ar1s gtP.VDfstswxmlG.ai.ssm CMIdenate Tank aegulamryAnatysk Worksheet Colorado Regulation 3ParesA MR-APEN an,d Per. ...met. 150( .enbn.re.agn Aamnmm�.Amn ATTAINMENT' L Axe uncontmnea.mi amnions m amvartede polutamrmm tn4bamaual source greater than 3 mdla.auixion 3,Pn Asenwn 11.0.1.31, ate lservke duipmrto12/ Ran me not modified artass/31/a0nl5oeP5 Memo nsulafinklasl.uadl.laand section amradnmma rvlaance w vanMxwapprobllMi 3. ...Malk,' unmmrmlea v0e emissions {naatnan sip:, Na greater than loTW or CO emwkna greaterman10, Meaolakn 3, Pena, saalon ll.a3p L Are rmcenteodN einrmanahomanyaaw pollutants (Tom tmrMhwual source pemrthanlTn@ogle. 3,mrthsmbn 0.0.v13 art beniadm.l parml3Mo/tdmand not modified anxu/31/21:02, eP5 Memo uselafinkanaLssaneLlaana3ewon:Nraaalwnal ruwn:en granaMneragmonmyli 3. Are total 'milk, uncontrolled VOL emissions greater than 1Trv, NO5 greater than siwnreneni.ons'treater than 10Trvlaeaulamn3,nrta,sann 11.0.213 letafg 1. kl data geta?,seemsInd,. tank lecirted Mu twee control area orany ozone nonattaintnent area or attainment/maintenance aaa 1. 15tbis storage tank located atm od and eas.sloration and Mn gpoabmumnxvara mmmwrnabn ornxvalwmpmaenx Ismr.rman.ba,hpa:ro<kpinv::n i 3,_:n:r�n:.:s Section XILC51 —General Requirunl erraPoll.. Control Equipment —Prevention of Leakage SecaanXILO Control Repots -men. Section wl.F-uaoa wngand Porn ColoradoReplatlan ',Seaton SLR 1.:t.Ro a non-am...am area oratemneetimamtenoce area? tanb loafed at a 3. n5.stneltH natural:,e�tr nee a`rtmntedZIdnemiubnaand have uncontrolled actUal.mlanm greater than or coal le xtnM per year van Section Section Intl -General raatenisf Air wwtbn Conti Equipment-nevennnn n Leakage. Sect55nXii.C.2-ErnisabnEstiniation ',Myra Colorado Regulation 7.5eNon 1. lathistank located at wnn/atologelaellrvx 3. 4.4 candeRaate stomp tanh' located at an.and gas orlon and promabnonaabn, v uapnnalbe,natuel essmmo/aw stationor natuagavmomng Wm3 3. la this condensatestaraptankalt5e0 roafstorage tank, a. Are uncontnal4d actual emlasions•of thtsstorage tank equal to or greater than 6tona per year VOC3 Iwr Section 10/11.C.1.Ernissions Co ntrol x11 prmwow s, toe on,stxyrmd-!in.? sectson.R.Ca• Capture and Monkodngbr sorer Tanbmtea wltb Air Pollution control Equipment 4.{.=R Pan 60 Subpart Kix or Veto. smw�P.RI•r xertx.n3or ectue to 73 ranee eteclm'II anbaisp 0 11b(d)(q? a. ...vessel basal:sign apatby lesathan or equal am'(.10 ee1),uad n.atecered, processn.a ea.ore pr. ecustody nrrer' a 2223#32136asst2? mail/led (see definitions 40CF3, e0?)armrduiyae,v3g, 4. De.thatanbeneet thedeffnition al 'storage 5.M.'In 50.1111, 5. Oa. themrape vesselsoare ic aquq (v0t1•s a defined In 60.11143 f the additional ionc R. o eestela pressure ume desl6ped too,.Inof 204,9 wa Ms.?pal] and without eawons to the whore (50.110taa1(11po n opy4 greater or equal to m' H30 SRI and storm aIqua sum a maximum true wpor preamre`ess 160.110bIb11?l wor design opacity is pester than or equal to 73 M' (^473 BBL) but seaman 111 m' (-35,1331.](-35,1331.] and daeapuMwimamaw, uewknewpor ransom' less than lsokm(6011O4rydp J. nerogmwn2emwwnawmmmrmreoulaement5 a. node. apaatyxe ore 151m' (-3501131.] ananiruM1 a kW.,.a mmmum cue vaporp.mum greater or equal m 3.5. ins than 5.1., or e.The apadry b eeaere than or yea m731.4' ,4721331) but roman 131m' i...950 eau and nitre a iaum with a mam Inc bnuwporpessue 6mxerm11 an or equal to .0 5%but lust. 11.6 kpai ,<mm.5.5x3 nm..gar -N.s_ fib urn. Partwsmlaart0000/eaow..mwmanPenananafor Crude Oaand wlvral Melon.. Tmmmalnnand osaemm istim rondehiata storage vessel locrtedat Malty in the onshore all kele eamumn.aasegment, Mei ttte w".',rooming miernkmemwaaaammsran t on and Industry? led lseeeennnammcFa, e0.21 xne3ePtenberv, a0ssr 4. Are potential VOC emIstIons. frorn trell.dualatoragaveasel greater than or equal to 6 Wm sn0laa.s. 2 6. Isthe venal wbaemetigwaml controueam ®ba of � Wren.forstara.e vessels In urea Paaeomb am urmuxPan63 tab artxx? storage rosr...tae Mote: Nano..a.uws.Nspmwauwaerambwa to be subject. 26Psaaoo/0a0a due to emNbna abwatwa perynetmeenene epprahaltsanermrwbu date, It should mournayen to 1.15A5 0000/0000a per 303355(.121/e2s3ccae2Nw.n avom„mlwc.nNmuserop4.bw6 P.ay.ad 40 CFR. 473, Subpart 5352.255203 and Ca.3,oaua55 Fuca.. 1. lathe . n uallty that meets Ober of the tollowingemerb: a. Ataenitywl xv Done, upwdes or stores 1puas' 163.?601aµln:On b.tactxymat upgradesorstoresnatural gal m prior me po.at wnkhnatuawemmNrc,utuaRa l gas and smnmtmw aaeure.e5,,,,,,,..5s, a aiseuser' (53.760(.113117 del tar NeA? 4. Doesthetank 'neat the dd.. of 'storage Igml with the potential for flash ernisslone per 63.7e1i, 551 lion: Gate ovtpuntion Source Requires. MT. Continuo -you bare ...zed encnyroe onth pml�summ.rrrmeet. rvehn< source bsubjec Ccmtinue -You md.asw,mamkw. Maraca Tani. not have to xtulatbn t?x lsemm�e =us en have Imitated fealty %we on woke aumm an• she.. Indlaedikemuae merry on the Prolensummaryaneet. Go to the net question- you bafie lndlead hat, tweon project Mornersnnt. Go tothe next n a source ambito to pals. ReRuiallon-7,.ctionaX 5t25C w to the next5ueaon Go tone nen queSlon Storage Take nxwbleo N6Pskb. Vigil Continue •Vou won the Pnlecsummaa,Me. Storage,. 4 not subject MPSWOO .atothe next question tmmntlnuedefaming. of Nps0000aapp.° . Storage Tank b rem subject revs 00oa. lyre Iaminue -you have Indicated memurce category on the Project 3ummxysbeen I3m 3rb:ea?Mxei10l .bpa2.4. General prowbm 5.2433.33.1 41 22452 ntroiwndar. §53.3,3-Monmring g6ina-Pcnrdbeepine 553775 -Reporting RAU Rau RACY 'Mew b rewired Nsnol.Lkn JIM not ApolyaNO3tMmnk2btne renatWmn.ntaru. It the tank meta both cearra.tnen review wer,.wkemma DIstlainter an wins*eminingpgfmd2MP/cert. 'egaemerodae cbne3Ag nalmpmwNirq rapwema exaso MCon3o'Cara., dorm.,r., and Umm.r,arnettammi2may 2 epp,H2bnb°�rpti ua...,tw m. pe.mm�n a.rM.and2u,ua�mw .T2.. 2#2,T 0 chanAreat.le ma /a'romw, maul,.. end nd72 by*N requirementbbara.march ad pie enarsrwwnbma o-awowrtacwmmnalantyuarrom.Stebyaoedmenardng2regal. winm,md, Trouaodrno..,r. aganan•,�anmea,•smr: 'nroaM,'ae an Ndmdeab Inwpmbbv end rearrvreummv. Maraminylennbomrysuan as•waraa',,2205 are 'maidla demi bemnkoyna reparamerg ua thebrmdaw CM. Marc, QuagilyConIrd rn.—n*Rampima. bd. dvmwaea@ mda.Mab mgenyeemq r pteuve In nda... 5.k h not mbutct MALT XX-Then aro no MAG XN requlremoMfor UnW atareamurm Produced ',Neter Storage €'ank(s} Emissions Inventory sawnm laolorne. .....m• fn.. Control DevIce sawn m-vm..uw Rev Infom,donwr u,awm sdmm• _ gT•wa m1wmldlmn- I � em. Twd�wa= mk IPrzl Produced0000 m�bpH. mb n. dvkl Heat cont. of g mI dp.re[Lofkry. Volume aaanen eat mit ..ae[aemadto.omeoamn Ion P•q atd Feat mlde,eolwaste gsm.dtnmmam�Inneaare. Potential tolmltlp1EOFeat oe. otvono g. routed to ...Ion eva.e= mPgnog Sas .....year Control DevIon Pew.td Mont. .wa.,.n- HAMSIV kiM110111per year .er.aay a. an lwg laom aaylN e•dlenw PmkaomP«,om.Mao.. Produced Wear,. Urcormolled controlled MIENIMIEW (I... IP..dooea. O 0000 • control omIce Uncontrolled Uncontrolled Uncontrolled uncorerollel I 00mbma•dl MCMINN MEEEMOI EmiesIon Factor Sour. sow..os mld.minventors VOC CO keentrel r00nan Actuale Con::olled now, n.etiean uncontrolled Cootrollel ont. uma a/Control. l 131 xmmous Pao.. Toluene 0M1dh. Sr. yea Uns.,w.l Uncontrolled on..d Requested PernUttlr. Untontrolled Coaled tllohaed VIHO .00 a„b,l Iwrnon. Paulanonl Sec..11.1 U,C3 von v, SKIM W11.G1 P>Wadon s, P0.5,0.5..010 neguhuvn s, Pan.,eaSPS.S.part 0.000 NSPS aim .300a Is•• r.ato .nplIceld..m0M1••t for de0P•dan.laoil Amanm �Idld•d M.ldlesmplw[adT.aure wganmam Doeuabemmpany uses 0Neapedlken.on.faaoatoeermatevnt4wui ff yes and If.. amlla•M1 enbdom,aret0eemwwnfaaon baud on a pre.. Ikud....led.. at ea (a1[P ...Honnkld and an .., mN[da.M1 6manon anal,.TW sampk.M1oud bemroNedrey:eemauvvuAkM1 general. means at oratthea... iaeiveidaolder xa.eaev[ 000,o..we been rnak., no now kmN 1. sop, . to Leman oldereseaper...e. Vogt...m.0i con. n In..10..nre tam[rev.. tto... altespe...ionsfacror..P3 Memo Does . company nen. de..mamvl.v�for If pm.m vambwn..,.wm w. t.ane.w�.nt mem,eneree_medee. n�t%,emmeoamnmokebeted or and out.oanconI.at%ontan.. TTH 01 .400,05 Amd losses Poll.. Few I%PWt000glav kaana.,d,.d phas:..as:0.0 ab/..Poogam aaatnm.gl.[ 0.0 16/1.000 glom0.0 aaa 01oo00 .s 95.0 aen.Ppp gam aaa mma,�w� a/1.umgamaadtbmo[bw: 05.0 gb/ayoggamllgaa0M1lvuebM 55v9b/d.aooplknaawaelvvad,P4 a0dbmaelx m/tell put ..ugh xden. Ib/d,00 gallons Ndquldllospleput ,dean. 0..000 55.0 16/1,000 gallons lgmatbmtplwn NOR VOC co Penanno 0.12.6U Produced Water Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts Aand B-APEN and Permit Requirements 'source kin the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A, Section II.D.1.a(? 2. Is the operator claiming less than 1% crude oil and is the tank located ate non-commercial facility for processing ail and gas wastewater? (Regulation 3, Part B, Section ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NO5 greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? 'You haveindicated that source is In the ruoo-Attoinrnent Area NON -ATTAINMENT 1. Are uncontrolled emissionsfrom any criteria pollutants from this individual source greater then 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located et a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section lI.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOR greater than 5 TPY car CO emissions greater than CO TPY (Regulation 3, Part 5,Section 11.D.2)? 'Source requires APEN, is permit exempt Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water 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 produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tans per year VOC? 'Storage tank is subject to Regulation 7, Bastion XvII,B, C<1 & C..9 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 produced water storage tank contain only 5stabi11eed" liquids? If no, the following additional provisions apply. IStmage tank is solject to Regulation 7. Section XVII.C.2 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part GO, 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 (m) [^472 BBLt)? 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 m' (^10,000 BBL] used far petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.1116? 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"' In 60.111h? - 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.1116? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storegevessel a pressure vessel designed to operate in excess 01204.9 kPa [^29.7 psi] and without emissionsto the atmosphere (60.110b(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 pressure' less than 3.5 kPa (60.11ob(b()7; or c, The design capacity is greater than or equal to 75 M' [^472 BBL] but less than 151 m [-'950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? 7. Does the storage tank meet either one of the following exemptions from control requirements: a. The design capacity Is greater than or equal to 151 m' [-950 Bell and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. The design capacity is greater than or equal to 75 M' [-'472 BBL] but less than 151 m' [`950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? WIMP Storage -rankly not subject to SOPS Kb 40 CFR, Part 60, Subpart 0000/g000e. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore all and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 15, 2015? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Does this produced water storage vessel meet the definition of"storage vessel"' per 60.5430/60.5430x? 6. Is the storage vessel sublert to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart NN? Not enough information [Note: If a storage vessel is previously determined to be subject to NOS 0000/o000a due to emissions above 6tons per year VOC on the applicability determination date, It should remain subject to NIPS 0000/00004 per RACT Review RACT review is required If Regulation 7 does not apph/ AND If the tank is in the non -attainment area. It 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 conaicf between the language of this document and the language of the Clean Air Ad„ ifs 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 g5%!„ A kAitKA Yes yagglf aSI Hydrocarbon Loadout Emissions Inventory Section 01 -Administrative Information 'Facility AIRs ID: A088 Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? dracarbon loadout to tank tracks,. on, Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information far Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit LimitThrouglput= Potential to Emit (PTE) Volume Loaded = Barrels (bbl) per year Barrels (bbl) per year Barrels (661) per year Requested Monthly Throughput = 108286 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas= Actual Volume of waste gas emitted per year= Requested 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 = .7.368:P;t, Btu/scf 1484466 scf/year 2523592 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = MMBTU per year MMBTU per year 5,971 MMBTU per year Control Device Pilot fuel Use Rate: Pilot Fuel Gas Heating Value: 'Pilot emissions are reported and tracked separately as an insignificant activity Section 04- Emissions Factors.& Methodologies Does the company use the storm default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? scfh Btu/scf 0.0 MMscf/yr 0.0 MMBTU/yr T e state default emissions factors may be used to estimate emissions. Hydrocarbon Loadout Emission Factor Source Pollutant Uncontrolled Controlled (Ib/hhl) (lb/bbl) (Volume Loaded) (Volume Loaded) EIMMIZEMIIIIIINEEMIMEIMEMBEe �' MEMI Ey, L .• 1.07E'06 MEIIIMMIIIy a MMIIMMEIME 3.606-08 1.80E-04 Pollutant Control Device Emission Factor Source (16/MMBtu) (16/661) (waste heat combusted) (Volume Loaded) p it007.6 '® IMMZEI;1 ifu07fir xs =MEW 0000 r ,' ,® ®. ti ttaiv . .. C Pollutant Pilot Light Emissions Emission Factor Source Uncontrolled Uncontrolled (Waste Heat Combusted) (Pilot Gas Throughput) ® IMEMB1. ®' EIMECI 0.0000 0.0500 W&B Losses WOO fraction From ProMax VOC ton/yr VOC 66.1000 100.00% Benzene Toluene 0.006 0.01% Ethylbenzene 0.0076 0.01% Xylene 0.021 0.03% n -Hexane 224 TMP 0.0023 0.00% 7 of 17 K:\PA\2019\19 W E0916.CPLxlsm Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/yearl Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.02 0.01. 0,0E 0.02 0.02 4 0.02 0.01 0.0E 0.02 0.02 4 0.00 0,00 0.00 0.00 0.00 0 0.20 0.12 . 0.12 0.20 0.20 34 150.45 00.50 4.43 150.45 7,52 1270 0.33 0.54 0.54 0.93 • 0.93 157 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/yeer) Actual Emissions Uncontrolled Controlled (Ibs/yeer) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/yeer) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 523 308 15 523 26 27 16 1 27 1 35 20 'E 35 2 96 56 3 96 S 4590 2700 135 4500 230 10 fr 0 10 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B RACr- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) Source requires a permit The Ioadout must operate with submerged Mond loudest emissions must be routed to flare to satisfy RACT. Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% fora 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 The heat content and molecular weight o€wastegas (used mcalculatidia for Volume of waste gas emitted) is based on the properties ofworkmg and breathing emissmnsas moons "'Applicant (lid net report emissions of HAP aside from those with Division approved. standard it standard However, sinceapplicaM s using working anddbreathing properties— mbustion emissions, I find it1-damnable t the W&6 composition to estimateof toluene, thylbeItne, btfenesnd 224-TMP. The t of each HAP tbo'l each was multiplied by thestate defua It VOC emission fact r This ly rs resu is in no HAP (aside from benzene and ,t exanel above APEN report ng threshold Section 09- Inventory SCC Coding and Emissions Factors AIRS Point 0 003 Process SCC Code 01 4-06-00132 Crude Oil, Submerged Loading Normal Service (5=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 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.6 05 lb/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.01 99 lb/1,000 gallons transferred Toluene 0.00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 IS 16/1,000 gallons transferred n -Hexane 0.00 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 8 of 17 KI\PA\2019\19W E0916.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re. ulatian 3 Parts A and B -APES and Permit Requirements (Source is in the Nan-Aiteinmont Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 WY (Regulation 3, Part A, Section 11.01x)7 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part 0, Section 11,0.1.1)7 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 bhls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOn greeterthen 10 TPY or Ca emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)7 IYou hove indicated that course is In the hbn-Attalnment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than l TPY (Regulation 3, Part A, Section ll.D.La)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Parts, Section 11.0.1.1)7 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 loading1ess than 6,750 bbis per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 Ibis 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 WV or CO emissions greater than vo TPY (Regulation 3, Part B, Section 11.0.2)? (Source requires a permit 7. RACT-Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy(Regulation 3, Part B, Section lll.D.2.a(? liho laadaut must operate with submerged Nil and Madan emissions must be routed to Rare 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 igulations. 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 Stifle 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 unoarthe temis 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 e. yWoel Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 123 County Plant Point Section 02 - Equipment Description Details Venting of ga Detailed Emissions Unit Description: Limited Process Parameter Section 03 - Processing Rate Information for Emissions Estimates 30,000:0; Barrels (bbl) per year Requested Permit Limit Throughput =-, - • 51,000.0._ Barrels (bbl) per year Requested Monthly Throughput = 4331.S Barrels (bbl) per month Potential to Emit (P16) Throughput = 11000.€1 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: 2.394944294 MMscf/yr vented (requested) 'pilot emissions for combustor are calculated and reported separately with insignificant activities. This is a common combustor for multiple points. Section 04 - Emissions Factors & Methodologies Description MW ed=sepziatomreceive wellhead fluids e, eight (8) wells. Gas from the 3 -phase Imnzoneal he ssparat' is. lied a pressurized liquid condensate sample ft m one of the 3 -phase horizontal p ator mode m: perating pressure of A9 psig and temperature of: 1131. The modefed'operatmg coad:tions.oa the healer treater is he ProMax simulation submitted 9/5/19 ,37.2 Ib tb-mol U/eight CO2 2.4 N2 R4 methane 130 ethane-'' 19„6 propane 26. isobutane 53 n -butane 12.9 pentane 4.7. n -pentane 5.7 cyclopentane 5.4 n -Hexane 191 cyclohexane 0.6 2-methylpentane 3.T heptanes 1.65 methylcyclohexane 0.6. 224-TMP 50 Benzene 03. Toluene 0.3. E ylbenzene 0.5 Xylenes 5.1'. C8+ Heavies 1.0 Total VOC Wt % 99.3 61.5 Displacement Equation _x=(3MWrxx/C ed to the horizontal heater tree, r -phase paraator)sovered bythis ough the heater rreaWrg PMaz. Ti . epresentaesample indicate ig/13OF. The composition reflected below representt t1t uHttlBl*CftN 10 of 17 K:\PA\2019\19WE0916.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (Ib/661) (lb/bbl) (Liquid Throughput) (Liquid Throughput) VOC 2,3975 0.0126 0,0113 0.09.1.2 0,0040 0.0066 0.0002 0.1449 0.0006 0.0006 0,0001 0.0002 0.0041 0.0000 Benzene Toluene Ethvlbenzene Xylene n -Hexane 224 TMP Emission Factor Source Emission Factor Source Pollutant Primary Control Device Uncontrolled lb/bbl Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 0:007 0.0007 0.0007 0.0001 0,0006 0,0301 _,...0.0075. SOx NOx CO 0.0006 0,0600.-:::: 0.3100 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) ' PM10 PM2.5 SOx NOx VOC CO 0.0 _, 0.0 0.0 0.02 0,02 3 0.0 0.0 0,0 0,02 0.02 .3 0.0 0,0 0.0 0.00 0,00 0 0.2 0.1 0.1 0.17 0.11 _ 29 73.0 43.5 2.2 73.39 3,69 62.8 0.0 0.0 0.5 0,77 0.77 130 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled fibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 642 318 19 642 32 574 338 17 - 574 29 59 35 2 59 3 204 120 0 204 10 4417 2598 130 4417 221 12 7 0 12 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 7, Section XVII.B,2, G The control device for this separator is not subject to Regulation 7, Section )IVil.B.2.e Section 07 - Initial and Periodic Sampling and Testing Requirements Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the equipment covered underthis AIRS ID) and process simulation to estimate emissions? g :N This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company request a control device efficiency greater than 95% for a flarefiercer 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 'The requested VRU downtime corresponds to about 3.5% based on nested d i- or to sonderis=_t 'I will approve the use of liquids throughput monitoring forthts emission port based on toe following ( ) emissions are only routed to the comoustor as an alternative: scenario to recycling gas to the sales line () uncontrolled requested emissions'of VOC are less than 1.00 tpy ( ) the pressurized liquid p directly upstream unit. b uid. sample was direct) pstreamaf the emission (iv) facility -wide emissions of VOC considering limits intiluded in proposed cons:mot on permits are 25 epy, ih s s well below the current major source threshold of 300 tpy VOC for N,ANSR and is further in place upon the pending edesignatios of the DFA'lFR zone 00,, '1a nmest area (from moderate to serious') Iv) I will require a site -specific extended gas anlays s be used to acree CAntratie that the weight VOC predicted in this model (62.2% VOC by weight) is accurate or conservative. This determination rn ay be reconsidered upon niodlficat onto increase the votern,tr cflow of gas to the combustors, or upon presentation of data suggesting that. the predicted gas composition is significantly inaccurate upon self certi ice Applicant indicates that gas from this unit will be recompressed using l of 2 compressors (CT &C2) In actual practice, the entirety of the gas stream will be recycled as long as l of the 2 compressors is running- However, the applicant conservatively assumes that HT gas (and VRT gas, see discussion on Point 005 tab) Is all sent to flare doririg Cl or C2 downtene, Pe tanks This is supported by the fact that only 3.5% of the expected vz,: or, are proposed to be corn busted.:.. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Pointil 004 Process 9 SCC Code 01 3-10-001-29 Oil & Gas Production: Gas/liquid separation Pollutant Uncontrolled Emissions Factor Control % Units PM10 0,7 Ib/1000bbl NOx 6.6 0 Ibj1000bb1 VOC 2097.5 95 ib/1000bbl CO 30.1 - 0 ib/S000bbi Benzene 12.6 _ 95 IL/2000bbl Toluene 11.3 95 tb/.1.000661 n -Hexane 06.6 95 0h/1000bbi 224 TMP 0.2 95 Ib/i000bbi Id thatwlllb 11 of 17 K:\PA\2019\19 W E0916.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re elation 3 Parts A. end B - APEN and Permit Requirements ISoarce is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2TPY (Regulation3, Part A, Secton 11.0.1.a(7 2. 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 5, Section 11.0.3)7 'You have indicated that some 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 11.0.1.a)7 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than it TPY (Regulation 3, Part 0, Section 11.0.2)7 JSnurco requires a rarinit Colorado Regulation Inaction XVII 1. Was the well newly constructed, hydraulically fractured, or recempleted on or after August 1,20147 'Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Central (Optional Section( a. Is this separator controlled by aback -up or alternate combustion device (I.e., not the primary control device) that is not enclosed? The control device for this separator is not subject is Ruguietibn ],Section XVII,B.2.a Section XVII.B.2a-Alternative emissions control equipment 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 ofthestatute 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. Separator Venting Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 123 A088 Plant 000 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Venting of gas from one(1) Vapor recove Enelosed'Zombustor' Emission Control Device Description: • Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Primary Emissions - Separator Actual Throughput = • section 03 - Processing Rate Information for Emissions Estimates 00'< Barrels (bbl) per year ower(VItT) duringvapor ).ecovery`unit(VRU) compe 95 duwntfine. Requested Permit Limit Throughput= 51,000 Barrels (bbl) per year Requested Monthly Throughput = 4331.5 MMscf per month Potential to Emit (PTE) Throughput = 01,00€) Barrels (bbl) per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: 195317 Btu/scf scf/bbl Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: `pilot emissions for combustor are calculated and reported separately with insignificant activities. This is a common combustor for multiple points. Section 04 - Emissions Factors & Methodologies seth Btu/scf 0.0 MMscf/yr Brght (8)3 phase hprrz e5alheated separators receive wellhead fluids from eighf (8) wells.. Gas from the 3 -phase horizontal heated separators is directed ₹or the borizast it heater treater )3-phaseseparator) co red by Point o041Subsegpea-rv- ppnd nsate framehe heat rtreat-er is directed to one (1)vapor recovery tnw r overed:hythm The rep pint. The appbcant putted apressurized liquid condensate sempte from one df th 3 -phase hnrFiontai §eparator3 and,modeled emissions through the heater treater and subseque rt)ytl a VRT u. ea PtoMar. TFe:representative sample indicates a 3 -phase horizontal separator operating pressure. of 89 psig and: temperature of 113F. The modeled operating conditions of the heater treater and VRT are 35_psigj130F andal psig/70F. respeetively.The composition reflected below represents the composition of the modeled stream ' VRU Gas" from the Prorvt as simutatioo:submftted 11[14(2019. Weight % Helium CO2 N2 methane ethane 3.0 0:3 15 24.3 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies ,5 4.9:: .0 3.5. (13 0.3 2.3 0.2 0:1 5.0 Total VOC Wt % 130.0 55.2 Ib/Ib-mol Emission Factors Separator Venting Uncontrolled Pollutant (Ib/bbl) Controlled (Ib/bbl) (Liquid Throughput) (Liquid Throughput) VOC 0..€,717 0.0005 0.0004 0,0900 0.0001 0.0033 0.0000 0.0088 0.0000 0,0000 0.0000 0.0000 0.0002 0.0000 Benzene Toluene Ethylbenzene X ene n -Hexane 224 TMP Displacement Equation Ex=Q'MW"Xx/C 13 of 17 K:\PA\2019\19 W E091s-CP1.xlsm Separator Venting Emissions Inventory Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) Emission Factor Source PM10 PM2.5 0.0075 0.0000 0,0000 ,3.0.0075 SOx NOx CO 0680..:'. (1.0004 0.0020 0.3100.:.. 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) PM10 PM2.5 SOx NOx VOC CO 0.0 0.0 0.0 0.00 0.00 0 0.0 0.0 0.0 0.00 0.00 0 0.0 0.0 0.0 0.00 0.00 0 0.0 0.0 0.0 0.01 0.0'1 2 4.4 2.6 0.1 4.38 0.22 37 • 0.0 0.0 0,0 0,05 OA5 9 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ihs/year). • (Ibs/year) . Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 25 ' . 15 - 1 '25 3. 18- 2 1 0 2 0 0 3 0 5 0 170 100 S 170 8 0 II 0 0 Il Section 06 - Re: ulatory Summary Analtmis Regulation 3, Parts A, B Regulation 7, Section XVII.6, G Regulation 7, Section XVII. B.2.e (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G Thu control device for this separator is not subject to Regulation 7, Section XVIl.B.2.e Section 07 - Initial and Periodic Sampling and Testing Requirements Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the "' f equipment covered under this AIRs ID) and process simulation toestimate emissions? This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company request a control dente 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 The facility diagram provided n the application displays one{i)`URk1tp�d`a"GM'UOrzec5.7L that is dedicated to the VRT sayers. 5ubsequentfy,:R shows that VRT vapors are recnmpres=edh one 111 afrwn (2i vapory unite used to co;npress hrat treater gas. As a result, it is suggested that Heater -treater VRU downt tee will result in gas nom hoth the VRT and HT being routed to flare. This scenario was confrmedioith the aop. cant who Indicates that. downtimetor the VRT will be recorded a_the. FighestvaI- e of recorded downtime in the comp! a ,c_ period between c .mp e s 1, z, and 3 e other wards, the downtime used to calculate emission for. the VRT will be at,..as as much downtime as reported for the heater'reater (so. tt 004j T II.I.I edto use liquid throughput monitoring as a su oga'ete demonstrate compliance wit used. ProMax sanulotion that undated the operating or` Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 005 01 3-10-001-29 Oil & Gas Production: Gasiiquid separation d to the flare. This: is acceptable monitoring m Pollutant PM10 PM2.5 SOx - NOx VOC CO Benzene Toluene Ethylhenzene Xylene n -Hexane 224 TMP ' Uncontrolled Emissions Factor Control 5 Units 0.0 0 lb/1000bbl 0.0 0 Ib/1000bbl 0.0 0 lb/10006b1 0.4 0 Ib/1000bb€ 171.7 95 Ib/100obbl 2.11 0 €b/.1.000bbl 0.5 95 Ib/S000bb1 0.4 95- €b/1000661 0.0 95 ib/1000bhl 0.1 95 ib/1005bbl 3.3 95 ib/10006hl 0.0 95 €h/l000bbl 14 of 17 K:\PA\2019\19 W E0916. CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re latlon 3 Parts A and B - APEN and Permit Requirements ISoerce is in the Non-Aftninmeat Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY (Regulation 3, Part A, Section II.D.1.a)7 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, N0N greater than SO TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)7 'Youta,. indicated that source kin 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 IIA.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NON greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7 'Sows. requires a permit Colorado Regulation 7,5ectlon XVII 1. Was the wet newly constructed, hydraulically fractured, orrecompleted on or after August 1, 2Q14? 'Source 3s subject to Regulation 7, Section XVii.B.2, *SAWA Section 0011.82 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G- Emissions Control Alternative Emissions Control (Optional Section). a. Is this separator controlled by a back-up or alternate combustion device (i.e., notthe primary control device) that is not enclosed? The coocrol device for this separator is net subject to Regulation 7, Section XVIl.B.2.a Section XVII.B.2.a —Alternative emissions control equipment 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 toe 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. Mandatorytemlinology such as 'must' end '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. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY- HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources LLC 123 A088 HDI KF 01-65-10 Pad History File Edit Date Ozone Status 11/1/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S 502 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S 502 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACIUTY TOTAL 0.0 0.0 0.0. 0.0 0.0 0.0 0.0 0.0 ' 50 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Fadlity - No Previous Total Previous Permitted Fecilrtv total 50 0.0 0.0 0.0 0.0 0.0 0.0 0.0 00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0016 Condensate Tanks 0.2 0.2 1.5 486.3 6.5 10.1 0.2 0.2 1.4 24.4 6.5 0.5 New CP 002 19WE0917 Produced Water Tanks 0.1 0.1 1.3 86.5 5.6 9.6 0.1 0.1 1.3 4.4 5.6 0.5 New CP 003 19WE0918 Condensate Loadout 0.0 0.0 0.2 150.5 1.0 26 0.0 0.0 0.2 7.6 1.0' 0.1 New CP 004 19WE0919 3 -phase (HT) separator venting 0.0 0.0 0.2 73.9 0.8 3.0 0.0 0.0 0.2 3.7 0.8 0.1 New CP 005 19WE0920 VRT venting - 0.0 0.0 0.0 4.4 0.1 0.1 0.0 0.0 0.0 0.3 0.1 0.0 New CP 006 GP02 ENG01 GM Vortec 5.7L 0.1 0.1 12.4 0.7 9.8 0.1 0.1 0.1 0.9 0.7 - 1.8 0.1 New GP02 007 GP02 ENG02 GM Vortec 5.7L 0.1 0.1 12.4 0.7 9.8 0.1 0.1 0.1 0.9 0.7 - 1.8 0.1 New GP02 008 GP02 ENG03 GM Vortec 5.7L 0.1 0.1"' 12.4 0.7 9.8 0.1 0.1 0.1 0.9 0.7 1.8 0.1 New GP02 0.0 0.0 XA Combustor Pilots (2 ECD's) ' 0.001 0.001 0.0 0.00 0.0 0.0 0.001 0.001 0.0 0.00 0.0 0.0 XA Horizontal Separator FI TR 0.160 0.160 0.0 2.2 0.12 1.8 0.0 0.160 0.160 0.0 2.2 0.12 1.8 0.0 XA HeaterTreater Separator HTR 0.060 0.060 0.0 0.8 0.04 0.7 0.0 0.060 0.060 - 0.0 0.8 0.0 0.7 0.0 XA FUdtive VOC 0.3 D.0 0.3 0.0 FACILITY TOTAL 0.8 0.8 0.0 0.0 43.5 803.7 0.3 45.8 25.7 0.8 0.8 0.0 0.0 8.8 42.7 0.3 21.8 1.6 VOC: Syn Minor (NANSR and OP) NO. Minor CO: Minor RAPS; Syn Minor n -hexane Ell -l: Syn Minor+ no TES dehy 7777: Syn Minor Permitted Facility Total 0.5 0.5 0.0 0.0 40.5 803.6 0.0 43.3 257 0.5 0.5 0.0 0.0 5.8 425 0.0 19.4 . t.6 Eroktdes units exempt from pemtds/APENs (A) Change in Permitted Emissions 0.5 0.5 0.0 -0,0 5.8 425 0.0 19.4 Pubcom required based on new syn minor limits for NNSR (VOC). Below modeling thresholds. Note 1 Total VOC Fadlity Emissions (point and fugitive) (0) Change in Total Pe witted VOC emissions (point and fugitive) 430 Fadlity is eligible for GP02 because <90 tpy 425 Project emissions less than 25 tpy VOC In nonttainment area Note 2 16 19WE0916.CP1xlsm 11/25/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A088 Facility Name HDI KF 01-65-10 Pad Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 2-24 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0916 Condensate Tanks 2142 1462 119 371 16150 34 10.1 002 19WE0917 Produced Water Tanks 4620 14520 9.6 003 19WE0918 Condensate Loadout 523 27 35 96 4590 10 2.6 004 19WE0919 3 -phase (HT) separator venting 642 574 59 204 4417 12 3.0 005 19WE0920 VRT venting 25 18 2 5 170 0.4 0.1 006 GP02 ENG01 GM Vortec 5.7L 149 20 19 11 22 0.1 007 GP02 ENG02 GM Vortec 5.7L 149 20 19 11 22 0.1 008 GP02 ENG03.GM Vortec 5.7L 149 20 19 11 22 0.1 0.0 XA Combustor Pilots (2 ECD's) 0.0 XA - Horizontal Separator HTR 0.0 XA HeaterTreater Separator HTR 0.0 XA Fugitive VOC 0.0 TOTAL (tpy) 0.2 0.0 0.0 4.0 1.0 0.1 0.3 19.9 0.0 0.0 0.0 0.0 25.7 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH- 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0916 Condensate Tanks 107 73 6 19 808 2 0.5 002 19WE0917 Produced Water Tanks 231 726 0.5 003 19WE0918 Condensate Loadout 26 1 2 5 230 1 0.1 004 19WE0919 3 -phase (HT) separator venting 32 29 3 10 221 1 0.1 005 19WE0920 VRT venting 1 1 0.1 0.3 8.5 0.02 0.0 006 GP02 ENG01 GM Vortec 5.7L 149 20 19 11 22 0.1 007 GP02 ENG02 GM Vortec 5.7L 149 20 19 11 22 0.1 008 GP02 ENG03 GM Vortec 5.7L 149 20 19 11 22 0.1 0.0 XA Combustor Pilots (2 ECD's) 0.0 XA Horizontal Separator HTR 0.0 XA HeaterTreater Separator HTR 0.0 XA Fugitive VOC 0.0 TOTAL (tpy) 0.2 0.0 0.0 0.2 0.1 0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.6 17 19 W E0916.CP1.xlsm 11/25/2019 l�^ MR�SMT 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 CONSTRUCTION PERMIT Permit number: 19WE0917 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Verdad Resources LLC HDI KF 01-65-10 Pad 123/A088 SESE Sec 10 T1 N R65W Weld County Well Production Facility Equipment or activity, subject to this permit: 1 Facility Equipment ID AIRS Point ' Equipment Description Emissions Control Description PW01-04 002 Four (4) 538 barrel fixed roof produced water storage vessels connected via liquid manifold. Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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 operators 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 8 COLORADO Air Pollution Control Division Department of Public Health & Enwonment 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.) I. 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 AIRS Point CO Facility Equipment ID Tons per Year NO), PM2.5 VOC Emission Type PW01-04 002 1.3 4.4 5.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit 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 8 a„, 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 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 PW01-04 002 Enclosed Combustor 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 PW01-04 002. Produced Water Throughput 660,000 barrels The owner or operator must monitor monthly process:, rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of eachmonth 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. 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 upon installation of the combustion device. 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 must install and operate air Page 3 of 8 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 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. 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 these points, the owner or operator must follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.)' COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator 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 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) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 4 of 8 f� 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 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 No. 3, Part D must 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 (Reference: Regulation Number 3, Part D, 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 Regulation Number 3, Part B, Section II.B.` upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ob initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Page 5 of 8 COLORADO Aix Pollution Control Division Department of PubItc Health & Env ronment Dedicated to protecting and improving the health and environment of the people of Colorado Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 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: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad; Resources, LLC Synthetic minor permit at new well production facility Page 6 of 8 COLORADO Air Pollution Control Division Department of PublicHealth & 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) 002 Benzene 71432 4,620 231 n -Hexane 110543 14,520 '' 726 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0037 0.0037 CDPHE CO 0.0167 0.0167 VOC 0.2620 0.0131 71432 Benzene 0.0070 0.0004 110543 n -Hexane 0.0220 0.0011 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 Page 7 of 8 o COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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, HAP NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.Rov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix AAppendix 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'' 3.1200-63.1439 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 8 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0918 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: Verdad Resources LLC HDI KF 01-65-10 Pad 123/A088 SESE Sec 10 T1 N R65W We id County Well Production Facility Equipment or activity subject to this permit: 1 Equipment ID' AIRS Point' Equipment Description Emissions Control De-ctiption TLQ1 003 Truck loadout of condensate by submerged fill. Enclosed combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 etseq), 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 operators responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 9 COLORADO Air Pollution Control Division Department of %biic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must 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 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 TL01 003 --- --- 7.6 - Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tonsper 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 criteria pollutants OR 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. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. 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.) Page 2 of 9 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 Equipment ID AIRS Point Control Device Pollutants Controlled TL01 003 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. 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 TL01 003 Condensate Loaded to tank trucks 1,275,000 barrels The owner or operator must calculate monthly process rates based on the calendar i:month. 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,, 9. 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.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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 must be conducted by submerged fill and emissions must be controlled by a combustion device. (Reference: Regulation 3, Part B, III.D.2) 12. 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. 13. • 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 Page 3 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. b. 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. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. 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. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 14. For this controlled loading operation, the owner or operator 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): Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. 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 Ft MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your OEM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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 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) 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 (NOin;ozone nonattalnrnent;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 eported 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 must 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 (Reference: Regulation Number 3, Part D, 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 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. Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of. 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this lermit 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 resection of the entire permit and upon such : occurrence, this permit must ` be deemed denied ab'i itio. 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 requesta 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: Bradley Eades Permit Engineer Page 6 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Synthetic minor permit at a new well production facility. Page 7 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder 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 ofof 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:// .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 523 26 Toluene 108883 ` 27 1 Ethylbenzene 100414 35 2 Xylenes 1330207 96 5 n -Hexane 110543 4,590 230 2,2,4- Trimethylpentane 540841 10 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. 5) The emission levels contained in this permit are based on the following emission factors: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.2360 1.18E-02 MemAPo PS o 14-02 Benzene 71432 4.10E-04 2.05E-05 EPA TANKS n -Hexane 110543 3.60E-03 1.80E-04 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 The uncontrolled VOC emission factor was calculated using emission factors provided in APCD PS Memo 14-02. The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors, as modeled using EPA TANKs, by the VOC emission factor. Controlled emission factors are based on an enclosed combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP NANSR Synthetic linor 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://www.ecfr.eov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 COLORADO Air Pollution Control Division Department of PublicHealth & Env ronment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0919 Issuance: 1 Verdad Resources, LLC Facility Name: Plant AIRS ID: Physical Location: County: Description: HDI KF 01-65-10 Pad 123/A088 SESE Sec 10 T1 N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point' Equipment Description Emissions Control Description HT-VENT01 004 Venting of gas from one heater treater (3- Phase separator) during vapor recovery unit (VRU) compressor downtime. Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission '' and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants mustnot exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO HT-VENT01 004 --- --- 3.7 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled HT-VENT01 004 Emissions from the Separator are routed to an Enclosed Combustor during Vapor Recovery Unit (VRU) downtime PROCESS LIMITATIONS AND RECORDS! VOC and HAP 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4. ) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit HT-VENT01 004 Condensate throughput during vapor recovery unit (VRU) downtime 51,000 bbl/yr Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator must continuously (i.e. at least once every 15 minutes) monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. VRU downtime is defined as times when either of the two (2) compressors used to recycle vapors from this emission point are not operational. 11. The owner or operator must use monthly VRU downtime records, monthly condensate throughput records, calculation methods detailed in the 0£tM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health, & Environment Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This!taremust be equipped with an operational auto -igniter upon installation of the combustion device. 15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompteted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 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 0ftM 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/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of pounds per Barrel of Condensate Throughput, i.e. lb/bbl) using Division approved methods and a "gas emitted per barrel of condensate throughput" factor of 45.8 scf/barrel. Results of the Analysis must be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are 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 less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 18. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or 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; 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 Page 5 of 10 COLORADO Air Pollution Control Division Department of Publtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 21. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 22. 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. 23. 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. 24. 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. 25. 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. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. 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. 28. 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. Bradley Eades Permit Engineer Permit History Issuance ', Date Description Issuance 1 ,This Issuance Issued to Verdad Resources LLC Synthetic minor permit at a new well production facility. Page 7 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 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) HT-VENT01 004 Benzene 71432 642 32 Toluene 108883 574 29 Ethylbenzene 100414 59 3 Xylenes 1330207 204 10 n -Hexane 110543 4,417 221 2,2,4- Trimethylpentane 540841 12 1 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 ebt., COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 2.8975 0.1449 Pressurized liquid analysis and ProMax 71432 Benzene 0.0126 0.0006 108883 Toluene 0.0113 0.0006 110543 n -Hexane 0.0866 0.0043 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 130 °F and separator pressure of 35 psig. 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, HAP NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.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 Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 COLORADO Air Pollution Control Division Department of 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 19WE0920 Issuance: 1 Verdad Resources, LLC Facility Name: Plant AIRS ID: Physical Location: County: Description: HDI KF 01-65-10 Pad 123/A088 SESE Sec 10 T1 N R65W Weld County Welt Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description VRT-VENT01 005 Venting of gas from one (1) vapor recovery tower (VRT) during vapor recovery unit (VRU) compressor downtime. Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act'(C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION! LIMITATI0NS`AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 N0,t V0C CO VRT-VENT01 005 --- --- 0.3 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health &Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled VRT-VENT01 005 Emissions are routed to an Enclosed Combustor during Vapor Recovery Unit (VRU) downtime PROCESS! LIMITATIONS AND RECORDS VOC and HAP 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 AIRS Point Equipment ID Process Parameter Annual Limit VRT-VENT01 005 Condensate throughput during vapor recovery unit (VRU) downtime 51,000 bbl/yr Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator must continuously (i.e. at least once every 15 minutes) monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. VRU downtime is defined as times when any of the three (3) compressors used to recycle vapors from this emission point are not operational. 11. The owner or operator must use monthly VRU downtime records, monthly condensate throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating property. This flare must be equipped with an operational auto -igniter upon installation of the combustion device. 15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OFtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O8M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of pounds per Barrel of Condensate Throughput, i.e. lb/bbl) using Division approved methods and a "gas emitted per barrel of condensate throughput" factor of 3.4 scf/barrel. Results of the Analysis must be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are Page 4 of 10 COLORADO Air Pollution Control Division Department of Publtc Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 18. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS .'. 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, 11.C.) Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Page 5 of 10 J COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 21. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 22. 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. B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. 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. 24. 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. 25. 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. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Page 6 of 10 COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. 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. 28. 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. Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC Synthetic minor permit at a new well production facility. Page 7 of 10 COLORADO Aix Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or Limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) VRT-VENT01 005 Benzene 71432 25 1 Toluene 108883 18 1 Ethylbenzene 100414 2 <1 Xylenes 1330207 5 <1 n -Hexane 110543 170 8 2,2,4-540841 Trimethylpentane <1 <1 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 CO HE COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 0.1717 0.0086 Pressurized liquid analysis and ProMax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on modeled VRT temperature of 70 °F and separator pressure of 11 psig. 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, HAP NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.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 Page 9 of 10 MACT COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 /am Condensate Storage Tank(s) APEN - Form. APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/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: 19WE0916 AIRS ID Number: 123 / A088 / 001 [Leave blank unless APCD has already -assigned a permit # and AIRS ID] Section_1 -_Administrative Information Company Name': Verdad Resources LLC Site Name: HDI KF 01-65-10 Pad Site Location: SESE Sec 10 T1 N R65W 40.060105/-104.642444 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Phone Number: E -Mail Address2: Brad Ganong 720-845-6918 bganong@verdadresources.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 1 COLORAD6. ix'-ra?imccf a(Pv3w�'. crs:ue.rm Permit Number: 9WE0916 AIRS ID Number: 123 / A088 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit ❑ Request coverage under 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 ❑ Change company name ❑ Change permit limit - ❑ Transfer of ownership3 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft Notes: Permit Addendum - Emission point redline edits 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Condensate Storage Tanks For new or reconstructed sources, the projected start-up date is: 07/01/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: ❑✓ Exploration & Production (E&P) site weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? Yes No 0 • Are Flash Emissions anticipated from these storage tanks? 0 Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? 0 Yes • No tf "yes", identify the stock tank gas -to -oil ratio: 0.0025 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 0 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 21 COLORADO. Permit Number: 19WE0916 AIRS ID Number: 123 / A088 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbilyear) Requested Annual Permit Limit4 Condensate Throughput: 750,000 From what year is the actual annual amount? projected Average API gravity of sales oil: ~42 degrees O Internal floating roof Tank design: ❑✓ Fixed roof 1,275,000 RVP of sales oil: ~7.3 ❑ External floating roof Storage'. Tank ID. TK01-08 # of Liquid Manifold Storage ',Vessels in Storage Tank 8 x 538 bbl Total Volume of Storage Tank, (bbO 4304 Installation Date of Most,;: Recent. Storage Vessel iri Storage, Tank (mopth/year) 06/2019 Date; of First" Production . • 's (month/year) 07/2019 .Wells Serviced by this Storage Tank or Tank Batten PI ;Humber; 05 123 - 46167 Name of Well . . HDI KF 10-1H (05-123-46167) (E&P Sites Ony) Newly Reported Well, 05 - 123 - 46165 HDI KF 10-3H (05-123-46165) 05 123 - 46160 HDI KF 10-4H (05-123-46160) 05 - 123 - 46158 HDI KF 10-5H (05-123-46158) 05 123 -46162 HDI KF 10-7H (05-123-46162) 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 wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longrtude or UTM) 40.060105/-104.642444 Operator Stack. ` !` , ID No. Discharge Height Above „ Ground " Level (feet). .. Temp.' (�F) . .: Flow Rate (ACFM) Velocity (ft/sec) EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) ID Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) El Circular ❑ Square/rectangle El Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 96 Interior stack width (inches): Interior stack depth (inches): Farm APCD-205 Condensate Storage Tank(s) APEN - Revision 07/2017 0O nail.- Permit Number: 19WE0916 AIRS ID Number: 123 / A088 / 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: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: MMBtu/hr Make/Model: 2x GCO Beast 3200 Type: 2x Enclosed Combustors Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: 2,366.2 0.047 Btu/scf MMBtu/hr Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: 0 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)? 11 psig Describe the separation process between the well and the storage tanks: Produced fluids from the wells are directed to eight 3 -phase horizontal heated separators. From the separators, oil is directed to one 3 -phase horizontal heater treater for further separation and pressure reduction. From the heater treater, oil is directed to one VRT. From the VRT, oil is directed to the storage tanks. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 41 COLORADO. n��,.+tars„ti Benzene VOC Permit Number: 19WE0916 AIRS ID Number: 123 / A088 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): escription of Control`Method(s) Enclosed Combustor Overall Requested Control ... Efficiency (%'reduction in emissions) 95 NOx CO HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? 2019/pro acted Criteria Pollutant Emissions Inventory 0.76 Ib/bbl Site Specific Uncontrolled{ Basis Source? (AP -42, Mfg. etc) Actual Annual Emissions equested Annual Perini Emission Limit(s)4 Uncont "rolled'` ; Emissions: (Tonslyear) ., ontrolled Emissions? frons/Yeark Uncontrolled . Emissions (Tons/year) Controlled,," Emissions (Tons/year) VOC 286.13 14.31 486.42 24.32 NOx 0.0023 lb/bbl Calc / AP -42 0.85 0.85 1.43 1.43 CO 0.010 lb/bbl Calc / AP -42 3.81 3.81 H 6.46 6.46 Non Criteria Reportable.._Poliutant Emissions Inventory -;-= 7.., heroical Abstract Service (CAS) Number mission Factor6 `Actual Annual Emissions Uncontrolled" Basis Units Source (AP 42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled ' Emissions? (Pounds)year) 71432 0.0017 lb/bbl Site Specific 1,26.00 63.00 Toluene 108883 0.0011 lb/bbl Site Specific 860.00 43.00 Ethylbenzene 100414 0.000093 lb/bbl Site Specific 70.00 3.50 Xylene 1330207 0.00029 lb/bbl Site Specific 218.00 10.90 n -Hexane 110543 0.013 lb/bbl Site Specific 9,500.00 475.00 2,2,4- Trimethylpentane 540841 0.000027 lb/bbl Site Specific 20.20 1.01 4 Requested values will become permit limitations. Requested timit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 Permit Number: 19WE0916 AIRS ID Number: 123 / A088 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Michael Cugnetti Date Director of EHS&R Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. - Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303)692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd COLORADO. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 Ct1ex,, -ILI-AUlci 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: 19WE0918 AIRS ID Number: 123 /A088 / 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: HDI KF 01-65-10 Pad Site Location: SESE Sec 10 T1 N R65W 40.060105/-104.642444 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 E -Mail Address2: bganong@verdadresources.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 lUse the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via a -mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN -Rev 02/2017 JLORAno 3 f MY4SPm4R! Permit Number: 19WE0918 AIRS ID Number: 123 /A088 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action NEW permit OR newly -reported emission source Request coverage under 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 - ▪ Umit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Permit Addendum - Emission point redline edits 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: 07/ 01. /2019 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 ❑✓ Yes ❑ No ❑ Yes ❑✓ No ❑ _ Yes ❑✓ No ❑r Yes El No ❑ Yes ❑ No Yes ❑ No El Yes ❑✓ No Permit Number: 19WE0918 AIRS ID Number: 123/A088/003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: Condensate O Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth 1,275,000 Bbl/yr Actual Volume Loaded: 750,000 Bbl/yr This product is loaded from tanks at this facility into: trucks (eg, "rail tank cars" or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: ,F True Vapor Pressure Psia @ 60 °F Molecular weight of displaced vapors Lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: Bbl/yr Actual Volume Loaded: Bbl/yr Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Load Line Volume: Lb/ft3 ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 `Hydrocarbon Liquid Loading APEN - Rev 02/2017 3I Permit Number: 19WE0918 AIRS ID Number: 123/A088/003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude' or UTM, 40.060105/-104.642444 a r Disch rge Hei I .1 r e oc EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 96 Section 6 - Control Device Information Loading occurs using a vapor balance system: Requested Control Efficiency. 100 % ❑ Combustion Device: Pollutants Controlled: VOC, HAPS Rating: MMBtu/hr. Type: 2x Enclosed Combustors Make/Model: 2X GCO Beast 3200 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency • 98 . Minimum Temperature: n/a Waste Gas Heat Content 2,366.2 Btu/scf • Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0.047 MMBtu/hr Pollutants Controlled: Description: Control"Efficiency Requested 0 Form APCD.,208`-Hydrocarbon• Liquid Loading APEN._ Rev 02/2017 PM PM Permit Number: 19WE0918 AIRS ID Number: 123/A088/003 [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): Control Equipment Description Overall Requested: Control:; Efficiency;' %reduction in emissions) SOX NO), CO VOC vapor balance /combustor 100/95 HAPs vapor balance / combustor 100 / 95 Other: 0 Using State Emission Factors (Required for GP07) VOC I] Condensate 0.236 Lbs/BBL ❑ Crude 0.104Lbs/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? Projected Use_the.following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled. Emission , . Factor Emission Factor nits Emission Factor; Source- (AP -42, Mfg. etc} Contro lied (Tons/year) Uncontrolled (Tons/year) Rtecf Annual !rm.. ission> Limit(s)s Uncontrolled ;: (Tons/year) Controlled` (Torts/year) SOX NOX 0.00035 lb/bbl Ap-42/Calc 0.13 0.13 0.22 0.22 VOC 0.236 lb/bbl CDPHE 88.50 4.43 150.45 7.52 CO 0.0016 lb/bbl Ap-42/Calc 0.59 0.59 1.00 1.00 Benzene 0.00041 lb/bbl CDPHE 0.15 0.0077 0.26 0.013 Toluene Ethylbenzene Xylenes n -Hexane 0.0036 lb/bbl CDPHE 1.35 0.068 2.30 0.11 2,2,4- Trimethylpentane Other: a Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annuat 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 Permit Number: 19WE0918 AIRS ID Number: 123 /A088/ 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 Authorized Person (not a vendor or consultant) Date Michael Cugnetti Director of EHS&R 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 OLORADO Form APCD-208 -Hydrocarbon Liquid Loading APEN Rev 02/2017 3304-1 -"1/3\ 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. 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 (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 19WE0919 AIRS ID Number: 123 / A088 /004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: HDI KF 01-65-10 Pad Site Location: SESE Sec 10 Ti N R65W Mailing Address: 40.060105/-104.642444 (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Brad Ganong Phone Number: 720-845-6918 E -Mail Address2: bganong@verdadresources.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. CcLORA QO Form APCD-211.- Gas Venting APEN - Revision 3/2019 Permit Number: 19WE0919 AIRS ID Number: 123 /A088/A088/004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership's ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: Permit Addendum - Emission point redline edits 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: compressor downtime Heater Treater venting during VRU Company equipment Identification No. (optional): HT-VENTO1 For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 07/01/2019 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: variable hours/day variable days/week variable weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/2019 ❑✓ Yes Yes Yes ❑ No No Permit Number: 19WE0919 AIRS ID Number: 123 /A088 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ - Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑✓ Other Description: Heater Treater Serial #: # of Pistons: Capacity: gal/min Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameters5: ❑✓ No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year Liquid Throughput Process Parameters5: Vented Gas Properties: -OR- Requested: 51,000 bbl/year Actual: 30,000 bbl/year Molecular Weight: 37.19 VOC (Weight %) 64.59 Benzene (Weight %) 0.281 Toluene (Weight %) 0.251 Ethylbenzene (Weight %) 0.026 Xylene (Weight %) 0.089 n -Hexane (Weight %) 1.930 2,2,4-Trimethylpentane (Weight %) 0.0051 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 Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 Gas Venting APEN - Revision 3/2019. ✓ • Combustion 0 Device: Permit Number: 19WE0919 AIRS ID Number: 123 / A088/004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information eographical Coorddinat Lot itudelL"ongitude or;UT 40.060105/-104.642444 Operato Sfack ID Igog� Dischargee Height Above -ou d Level s emp ¢} �� lov at {ncri) z elocity� lft/sit j EC01-02 32 1000 50 0.017 Indicate the, direction of the stack outlet: (check one) ✓❑ Upward Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular O Other (describe): Interior stack diameter (inches): El Upward with obstructing raincap 96 Section 6 - Control Device. Information Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: Pollutants. Controlled: VOC/HAPs Rating: Type: 2x Enclosed Combustors -; ' - Make/Model: MMBtu/hr hr Requested Control Efficiency: 95 . Manufacturer Guaranteed Control Efficiency: 98 % 2x GCO Beast 3200 Minimum Temperature: N/A Waste Gas Heat Content: 2122 22 Btu/scf s Constant Pilot Light: 0 Yes O No Pilot burner Rating: 0.0,4,7 . MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form: APCD-211 - Gas Venting APEN: Revision 3/2019 4I Benzene 71432 PM Permit Number: 19WE0919 AIRS ID Number: 123 /A088 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6; the following table can be used to state the -- overall (or combined) control efficiency (% reduction): escription of torltr0l. Methods; Overall Requested �� Control Efficiency.: (%reductio"n in` emissions).:: Sox NO), CO VOC Enclosed Combustor 95 HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory,' PM Uncontrolled Bans lb/bbl ourcce AP 42 etc ) Uncontrolled-- (tans/year): :ontrolled' missions6 W 'tons/year) equested Annual Permit Emission Limit(s)5 ncontrolled missions, (tonsfyear) 0.17 SOx NOX 0.0066 Calc / AP -42 0.10 0.10 0.17 CO 0.030 lb/bbl Calc / AP -42 0.45 0.45 0.77 0.77 VOC 2.90 lb/bbl Site Specific 43.46 2.17 73.91 3.70 on -Criteria Reportable Pollutant; Emissions Inventory mission Factor Uncontrolled Units Source (AP -42, Mfg:,, etc-) ,ctual'Annual Emissions Uncontrolled Emissions (pounds/year) Controlled Emissions6 (poundslyear) _' 0.013 lb/bbl Site Specific 377.58 18.88 Toluene 108883 0.011 lb/bbl Site Specific 337.84 16.89 Ethylbenzene Xylene 100414 0.0012 lb/bbl Site Specific 34.77 1.74 1330207 0.0040 lb/bbl Site Specific 119.81 5.99 n -Hexane 110543 0.087 lb/bbl Site Specific 2,598.13 129.91 2,2,4- Trimethylpentane 540841 0.00023 lb/bbl Site Specific 6.87 0.34 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 3/2019 Permit Number: 19WE0919 AIRS ID Number: 123 / A088/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct: Signature of Legally Authorized Person (not a vendor or consultant). Date Michael Cugnetti Director of EHS&R Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www. colorado. gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO n.4*.. A 44 916 ui0 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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. 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 (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A listof 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: 19WE0920 AIRS ID Number: 123 /A088 /005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: HDI KF 01-65-10 Pad Site Location: SESE Sec 10 T1 N R65W 40.060105/-104.642444 Mailing Address: 1125 17th Street, Suite 550 (Include Zip Code) Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Brad Ganong 720-845-6918 bganong@verdadresources.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 3/2019 Permit Number: 19WE0920 123 /A088/005 AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Permit Addendum - Emission point redline edits 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: compressor downtime VRT venting during VRU Company equipment Identification No. (optional): VRT-VENTO1 For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 07/01/2019 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Variable hours/day variable days/week variable weeks/year Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/2019 O Yes ❑ Yes O Yes ❑ No O No ❑ No COLOtAD Permit Number: 19WE0920 AIRS ID Number: 123 / A088 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information O Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: ❑ Blowdown Events Serial #: Capacity: gal/min Model: # of Pistons: Leak Rate: Scf/hr/pist # of Events/year: Volume per event: MMscf/event O Other Description: Vapor Recovery Tower If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameters: ❑✓ No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year Liquid Throughput Process Parameters5: Vented Gas Properties: -OR- Requested: 51,000 bbl/year Actual: 30,000 bbl/year Molecular Weight: 34.25 VOC (Weight %) 56.70 Benzene (Weight %) 0.163 Toluene (Weight %) 0.199 Ethylbenzene (Weight %) 0.010 Xylene (Weight %) 0.033 n -Hexane (Weight %) 1.099 2,2,4-Trimethylpentane (Weight %) 0.0025 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 Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. !'COLORA©a'. Form APCD-211 - Gas Venting APEN Revision 3/2019 0 Upward ❑ Horizontal Permit Number: 19WE0920 AIRS ID Number: 123 /A088 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates; (Latitude/Longitude or UTM) 40.060105/-104.642444 ac %-.,..t,,F. �. fir, Cdr,...>.: .- e-gj,��S Abov Gr ti, eel) .s,....'$.N v Y. - �'�'_ a EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 96 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. ❑ VRU:.; Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: % ❑ . Combustion Device: Pollutants Controlled: VOC/HAPs Rating: , MMBtu/hr Type: 2x Enclosed Combustors Make/Model: Requested Control Efficiency: 95 Manufacturer. Guaranteed Control Efficiency: 98 Minimum Temperature:. N/A 2x GCO Beast 3200 Waste Gas Heat Content: 1,958 Btu/scf Constant Pilot Light: Li Yes ❑ - Nd Pilot burner Rating: 0.047 MMBtu/hr Other: Pollutants Controlled: - Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 3/2019 4 tA:RO, Sf ' "5r,•:: s Permit Number: 19WE0920 AIRS ID Number: 123 / A088 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Benzene Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM Overall Requested Contro(Efficiency (% reduction in emissionsj' SOX NO. CO VOC Enclosed Combustor 95 HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? projected PM Uncontrolledw; Basis Ib/bbl Criteria Pollutant Emissions Inventory source AP 42 g etc) Uncontrolled Emissions (tons/year). ontrolled Emissions (tons/year).: Requested Annual Perini Emission Limit{s)5 0.011 0.011 SOX NO. 0.00045 Calc / AP -42 0.0067 0.0067 CO 0.0020 lb/bbl Calc / AP -42 0.031 0.031 0.052 0.052 VOC 0.17 lb/bbl Site Specific 2.57 0.13 4.37 0.22 on -Criteria Reportable Pollutant Emissions Inventory iemical Abstract Service (CAS),. Number Emission Factor , Uncontrolled Basis Units Source (AP -42 Mfg., etc.) ctualAnnual_Emissions Uncontrolled J" Emissions - (pounds/year)' ontrolled Emissions6 (pounds/year) 71432 0.00049 lb/bbl Site Specific 14.83 0.74 Toluene 108883 0.00036 lb/bbl Site Specific 10.76 0.54 Ethylbenzene Xylene 100414 0.000030 lb/bbl Site Specific 0.90 0.045 1330207 0.00010 lb/bbl Site Specific 3.01 0.15 n -Hexane 110543 0.0033 lb/bbl Site Specific 99.72 4.99 2,2,4- Trimethylpentane 540841 0.0000077 lb/bbl Site Specific 0.23 0.012 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 Gas Venting APEN - Revision 3/2019 5I COLORADO nx4: gr,":xl Permit Number: 19WE0920 AIRS ID Number: 123 / A088 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person (not a vendor or consultant) Date Michael Cugnetti Director of EHS&R 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) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 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 Form APCD-211 - Gas Venting APEN - Revision 3/2019 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150. Or visit the APCD website at: https: //www.colorado.Rov/cdphe/apcd REcEivED SEp-52019 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit d ion Sts Soured All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 19v/6(6917 AIRS ID Number: 123 /A0gg/ dot [Leave blank unless APCD has already assigned a permit f and AIRS ID) Section 1 - Administrative Information Company Name': Site Name: Verdad Resources LLC HDI KF 01-65-10 Pad Site Location: SESE Sec 10 Ti N R65W 40.060105/-104.642444 Mailing Address: (Include Zip Code) 1125 17th Street, Suite 550 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Phone Number: E -Mail Address2: Brad Ganong 720-845-6918 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-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 !16154 COLORADO 1 I H•ai] G^�m.�.on:r.ery Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action D NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ 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 ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Initial permit application. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Produced Water Storage Tanks For new or reconstructed sources, the projected start-up date is: 07/01/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 Exploration Et Production (EEtP) site days/week 52 weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes • No Are Flash Emissions anticipated from these storage tanks? 0 Yes • No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • D Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? 0 Yes ■ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No F4 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 AY COLORADO 2 I arEtlan~meet Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 550,000 Requested Annual Permit Limit4 (bbl/year) 660,000 From what year is the actual annual amount? Tank design: I Fixed roof Projected ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW01-04 4 x 538 bbl 2152 07/2019 08/2019 Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 46167 HDI KF 10-1H (05-123-46167) ❑� 05 - 123 - 46165 HDI KF 10-3H (05-123-46165) 2 05 - 123 - 46160 HDI KF 10-4H (05-123-46160) GI 05 - 123 - 46158 HDI KF 10-5H (05-123-46158) 0 05 - 123 - 46162 HDI KF 10-7H (05-123-46162) l7 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.060105/-104.642444 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) EC01-02 32 1000 50 0.017 Indicate the direction of the stack outlet: (check one) El Upward ❑ Horizontal ❑ Downward El Other (describe): Indicate the stack opening and size: (check one) El Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 96 Interior stack width (inches): Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 �Y COLORADO Permit Number: AIRS ID Number: (Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: Type: 2x Enclosed Combustors MMBtu/hr Make/Model: 2x GCO Beast 3200 Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: n/a Waste Gas Heat Content: Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: 1,496 0.047 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —35 psig Describe the separation process between the well and the storage tanks: Produced fluids from the wells are directed to eight 3 -phase horizontal heated separators. From the separators, oil is directed to one 3 -phase horizontal heater treater for further separation and pressure reduction. From the heater treater, oil is directed to one VRT. Produced water at the horizontal separators and heater treater is directed to the storage tanks. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 4 �eoLoaAoo ' Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN 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 Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/ ear) Y Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 0.262 lb/bbl CDPHE 72.05 3.60 86.46 4.32 NOx 0.0037 lb/bbl Calculated 1.01 1.01 1.21 1.21 CO 0.017 lb/bbl Calculated 4.59 4.59 5.51 5.51 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions (Pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 3,850.00 192.50 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 lb/bbl CDPHE 12,100.00 605.00 2,2,4 Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 5 I AV COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit fi and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of of Legally Autho rson (not a vendor or consultant) Date EH&S Manager Michael Cugnetti Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 6 I F•�,co�o,m �r v«•�r", E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Verdad Resouces LLC Source Name: HDI KF 01-65-10 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 - 46166 HDI KF 10-8H (05-123-46166) ►1 05 - 123 - 46164 HDI KF 10-9H (05-123-46164) .1 05 - 123 - 46159 HDI KF 10-11H (05-123-46159) /5 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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 B05a_Tank APEN-Addendum Hello