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Home My WebLink About20192298.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 June 11, 2019 Dear Sir or Madam: RECEIVED WELD COUNTY COMMISSIONERS On June 13, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Verdad Resources, LLC - Jackson 02N -64W-33 Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W: Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Public OCo l D4 / 19 cc: PLCiP), g1-ICSr), PwcEAR ►CM,7micK) OCoft'7/I9 2019-2298 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Verdad Resources, LLC - Jackson 02N -64W-33 Production Facility - Weld County Notice Period Begins: June 13, 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: Jackson 02N -64W-33 Production Facility Exploration Et Production Well Pad NWNW Sec 33 T2N R64W Weld County The proposed project or activity is as follows: Initial application for a new EEtP well site. The operator is requesting permit coverage for six (6) condensate storage vessels, hydrocarbon liquid loading, and separator venting at a new synthetic minor oil Et gas well production well facility located in the ozone non -attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1305 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.wv/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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 �V COLORADO 1 � � ry��.<�, a �� KbMlf�%.-Evrt:n�m. n, Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package #: 390669 Received Date: 11/30/2018 Review Start Date: 1/14/2019 Section 01 - Facility Information Company Name: Verdad Resources LLC County AIRS ID: 123 Quadrant Section Township Range NWNW 33 2N 64 Plant AIRS ID: Facility Name: Physical Address/Location: County: A017 Jackson 02N -64W-33 Production Facility NWNW quadrant of Section 33, Township 2N, Range 64W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? O carbon Monoxide (CO) ❑ Particulate Matter (PM) Q Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Condensate Tank Yes 18WE1305 • Yes Permit Initial Issuance C Produced Water Tank PW01-02 Y s 18WE1306.XP 1 No APEN Required / Permit Exempt _ Liquid Loading e_ 18WE1307 1 Yes Permit Initial Issuance Separator Venting HT-VENTO1 Ye 18WE1308 1 Yes Permit Initial Issuance Section 03 - Description of Project PA Pages for 002, 003, 004 hidden in this workbook as 001 is only point on permit 18WE1305. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greater than 25 tons per year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. No Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? No Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ CI O ❑ ❑ ❑ ❑ o O ❑ ❑ O O No If yes, explain what programs and which pollutants here SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) O ❑ O ❑ O O Title V Operating Permits (OP) O O O O O O O O Non -Attainment New Source Review (NANSR) ❑ O Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 County A017 Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Six (6)400 bbl condensate tanks Description: Emission Control Device ECD Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 200,750 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 200,750 Barrels (bbl) per year Requested Permit Limit Throughput = 240,900 Barrels (bbl) per year Requested Monthly Throughput = 20460 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = Secondary Emissions- Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = 240,900 Barrels (bbl) per year 2542 Btu/scf 70.09 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes 35,767 MMBTU per year 42,921 MMBTU per year 42,921 MMBTU per year Emission Factors Condensate Tank Emission Factor Source Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 6.96 0.35 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 0.007 0.000 Toluene 0.005 0.000 Ethylbenzene 0.000 Xylene 0.001 0.000 n -Hexane 0.072 0.004 224 TMP 0.000 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0000 AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0000 NOx 0.0680 0.0121 CO 0.3100 0.0552 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/morth) VOC PM10 PM2.5 N O x 837.8 698.1 34.9 837.8 41.9 7115 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 1.5 1.22 1.22 1.46 1.46 248 CO 6.7 5.54 5.54 6.65 6.65 1130 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 1793 1494 75 1793 90 Toluene 1214 1012 51 1214 61 Ethylbenzene 0 0 0 0 0 Xylene 346 288 14 346 17 n -Hexane 17448 14540 727 17448 872 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage Tank is not subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2 of 7 K:\PA\2018\18WE1305.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines n PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? NO 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 Operator used E&P Tanks to develop SSEFs based on pressurized oil sample. Ran E&P tanks in-house to verify. See application package for sample analysis/ conditions used. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # SCC Code 01 4-04-003-11 Fixed Roof Tank. Condensate, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 Ib/1,000 gallons condensate throughput NOx 0.29 0 lb/1,000 gallons condensate throughput VOC 165.6 95 lb/1,000 gallons condensate throughput CO 1.32 0 Ib/1,000 gallons condensate throughput Benzene 0.18 95 lb/1,000 gallons condensate throughput Toluene 0.12 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.03 95 lb/1,000 gallons condensate throughput n -Hexane 1.72 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 7 K:\PA\2018\18WE1305.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and 8 - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 WY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05.01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Sectior II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 WY (Regulation 3, Part B, Section I..D.2)? Source requires a permit Yes No Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Yes Yes Yes Yes Storage tank Is subject to Regulation 7, Section XII.C-F Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Section XII.D — Emissions Control Requirements Section XII.E — Monitoring Section XII.F — Recordkeeping and Reporting Colorado Refutation 7. Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Yes No Storage Tank is not subject to Regulation 7, Section XII.G Section XII.G2 - Emissions Control Requirements Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Colorado Regulation 7. Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? 'Storage tank Is subject to Regulation 7, Section XVII, B, C.1 & CS No Yes Yes Yes Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVlI.C.1 - Emissions Control and Monitoring Provisions Section XVR.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Yes Storage Tank is not subject to Regulation 7, Section XVII.C.2 Section XVR.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60. Subpart Kb. Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (-472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 ms (^10,000 BBL) used for petroleum' or condensate stored, processed, or treated prior to custody transfe? as defined in 60.11lb? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of 'storage vessers in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.11lb? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ("29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 ms ('950 BBL] and stores a liquid with a maximum true vapor pressure° less than 33 kPa (60.11ob(b))?; or c The design capacity is greater than or equal to 75 Ms 1472 661] but less than 151 ms ("950 B8L) and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? No Source Req Go to next Source Req Continue -' Continue -' Source is st Continue -' Storage Tar Continue - Go to the n Go to the n Source is st Storage Tar Storage Tar Storage Tank s not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR. Part 60. Subpart 0000. Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 603430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? 'Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §603425 Table 3 §603395 - Emissions Control Standards for VOC §605413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements 460.5417 - Control Device Monitoring Requirements (Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 60.5365(ej(2) even if potential VOC emissions drop below 6 tons per year) 40 CFR. Part 63. Subpart MAC' HH. Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user° (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of'storage vessel"' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? 'Storage Tank is not subject to MACT HH Yes No Yes No Subpart A, General provisions per 463.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 • Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank Is In the non -attainment area. ff the tank meets both criteria, then review RACY 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. I his document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation. or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act,, its implementing regulations. and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as recommend.' 'may.' 'should.' and 'can,' is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and 'required are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Continue - Storage Tar Continue -' Storage Tar COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Verdad Resources, LLC County AIRS ID 123 Plant AIRS ID A017 Facility Name Jackson 02N -64W-33 Productii History File Edit Date 2/5/2019 Ozone Status Non -Attainment n Facility EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) T POIN AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. 1.5 837.8 6.7 10.4 1.5 41.9 6.7 0.5 New Point 002 18WE1306.X P Produced (2) @ 400 Water Tanks bbl each - Two 0.3 20.1 1.3 2.2 0.3 1.0 1.3 0.1 New Point. Categorically exempt under Reg 3, Part B, Sec. II.D.1.M 003 18WE1307 Liquid Loadout 0.0 28.4 0.2 0.5 0.0 1.4 0.2 0.0 New Point 004 18WE1308 Heater Treater Venting 0.1 21.3 0.2 0.7 0.1 1.1 0.2 0.0 New Point 005 GP02 GM Vortec 5.7L, 92hp. 4SRB, S/N: 10CHMM201040084 0.1 0.1 0.0 12.4 0.6 9.8 0.1 0.1 0.1 0.0 0.9 0.6 1.8 0.1 New Point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 Separator Heaters 0.080 0.080 0.0 1.1 0.1 0.9 0.0 0.080 0.080 0.0 1.1 0.1 0.9 0.0 Heater Treater Heaters 0.080 0.080 0.0 1.1 0.1 0.9 0.0 0.080 0.080 0.0, 1.1 0.1 0.9 0.0 Fugitive Emissions 0.1 0.0 0.1 0.0 FACILITY TOTAL 0.2 0.2 0.0 0.0 16.4 908.4 0.1 19.9 14.0 0.2 0.2 0.0 0.0 4.9 46.2 0.1 11.9 0.8 VOC: NOx: CO: HAPS: HH: 7777: Syn Minor Minor (NANSR Minor (OP) Minor Minor + Minor affected B, T, (NANSR and and OP) X, HCHO Area OP) & Total 0.1 0 1 0.0 0.0 14.0 888.2 0.0 16.9 11.7 0.1 0.1 0.0 0.0 2.5 45.0 0.0 8.9 0.7 Excludes units exempt from Permitted Facility Total (A) Change in Permitted Emissions 0.1 0.1 0.0 0.0 2.5 45.0 0.0 8.9 Pubcom & modeling on (A change (not) required in emissions) based Note 1 Total VOC Facility Emissions (point and fugitive 46.3 Facility is eligible for GP02 because < 90 A) Change in Total Permitted VOC emissions (point and fugitive 45.0 Project emissions less than 25/50 tpy Note 2 Page 5 of 7 Printed 5/30/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources, LLC 123 A017 Jackson 02N -64W-33 Production Facility Emissions - uncontrolled (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL OW IPreviousFAC1L1TYTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. 1793 1214 346 17448 10.4 002 18WE1306.XP Produced Water Tanks - Two (2) @ 400 bbl each 1073 3373 2.2 003 18WE1307 Liquid Loadout 99 867 0.5 004 18WE1308 Heater Treater Venting 160 149 15 5J 1093 11 0.7 005 GP02 GM Vortec 5.7L. 92hp. 4SRB. S/N: 10CHMM2010400 149 20 19 12 4 1 1 22 0.1 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Separator Heaters 0.0 Heater Treater Heaters 0.0 Fugitive Emissions 1 1 1 2 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 1.6 0.7 0.0 0.2 11.4 0.0 0.0 0.0 14.0 0.0 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 6 18WE1305.CP1 5/30/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources, LLC 123 A017 Jackson 02N -64W-33 Production Facility Emissions with controls (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane 224 TMP TOTAL (tPY) McOH H2S IPreviousFAC1L1TYTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. 90 61 17 872 0.5 002 18WE1306.XP Produced Water Tanks - Two (2) @ 400 bbl each 54 0.1 169 003 18WE1307 Liquid Loadout zi 44 0.0 004 18WE1308 Heater Treater Venting 2 _-. 1 2 55 0.0 1 005 GP02 GM Vortec 5.7L. 92hp, 4SRB, S/N: 10CHMM2010400 1:16,i 2 0 i :- 12 1 0.1 22 0.0 0.0 0.0 . 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Separator Heaters 0.0 Heater Treater Heaters 0.0 Fugitive Emissions ._ 1 2 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.6 0.8 0.0 0.0 0.0 0.0 7 18WE1305.CP1 5/30/2019 of Division blic He lth b Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1305 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Verdad Resources, LLC Jackson 02N -64W-33 Prouction Facility 123/A017 NWNW SEC 33 T2N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK01-06 001 Six (6) 400 barrel fixed roof storage vessels used to store condensate Enclosed Combustion Device 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, submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 COLORADO Air Pollution Control Division Page 1 of 9 days may result in revocation of the permit. A self certification form and guidance on show to self.certify compliance as required by this permit may be obtained online at i, www.colOra .goy/cd ie/4ir-permit-self-certification. (Regulation Number 3, Part B, Section ;III.G.2 ) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TK01-06 001 --- 1.5 41.9 6.7 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 shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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. COLORADO Air Pollution Control Division Page 2 of 9 7. The emission -points `in the table below shall be operated and maintained with the emission icontrol equipment as listedFin order to reduce emissions to less than or equal ito the limits stablished in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK01-06 001 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK01-06 001 Condensate throughput 240,900 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) CDPHE COLORADO Air Pollution Control Division Page 3 of 9 12. The corn ustfon device covered bythis permit is subject to Regulation Number 7, Section XV B 2 Get ral Provisions (State only enforceable). If a flare or other licombdstion device is used tql control missions of volatile organic compounds to comply Section „ all be enc used; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.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. COLORADO Air Pollution Control Division Page 4 of 9 ADDITIONAL REQUIREMENTS 18. I,' A revised Air` PollutantzEmission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such COLORADO Air Pollution Control Division Page 5 of 9 final uthorization.`Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for; Final Authorization section of this permit. 21. This permit is issued ins 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. 22. 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. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources, LLC. CDPHE + COLORADO Air Pollution Control Division Page 6 of 9 Notes • Permit der at theitime;of this emit issuance: 1) TI permit ho lder is required topay feesor the processing time for this permit. An invoice fora these' fe v l be issu d after the ermit is issued. The permit holder shall pay the invoice within 30' -days of eeeipt of the "nvoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 1,793 90 Toluene 108883 1,214 61 Ethylbenzene 100414 0 0 Xylenes 1330207 346 17 n -Hexane 110543 17,448 872 2,2,4- Trimethylpentan e 540841 0 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.012 0.010 AP -42 CO 0.055 0.046 AP -42 COLORADO Air Pollution Control Division Page 7 of 9 "CAS Polluta Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source ,,VOC :.e m 96 0.348 EEtP Tanks 71432 Benzene 0.0074 3.70E-4 EEtP Tanks 108883 Toluene 0.0051 2.55E-4 EEtP Tanks 1330207 Xylene 0.0014 7.00E-5 EEtP Tanks 110543 n -Hexane 0.072 0.0036 EEtP Tanks Note: The controlled emissions factors for this point are based on the ECD 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 shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https: //www.federalreRister.Qov/documents/2016/06/03/2016-11971 /oil-and- natural-qas-sector-emission-standards-for-new-reconstructed-and-modified-sources 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I COLORADO Air Pollution Control Division Page 8 of 9 part 63: Natignal Emission Standards for Hazardous Air Pollutants for Source ategories TACT - 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 CDPHE COLORADO Air Pollution Control Division Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package #: 390669 Received Date: 11/30/2018 Review Start Date: 1/14/2019 Section 01 - Facility Information Company Name: Verdad Resources LLC County AIRS ID: 123 Quadrant Section Township Range NWNW 33 2N 64 Plant AIRS ID: Facility Name: Physical Address/Location: County: A017 Jackson 02N -64W-33 Production Facility NWNW quadrant of Section 33, Township 2N, Range 64W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) 2 Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit 14 Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank T K01-06 Yes 18WE1305 Yes Permit Initial Issuance CO2Produced Water Tank PW01-02 Yes 18WE1306.XP APEN Required / Permit Exempt Liquid Loading TL01 = _ 18WE1307 1 Permit Initial Issuance . Separator Venting HT-VENTO1 _ _. 18WE1308 Ye Permit Initial Issuance Section 03 - Description of Project PA Pages for 001, 002, 004 hidden in this workbook as 003 is only point on permit 18WE1307. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greater than 25 tons per year in Non -Attainment Area 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? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) O O ❑ O O ❑ Title V Operating Permits (OP) ❑ ❑ ❑ 0 ❑ ❑ 0 ❑ Non -Attainment New Source Review (NANSR) ❑ 0 Is this stationary source a major source? No If yes, explain what programs and which pollutants here SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ O O O O ❑ Title V Operating Permits (OP) O O O ❑ O ❑ ❑ ❑ Non -Attainment New Source Review (NANSR) ❑ ❑ Hydrocarbon Loadout Emissions Inventory 003 Liquid Loading Facility AIRs ID: 123 County A017 003 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Hydrocarbon truck loadout of condensate. Description: Emission Control Device Vapor Balance System + LCD Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Yes 100.0 95 Requested Overall VOC & HAP Control Efficiency %: 95.00 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded = 200,750 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 200,750 Barrels (bbl) per year Requested Permit Limit Throughput = 240,900 Barrels (bbl) per year Requested Monthly Throughput = 20460 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 240,900 Barrels (bbl) per year 2542.49 Btu/scf 331493 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? 37.84169231 702 MMBTU per year 843 MMBTU per ye 843 MMBTU per year 0.096212124 The state default emissions factors may be used to estimate emissions. tch- ding toss Equ++ >z 1.2.4LieS;i'Yi°Y1J J �..a..—.�.. «•.,+.�..«; - ,.....-p...........,-, ._ - .. Factor .:. Meaning -w... Valve Utttts .. 4 ---,r..-.. .. Sorutc, - - P , rroe'oai3.:iF Pressure r ,S:., M ..u._-.. . a I;v:p;etuiiu 1,•.'e₹i;.at of trai:;7c >, • ;:. • -,,; 4 1 €.tc,u14 I e, Pyl%Pf atci!, T',Arttl ;fie" 1i.:e3U'fize ii,0C SOS' 1.b1.100;‘‘ caliwi,,`' A C orri ent l Mass-i tacuca Emission _ Fnct�r Units Source Y< si -..w. ...4 , 7uittere i:: l,i;i .-_e_,. ..t. -r..- ,-.n ...».. ,_.,_- . lily ileiStene' z '3 ' f,l , Xylene ; ;bibb t . .. n-1exarte tit::;i;i w 4MP I i;1ir}+i . .... _'. Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 2.36E-01 1.18E-02 Condensate Loadout State E.F. Benzene 4.10E-04 2.05E-05 Condensate Loadout State E.F. Toluene 0.00E+00 0.00E+00 Ethylbenzene 0.00E+00 0.00E+00 Xylene 0.00E+00 0.00E+00 Condensate Loadout State E.F. n -Hexane 3.60E-03 1.80E-04 224 TMP 0.00E+00 0.00E+00 Control Device Emission Factor Sour Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 10 0.00E+00 AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 133 Industrial Flares (CO) PM2.5 0.00E+00 SOx 0.00E+00 NOx 0.0680 0.00024 CO 0.3100 1.08E-03 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM 10 PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.03 0.02 0.02 0.03 0.03 5 28.43 23.69 1.18 28.43 1.42 241 0.13 0.11 0.11 0.13 0.13 22 2 of 7 K:\PA\2018\18WE1307.CP1 Hydrocarbon Loadout Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (Ibs/year) Benzene 99 82.3 4.1 98.8 4.9 Toluene 0 0.0 0.0 0.0 0.0 Ethylbenzene 0 0.0 0.0 0.0 0.0 Xylene 0 0.0 0.0 0.0 0.0 n -Hexane 867 722.7 36.1 867.2 43.4 224 TMP 0 0.0 0.0 0.0 0.0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.0.2.a The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RAG. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes NOx and CO emissions vary slightly from APEN, but well below reprotable thresholds. Furthermore, operator calculated numbers are slightly more conservative than ours, will therefore accept and use for permitting. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # 01 SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.6 95 lb/1,000 gallons transferred CO 0.03 0 Ib/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.00 95 Ib/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 Ib/1,000 gallons transferred n -Hexane 0.09 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 3 of 7 K:\PA\2018\18WE1307.CP1 Hydrocarbon loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Yes No No No Yes Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? Yes The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RAC?. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," 'may" "should," and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Go to next question. Go to the next question Go to next question Go to next question Go to next question The loadout requires a permit The loadout must operate with submerged fill and loadout emissions must be routed to control to satisfy RACT. If not controlled, a RAC? analysis is required and provide discussion in Section 8. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Verdad Resources, LLC County AIRS ID 123 Plant AIRS ID A017 Facility Name Jackson 02N -64W-33 Productic History File Edit Date 2/5/2019 Ozone Status Non -Attainment n Facility EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons oer year T POIN AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 U0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 o.o 0.0 0.0 001 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. 1.5 837.8 6.7 10.4 1.5 41.9 6.7 0.5 New Point 002 18WE1306.X P Produced (2) @ 400 Water bbl each Tanks - Two 0.3 20.1 1.3 2.2 0.3 1.0 1.3 0.1 New Point. Categorically Reg 3, Part B, Sec. II. D.1. exempt under M 003 18WE1307 Liquid Loadout 0.0 28.4 0.2 0.5 0.0 1.4 0.2 0.0 New Point 004 18WE1308 Heater Treater Venting 0.1 21.3 0.2 0.7 0.1 1.1 0.2 0.0 New Point 005 GP02 GM Vortec SIN: 10CHMM201040084 5.7L. 92hp, 4SRB, 0.1 0.1 0.0 12.4 0.6 9.8 0.1 0.1 0.1 0.0 0.9 0.6 1.8 0.1 New Point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 Separator Heaters 0.080 0.080 0.0 1.1 0.1 0.9 0.0 0.080 0.080 0.0 1.1 0.1 0.9 0.0 Heater Treater Heaters 0.080 0.080 0.0 1.1 0.1 0.9 0.0 0.080 0.080 0.0 1.1 0.1 0.9 0.0 Fugitive Emissions 0.1 0.0 0.1 0.0 FACILITY TOTAL 0.2 0.2 0.0 0.0 16.4 908.4 0.1 19.9 14.0 0.2 0.2 0.0 0.0 4.9 46.2 0.1 11.9 0.8 VOC: Syn Minor NOx: Minor CO: Minor HAPS: Minor HH: Minor + 7777: Minor (NANSR (NANSR (OP) B, T, affected and OP) and OP) X, HCHO & Total Area Permitted Facility Total 0.1 0.1 0.0 0.0 14.0 888.2 0.0 16.9 11.7 0.1 0.1 0.0 0.0 2.5 45.0 0.0 8.9 0.7 Excludes units exempt from (A) Change in Permitted Emissions 0.1 0.1 0.0 0.0 2.5 45.0 0.0 8.9 Pubcom on & modeling (not) required based (A change in emissions) Total VOC Facility Emissions (point and fugitive 46.3 Facility is eligible for GP02 because < 90 A) Change in Total Permitted VOC emissions (point and fugitive 45.0 Project emissions less than 25/50 tpy Note 1 Note 2 Page 5 of 7 Printed 5/30/2019 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 A017 Facility Name Jackson 02N -64W-33 Production Facility Emissions - uncontrolled (lbs per year) POIN 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 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. 1793 1214 346 17448 10.4 002 18WE1306.XP Produced Water Tanks - Two (2) @ 400 bbl each 1073 3373 2.2 003 18WE1307 Liquid Loadout 99 867 0.5 004 18WE1308 Heater Treater Venting 160 149 15 53 1093 11 0.7 005 GP02 GM Vortec 5.7L, 92hp, 4SRB, S/N: 10CHMM2010400 149 20 19 12 4 1 1 22 0.1 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Separator Heaters 0.0 Heater Treater Heaters 0.0 Fugitive Emissions 1 1 1 1 % 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 1.6 0.7 0.0 0.2 11.4 0.0 0.0 0.0 0.0 14.0 I I *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane TOTAL 0PY) McOH 224 TMP H2S IPreviousFACILITYTOTAL 0 0 0 0 0 0 0 0 0 0.0 0 0 0 001 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. _ 90 61 17 872 0.5 002 18WE1306.XP Produced Water Tanks - Two (2) @ 400 bbl each 54 169 0.1 003 18WE1307 Liquid Loadout 5 44 f i 0.0 004 18WE1308 Heater Treater Venting 8 7 1 3 55 0.0 1 005 GP02 GM Vortec 5.7L, 92hp, 4SRB, S/N: 10CHMM2010400 149 20 19 12 4 1 1 0.1 22 0.0 0.0 0.0 0.0 6 18WE1307.CP1 5/30/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources, LLC 123 A017 Jackson 02N -64W-33 Production Facility 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Separator Heaters 0.0 Heater Treater Heaters 0.0 Fugitive Emissions A 1 1 1 2 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.6 0.0 0.0 0.0 0.0 0.8 I - - - - - 7 18WE1307.CP1 1307.CP 1 5/30/2019 Pollutic n C ntrol s, vi ;ion ep- ment f Public , •alth 8k vironment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1307 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Verdad Resources, LLC Jackson 02N -64W-33 Production Facility 123/A017 NWNW SEC 33 T2N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TL001 003 Truck loadout of condensate by submerged fill using vapor balance system Vapor Balance System, Enclosed Combustion Device 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, bar submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - COLORADO Air Pollution Control Division Page 1 of 9 certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form andguidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO TL001 003 --- --- 1.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division Page 2 of 9 Facility Equipment ID AIRS Point � Control Device Pollutants Controlled TL001 003 Vapor Balance System, Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TL001 003 Condensate Loaded 240,900 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by an enclosed combustion device. (Reference: Regulation 3, Part B, III.D.2) 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): COPHE COLORADO Air Pollution Control Division Page 3 of 9 a. The owner or oper- for shall inspect onsite loading ecuipment t i ensure that hoses, couplings, a d valves are maiptai i�ed to prevent drippings leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 13. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING a MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M 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 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. COLORADO Air Pollution Control Division Page 4 of 9 Periodic Testing Requirements 16. This source is not requiredtto conduct periodic teeing, unless,ctherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II. B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing COLORADO Air Pollution Control Division Page 5 of 9 in accordance with the provisions, of 25 7.114.5(12)(a) C.R and AQCC Regulation Number 3, Part B, Section IILG Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. 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. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources, LLC COLORADO Air Pollution Control Division Page 6 of 9 Notes to Permit Holder at the time of this per it issuanc 1) The permit holder is required i7,rpay feesr,fbr the processing tune for this peri An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) HT-VENT01 004 Benzene 71432 99 5 Toluene 108883 0 0 Ethylbenzene 100414 0 0 Xylenes 1330207 0 0 n -Hexane 110543 867 43 2,2,4- Trimethylpentane 540841 0 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.4E-4 3.4E-4 CDPHE CO 0.0016 0.0016 VOC 0.236 0.0118 CDPHE COLORADO Air Pollution Control Division Page 7 of 9 Pollutant CAS # Uncontrolled`t Emission Factors lb/bbl :ontrot ed " �t Emission z .. Factors lb/bbl _ Source - Benzene 71432 4.1E-4 2.1E-5 CDPHE n -Hexane 110543 0.0036 1.8E-4 Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 8 of 9 COLORADO Air Pollution Control Division Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package #: 390669 Received Date: 11/30/2018 Review Start Date: 1/14/2019 Section 01 - Facility Information Company Name: Verdad Resources LIC County AIRS ID: 123 Quadrant Section Township Range NWNW 33 2N 64 Plant AIRS ID: Facility Name: Physical Address/Location: County: A017 Jackson 02N -64W-33 Production Facility NWNW quadrant of Section 33, Township 2N, Range 64W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Q Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank TK01-06 ti'. 18WE1305 - Permit Initial Issuance 002 Produced Water Tank PW01-02 _: 18WE1306.XP I ., APEN Required / Permit Exempt 003 Liquid Loading TL01 Ye: 18WE1307 � _. Permit Initial Issuance 004 Separator Venting HT-VENT01 r _ 18WE130o r Permit Initial Issuance Section 03 - Description of Project PA Pages for 001, 002, 003 hidden in this workbook as 004 is only point on permit 18WE1308. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greater than 25 tons per year in Non -Attainment Area 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? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.S PM10 TSP HAPs Prevention of Significant Deterioration (PSD) O O O O O ❑ Title V Operating Permits (OP) O O O El O O ❑ O Non -Attainment New Source Review (NANSR) ❑ O Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ O O ❑ ❑ ❑ ❑ O ❑ ❑ ❑ O O Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123 County A017 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Heater treater venting to flare during VRU compressor downtime. Emission Control Device Description: ECD Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Liquid Throughput Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 4,015.0 Barrels (bbl) per year 95 Requested Permit Limit Throughput = 6,023.0 Barrels (bbl) per year Requested Monthly Throughput = 511.542 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 6,023.00 Barrels (bbl) per year Yes Yes Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description 2273 Btu/scf 97.06 scf/bbl Natural gas venting for times of VRU downtime (VRU guaranteed to 98% uptime, 2% downtime). While up, vapors from this separator are sent into a sales gas line. MW 39.7085 Weight % Helium CO2 1.92 N2 0.14 methane 9.14 ethane 19.42 propane 27.90 isobutane 5.42 n -butane 16.55 isopentane 4.55 n -pentane 5.30 cyclopentane 0.41 n -Hexane 1.785 cyclohexane 0.54 Other hexanes 3.28 heptanes 1.51 methylcyclohexane 0.63 224-TMP 0.018 Benzene 0.261 Toluene 0.244 Ethylbenzene 0.025 Xylenes 0.086 C8+ Heavies 0.88E Total 100.0' VOC Wt % 69.39 Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Emission Factors Separator Venting Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Liquid Throughput) (Liquid Throughput) VOC 7.06 0.3528 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Benzene 0.027 0.0013 Toluene 0.025 0.0012 Ethylbenzene 0.0025 0.0001 Xylene 0.0087 0.0004 n -Hexane 0.1815 0.0091 224 IMP 0.0013 0.0001 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) P M 10 0.000 AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.000 SOx 0.000 NOx 0.0680 0.0150 CO 0.3100 0.068 2 of 8 K:\PA\2018\18WE1308.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 0.00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 0.05 0.03 0.03 0.045 0.05 8 VOC 21.25 14.17 0.71 21.25 1.06 180 CO 0.21 0.14 0.14 0.206 0.21 35 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year (lbs/year) 0.0798 0.0747 0.0076 0.0263 0.5465 Benzene 160 106 5 160 8 Toluene Ethylbenzene Xylene n -Hexane 224 TM P 149 100 5 149 7 15 10 1 15 1 53 35 2 53 3 1093 729 36 1093 55 11 7 0 11 1 0.0055 Section 06 - Regulatory Summary Analysis 0.0040 0.0037 0.00038 0.0013 0.0273 0.00027 Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements You have indicated above the monitored process parameter is Liquid Througput. The following question does not require an answer. Qs -`. .' use .,. .> > r t t :',, i+.. gas, c. , ' i - ♦` l - C`.. the t.t?'3'} a lr 1t F_ � :t L.• Ul�r(: t ?�t 1-.F�r? ttif t,� _ L�.:. .i , k a tt�• ycir..t'., f, L.�. ,I•.�.,i;' Q_'r!11 iJC?>i ��. �:: • �, j,;$ S;3F?: ? Li• 'ii.(: refit tt-Ieu 3; '1iiJc't A .' e S:?t'�t�a?+;' f 'xiE>"t „,:.';i' ♦�;t. A and 1: r e r 'r� t c ,3ira, s i,r ,_ti r i €!- .� t�� • F: . S S�.v • 1. ,i,3 L. t' .1 l .t .tt :�. }., iii 1"!t �,-tt 4( i aril# el( .tg ,,/- .. .Y > ;3 L ₹.' , 11/4,\t t > lt;e ;,'"`4,1i; Ei,7,i,. nrc4 tt3.4,iii,u, } a•, 5ci;f+YJ if the ,rI .:t will c rt: < 'initial- 'e tines ; tie t"tt} ..�, icr? ,s t.e ^ueci it -sample ,ir. f ..? 1 th'.. it inn c::nt i;-:: '.;e2f:ritird m'id citu'r kat an eI: iy:- nn.factor ;3 i:ii:'s : 1i 4, i3t ?>: t � f 3x�i1':.itl Testing, 5. � fi -{. � ..Flt (I . v . ? �{ .: �. ,, i� } r v i t. }l.12J i �F' _ , . ? f to Y Ptr tt._ tl.� 1 e s ' .tct1 are less r n u: t . i�. i •. t t e, t _ C�iI?1t11i.a � ._ .. -L �il,. f?Fi S t7il f" i�.1t5 t' i :Sa �:>✓t"3 or" equal L t ic: emissions factors i5.Ai.ii;, .,L: Yvftil ti*„ ijtY er 1.> ,e: ` t ; u. t 0r_ > than z.. to 'Y' ten' r. .♦ ? •j\F `L. f?:C-. �. ,.•?t?2iiY{� t"t1 t � a{ it, of V0C art 3i.i'f cl ic�� :ti,{•. #.�i.{[il ,.) .. ., i�-. i E. 'j2c•<t' i vest Lire permit wi i cuntum ' •:� 1 t i n g i ? } t, , le a rlrf..r '>.'.iiii: '.is . frith: t:: -n t . 'f b- '.rr, ;,1! } .r s- -. AP.. t ♦ the �l init �#Test ?7,:, equ r>r3t 2J t _3 ..h :2 3 ._ _i't� � c:sF y.: c:t itil? Pi '':' 'F; t;� r;F:Li f;}i =�: P, -t4 �.t�1 t•:t�tir'< 3`F r≤iS a ...,�i:r;c. Vii:;. .?t: ,.e ,r issi t t ... s are If. -:5 than % u :the 'n L ' , a' tor; - n:' i';-4 t'..: 'i thy, ? �1:�; it:n F, r3..S1Jil ,cl 'v; ...: a 3 t, r -ia• G to L.1,: L'•. t S,!}i:� i£ . t .�. .. .• t - < l'i a " Peci4dic Testing Requirement!' t}t,t>.r.. a. Sitt'-'i l7 £.'i:ii'..r j.:•�i:> .n+": _ ,. :!`? Zii{= -•a 131�:iitc;it� h! .ri3 ;-tjt'?{"t _:mot %}rf fc3rii)i >a f'Ji'y si_ ,is S'It.. �,if t .•ic?.i f ir3'•.'f_ 3 r;"?F'tt I ?'?�il`P;lt+ttrt :i .,.}� v.t ,;;it•,r,,,?'t3t sx b _] per -t:i ?i. co!on.� '.>. that tv� i fc - .a. • 1, £ , .> , Y ; ..#t �.^ it 1 I th .f.i; . t t$ t! a L ,r , z f'tl t r a .> k £ -, J `% .. ii. (. 5..SIi1• C �:i{3 tl�t 3Lt3, �•a t<.:.... , {..tl £, t �, :L; ,�1� ,t trC; t.�<•;..t.:..• ["teed„ ;a `n '1;31 ct• ' htS ronrttli)fl ^ltIi i se the Tt; • um 4.. 0, astet- as emitted '.r_1 E.aI.ot IC Fit�5s ti �4i `>I:put" SS/hhi) y•�}.I 4'; �ect•r.. it#Ir. 7•[ }eu rj 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 under this AIRs ID) and process simulation to estimate 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 device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling v`:.� ''_ice t•� .—PC�,_i Tt'pa`•'PIN�.i i0 } �.- 3 of 8 K:\PA\2018\18WE1308.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Operator notes that, per VRU manufacturer, VRU is guaranteed at 98% uptime (2% downtime). Actual and requested permit limits correspond to anticipated VRU downtime (Le, total actual oil production = 200,750 bbl/yr; Actual VRU downtime production = 4015 bbl/yr). Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point $1 004 Process #1 SCC Code 01 3-10-001-29 Oil & Gas Production: Gas/liquid separation Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1000bbl PM2.5 0.00 0 Ib/ 1000bbl SOx 0.00 0 Ib/1000bbl NOx 15.00 0 lb/1000bb1 VOC 7056.28 95 Ib/1000bb1 CO 68.39 0 Ib/1000bbl Benzene 26.51 95 Ib/1000bbl Toluene 24.82 95 Ib/1000bbl Ethylbenzene 2.53 95 lb/1000bbl Xylene 8.73 95 lb/1000bbl n -Hexane 181.48 95 Ib/1000bbl 224 TMP 1.82 95 Ib/1000bbl 4 of 8 K:\PA\2018\18WE1308.CP1 Separator Venting Regulatory Analysis Worksheet Colorado - APEN and erns' uir Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1a)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 B. Section II D.3)7 Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 WY (Regulation 3, Part A, Section 1I.O.1.a), 1 Are total facility uncontrolled VOC emissions from the greater than 2 TPY. NOx greater than S TPY or CO emissions greater than 10 WY (Regulation 3, Part B, Section lID.2)1 Source requires a permit Colorado Regulation 7. Section XVII 1. Was ore we:l newly constructed, hydraulically fractured, or recompleted on or after August 1. 2O147 Source is subject to Regulation 7, Section XVII 82, Yes Source Requires an ADEN- Go to the next question Yes Source Requires a permit Section XVU.8.2 -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 backup or alternate combustion device (i.e.. not the primary control device) that is not enclosed? The control device for this separator a not subject to Regulatton 7, Section XVIl.B.2.e Section XVII.B.2.e - Alternative emissions control equipment Yes Source is subject, go to next question 'The control device for this separator is not subject to Regulation 7, Section XV Disclaimer This document assists operators with detemnning applicability of certain requirements of the Clean Air Act its lnplerrxinbng regulations, and Air Quality Control Commission regulations- This document is not a rule or regulation, and the analysis R contains may not apply to a particular situation based upon the individual (acts and circumstances This document does not change or substitute tor 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 c rid the language of the Clean Air Act„ its implementing regulations, arid Air Quality Control Commission regulations, the language of the statute or regulation will contol. The use of non -mandator) language such as "recommend," tray' '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 Qualify 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 CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Verdad Resources, LLC County AIRS ID 123 Plant AIRS ID A017 Facility Name Jackson 02N -64W-33 Productik History File Edit Date 2/5/2019 Ozone Status Non -Attainment n Facility EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons aer year POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. 1.5 837.8 6.7 10.4 1.5 41.9 6.7 0.5 New Point 002 18WE1306.X P Produced Water Tanks - Two (2) @ 400 bbl each 0.3 20.1 1.3 2.2 0.3 1.0 1.3 0.1 New Point. Categorically exempt under Reg 3, Part B, Sec. II.D.1.M 003 18WE1307 Liquid Loadout 0.0 28.4 0.2 0.5 0.0 1.4 0.2 0.0 New Point 004 18WE1308 Heater Treater Venting 0.1 21.3 0.2 0.7 0.1 1.1 0.2 0.0 New Point 005 GP02 GM Vortec 5.7L, 92hp, 4SRB, S/N: 10CHMM201040084 MM201040084 0.1 0.1 0.0 12.4 0.6 9.8 0.1 0.1 0.1 0.0 0.9 0.6 1.8 0.1 New Point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 Separator Heaters 0.080 0.080 0.0 1.1 0.1 0.9 0.0 0.080 0.080 0.0 1.1 0.1 0.9 0.0 Heater Treater Heaters 0.080 0.080 0.0 1.1 0.1 0.9 0.0 0.080 0.080 0.0 1.1 0.1 0.9 0.0 Fugitive Emissions 0.1 0.0 0.1 0.0 FACILITY TOTAL 0.2 0.2 0.0 0.0 16.4 908.4 0.1 19.9 14.0 0.2 0.2 0.0 0.0 4.9 46.2 0.1 11.9 0.8 VOC: Syn Minor NOx: Minor (NANSR CO: Minor (OP) HAPS: Minor HH: Minor + Z777: Minor (NANSR and OP) and OP) B, T, X, HCHO & Total affected Area Permitted Facility Total 0.1 0.1 0.0 0.0 14.0 888.2 0.0 16.9 11.7 0.1 0.1 0.0 0.0 2.5 45.0 0.0 8.9 0.7 Excludes units exempt from (A) Change in Permitted Emissions 0.1 0.1 0.0 0.0 2.5 45.0 0.0 8.9 Pubcom & modeling (not) required based on (A change in emissions) Total VOC Facility Emissions (point and A) Change in Total Permitted VOC emissions (point and fugitive\ 46.3 Facility Project is eligible for GP02 because < 90 emissions less than 25/50 tpy fugitive 45.0 Note 1 Note 2 Page 6 of 8 Printed 5/30/2019 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 A017 Facility Name Jackson 02N -64W-33 Production Facility Emissions - uncontrolled (lbs per year) POIN 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 18WE1305 Condensate Tanks - Six (6) @ 400 bbl each. 1793 1214 346 17448 10.4 002 18WE1306.XP Produced Water Tanks - Two (2) @ 400 bbl each 1073 3373 2.2 003 18WE1307 Liquid Loadout 99 867 0.5 004 18WE1308 Heater Treater Venting 160 149 15 53 1093 11 0.7 005 GP02 GM Vortec 5.7L, 92hp, 4SRB, S/N: 10CHMM2010400 149 20 19 12 4 1 1 22 0.1 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Separator Heaters 0.0 Heater Treater Heaters 0.0 Fugitive Emissions 1 i 1 1 7 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 1.6 0.7 0.0 0.2 11.4 0.0 0.0 0.0 0.0 14.0 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 7 18WE1308.CP1 5/30/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources, LLC 123 A017 Jackson 02N -64W-33 Production Facility Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH TOTAL (tpY) 224 1 -MP H2S Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0.0 0 0 0 0 001 18WE1305 Condensate Tanks - Six (6) © 400 bbl each. 90 61 17 872 0.5 002 18WE1306.XP Produced Water Tanks - Two (2) @ 400 bbl each 54 169 0.1 003 18WE1307 Liquid Loadout 5 44 0.0 004 18WE1308 Heater Treater Venting 8 f 1 3 55 0.0 1 005 GP02 GM Vortec 5.7L, 92hp, 4SRB, S/N: 10CHMM2010400 149 20 4 9 12 4 1 1 0.1 22 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Separator Heaters 0.0 Heater Treater Heaters _ 0.0 Fugitive Emissions 1 1 1 1 2 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.6 0.0 0.8 0.0 0.0 0.0 8 18WE1308.CP1 5/30/2019 ADO n Control,. Healtl- . Environr CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE 1308 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Verdad Resources, LLC Jackson 02N -64W-33 Production Facility 123/A017 NWNW SEC 33 T2N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description HT-VENT01 004 Heater Treater venting during VRU compressor downtime Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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, bar submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - COLORADO Air Pollution Control Division Page 1 of 8 rtify comp lance t the conditions "FailCI ays may rett in r_ onevocation of the permit: w to sel ertifyc— mpliance as rewired by do. /ai if-cer. Section III.G.2.) to demoitstrrte' complian ee,Ewithin 180 elf certification form andr uidance on is per4ii may be obtained online at •. Regulation Number 3 Part B, 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO HT-VENT01 004 --- --- 1.1 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The 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 COLORADO Air Pollution Control Division Page 2 of 8 submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. T( e emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled HT-VENT01 004 Emissions from the Separator are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit HT-VENT01 004 Liquids Throughput 6,023 bbl/yr Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator shall continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. 11. The owner or operator must use monthly VRU downtime records, monthly condensate/crude oil 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 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 shall be enclosed; have no visible emissions during normal COLORADO Air Pollution Control Division Page 3 of 8 operations, as ,defined. under Regulation. Number 7, XVII A;_16' and be des i ed so that an observer can, by means'iof visual observation from the outside of the enclosed flare or combustion device, or, by other 'convenient means approved by the Division, determine whether it is operating' properly.;_ This flare must be equipped, with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 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 a MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 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 17. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 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) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or COLORADO Air Pollution Control Division Page 4 of 8 For volatile organic compounds (VOC) and nitrogen oxides sources (M1 OX) in ozone nonaftainment areas emitting less than 100 tons -of VOC or NO,tper year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or ,. For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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 representations made by the owner or operator or owner or COLORADO Air Pollution Control Division Page 5 of 8 erator s agents. It is valid only for the `=equipment and' operationor activity pacifically 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 shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources, LLC COLORADO Air Pollution Control Division Page 6 of 8 Notes to'ermit 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 jthese fees -"Will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay' the invoice wiltresult in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) HT-VENT01 004 Benzene 71432 160 8 Toluene 108883 149 7 Ethylbenzene 100414 15 1 Xylenes 1330207 53 3 n -Hexane 110543 1,093 55 2,2,4- Trimethylpentane 540841 11 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: Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 7.06 0.353 E&P Tanks COLORADO Air Pollution Control Division Page 7 of 8 1U543 0.009 EP',Tanks exane. _r. 0.182 Note: The controlled emissions factors for this point are based ton the flare control efficiency of 95%. The emission factors listed above are based on a modeled separator temperature of 120 °F and separator pressure of 25 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 shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 8 of 8 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.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: � � [ (3kJ5 AIRS ID Number: ) Z3 /A0/7 / 0O1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Jackson 02N -64W-33 Production Facility Site Location: NWNW Sec 33 T2N R64W 40.101456/-104.561579 Mailing Address: (Include Zip Code) 1401 17th Street, Suite 925 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 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. COLORADO Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017 1 390663 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under 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 - APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Initial Permit Application - Site Specific Emission Factors 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Storage Tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 09/06/18 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: CI Exploration & Production (EEtP) site weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? IO Yes • No Are Flash Emissions anticipated from these storage tanks? • Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ■ Yes • No If "yes", identify the stock tank gas -to -oil ratio: O4 "2- 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 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No O ■ ZIWty COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 l ;7e \Iv' .5 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl/year) Condensate Throughput: 200,750 240,900 From what year is the actual annual amount? 2018/projected Average API gravity of sates oil: 42.3 degrees Tank design: Z Fixed roof ❑ Internal floating roof RVP of sales oil: 9.4 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK01-06 6 2400 08/2018 09/2018 Wells Serviced by this Storage Tank or Tank Battery5 (EftP Sites On y) API Number Name of Well Newly Reported Well 05 - 123 - 46494 Jackson 33-6H ❑� 05 - 123 - 46497 Jackson 33-7H❑ Ill 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/Longitude or UTM) 40.101456/-104.561579 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECO1 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular ❑ Square/ rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 54 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 COLORADO 3 1 .,'» ` "... Permit Number: AIRS ID Number: [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. 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: MMBtu/hr Type: Enclosed Combustor Make/Model: GCO ECD2000 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: -2542 0.0382 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 (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —20 psig Describe the separation process between the well and the storage tanks: produced fluids from the wells are directed to two 3 -phase horizontal heated separators. From the separators, oil is directed to two 3 -phase vertical heater treaters for further separation and pressure reduction. co�oacoo Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 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: 2018/pro ected From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor° Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) ) Uncontrolled Emissions (Tons/year) Controlled Emissions7 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 6.96 lb/bbl Site Specific 698.25 34.91 837.90 41.90 NOx 0.012 lb/bbl Calculated 1.23 1.23 1.48 1.48 CO 0.055 lb/bbl Calculated 5.56 5.56 6.67 6.67 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) g Uncontrolled Emissions Pounds/ ear (Pounds/year) ) Controlled Emissions7 (Pounds/year) Benzene 71432 0.0074 lb/bbl Site Specific 1,494.00 74.70 Toluene 108883 0.0051 lb/bbl Site Specific 1,014.00 50.70 Ethylbenzene 100414 Xylene 1330207 0.0014 lb/bbl Site Specific 288.00 14.40 n -Hexane 110543 0.072 lb/bbl Site Specific 14,540.00 727.00 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017 5 .itCOLORADO .r. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit 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. ///2,1/le— Date Signature of Leg y Authorized Person (not a vendor or consultant) Michael Cugnetti EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd COLORA60 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 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: ( g`tAJ E j 7 AIRS ID Number: (Z3 /A-0/7 / o D_3 [Leave blank unless APCD has already assigned a permit /# and AIRS ID] Company equipment Identification: TL001 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Jackson 02N -64W-33 Production Facility Site Location: NWNW Sec 33 T2N R64W 40.101456/-104.561579 Mailing Address: (Include Zip Code) 1401 17th Street, Suite 925 Denver, Colorado 80202 E -Mail Address2: bganong@verdadoil.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 390665 COLORADO 1 I M.v.._.., Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $25O must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ 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 - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Initial Application 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Hydrocarbon Truck Loadout For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 09/ 06 /2018 / / Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source toad 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 Li No No No Yes Yes Yes Yes Yes COLORADO 2 No No No Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: E Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 200,750 Bbl/yr Actual Volume Loaded: 240,900 Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: trucks (eg, "rail tank cars" or "tank trucks") 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-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Bbl/yr Actual Volume Loaded: Bbl/yr Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 3 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.101456/-104.561579 Operator Stack ID NO. Discharge Height Above Ground Level Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) (Feet) EC01 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) E Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 54 Section 6 - Control Device Information ❑✓ Loading occurs using a vapor balance system: Requested Control Efficiency 95 ❑ Combustion Device: Pollutants Controlled: VOC, HAPS Rating: Type: Enclosed Combustor Make/Model: GCO ECD2000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: n/a MMBtu/hr 95 98 Waste Gas Heat Content —2542 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0.0382 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 /AV COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC vapor balance 95 HAPs vapor balance 95 Other: ❑ Using State Emission Factors (Required for GP07) VOC 0 Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2018 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) - Actual Annual Emissions Requested Annual Permit 5 Emission Limit(s)5 Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO„ 0.0Q,34 lb/bbl Calculated 0.035 0.035 0.042 0.042 VOC 0.236 lb/bbl CDPHE 23.69 1.18 28.43 1.42 CO 0.0016 lb/bbl Calculated 0.16 0.16 0.19 0.19 Benzene 0.00041 lb/bbl CDPHE 0.041 0.0021 0.049 0.0025 Toluene Ethylbenzene Xylenes n -Hexane 0.0036 lb/bbl CDPHE 0.36 0.018 0.43 0.022 2,2,4- Trimethylpentane Other: a Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 5 I �.-,,,]F- Permit Number: AIRS ID Number: / / Michael Cugnetti [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. Date /d5 Pen (not a vendor or consultant) EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORA00 6i. 7(-722, (7 Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.coloracio.gov/cdphe/aocd. 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: 18WE1308 Company equipment Identification: HT-VENT01 AIRS ID Number: 123 /A017/ 004 red , tt;n Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Jackson 02N -64W-33 Production Facility Site Location: NWNW Sec 33 T2N R64W 40.101456/-104.561579 Mailing Address: (Include Zip Code) 1401 17th Street, Suite 925 Denver, Colorado 80202 E -Mail Address2: bganong@verdadoil.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. CC LOCAOC Permit Number: 18WE1308 AIRS ID Number: 123 /A017/ 004 i :a.. pr.,r4rlit aorf AIRS ID] Section 2- Requested Action 11] NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR ❑ APEN submittal for update only (Please 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 a Notes: Initial Application - Update to emissions calcs using ProMax 5.0 process simulation software. ' For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: compressor downtime. Heater Treater venting during VRU For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 09 / 06 / 2018 / / ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: variable hours/day variable days/week variable weeks/year Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions Q Yes ❑ No ❑ Yes Q No COLORADO re nl r'.. =_S 1 ..t�-. t.lraI as Ventirin APEN Rev 0312017 Permit Number: 18WE1308 fLea'1e f I ui<, u::'r AIRS ID Number: 123 /A017/ 004 C:C al.ra, ;is n d a i( , and AIR'S:v, Section 4 - Process Equipment Information El Gas/Liquid Separator ❑ Weil Head Casing ❑ Pneumatic Pump Make: Model: Serial #: Capacity: Gal/min ❑ Compressor Rod Packing Make: Model: # of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events # of Events/year: Volume per event: MMscf/event E Other Description: During VRU compressor downtime, gas from the heater treaters is directed to the enclosed combustor. If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Natural Gas Venting Process Parameters': Liquid Throughput Process Parameters": No Maximum Vent Rate: SCF/hr Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 6 023 Bbl/yr Actual: 4 015 BbLyr I 7 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: "i t . S VOC (mole %) 49.81 V0C (Weight %) 69.39 Benzene (mole %) 0.1325 Benzene (Weight %) 0.261 Toluene (mole %) 0.1052 Toluene (Weight %) 0.244 Ethylbenzene (mole %) 0.0093 Ethylbenzene (Weight %) 0.025 Xylene (mole %) 0.0321 Xylene (Weight %) 0.086 n -Hexane (mole%) 0.8223 n -Hexane (Weight%) 1.785 2,2,4-Trimethytpentane (mole %) 0.0062 2,2,4-Trimethylpentane (Weight %) 0.0179 Additional Required Information: Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX it n -Hexane, temperature, and pressure) !'.ir :l sans 3 Permit Number: 18WE1308 AIRS ID Number: 123 /A017/ 004 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.101456/-104.561579 Operator Stack ID No. Discharge Height ' Above Ground Level (Feet) Temp. ('F1 Flow Rate (ACFM) Velocity - (ft/sec) EC01 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) El Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 54 Section 6 - Control Device Information • VRU: Pollutants Controlled: Size: Requested Control Efficiency VRU Downtime or Bypassed Make /Model: Combustion Device: Pollutants Controlled: VOC/HAPs Rating: Type: Enclosed Combustor Make/Model: GCO ECD2000 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: N/A MMBtu/hr 95 98 Waste Gas Heat Content Constant Pilot Light: Yes ❑ No Pilot burner Rating 2273.05 0.0382 Btu/scf MMBtu / hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Permit Number: 18WE1308 AIRS ID Number: 123 /A017/ 004 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? ❑a Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM sox NOx VOC Enclosed Combustor 95 CO HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? N/A Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mf$. etc) Actual Annual Emissions .. - � : -. �- Requested Annual Permit Emission Limit0)s 5 - - Uncontrolled (Tons/year) Controlled' (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM Sax NO 0.015 lbs/bbl AP-i2?C k=uaied 0.045 0.045 VOC 7.06 lbs/bbl Site specific, 21.25 1.06 CO 0.068 lbs/bbl P-42/Caicu.a,xd 0.21 0.21 Benzene 0.027 lbs/bbl Site specific_ 0.080 0.0040 Toluene 0.025 lbs/bbl Site specific 0.075 0.0037 Ethylbenzene 0.0025 lbs/bbl Site specific 0.0076 0.00038 Xylenes 0.0087 lbs/bbl Site specific 0.026 0.0013 n -Hexane 0.18 lbs/bbl Site specific 0.55 0.027 2,2,4- Trimethylpentane 0.0018 lbs/bbl Site specific 0.0055 0.00027 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 5 I A Permit Number: 18WE1308 an un AIRS ID Number: 123 /A017/ 004 .,. APcD lia5 .. adv zs i4 rle. a ,_ . mt „ 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. si6;fig Signature of Legally nori ed Person (not a vendor or consultant) Michael Cugnetti Date EH&S Manager Name (please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance ✓E Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4309 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 COl'JnA40 Form APCD-211 -Natural Gas Vent1r EN 63 / 2017 6 Hello