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Home My WebLink About20194288.tiff RECEIVED COLORADO SEP 3 0 2019 Department of Public WELD COUNTY Health Es Environment COMMISSIONERS Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 September 24, 2019 Dear Sir or Madam: On September 26, 2019, the Air Pollution Control Division will begin a 30-day public notice period for Aka Energy Group, LLC - Speer Gas Plant. 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 Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director E* Pu b L .C rev;et) cc:PLCrP),HL(LK) Pi..,(SM/ER/cH/ck) *`k te * I O/o 7/19 o (sn) r ..1676 2olq- ` O9/3O/11 aM�M�M Air Pollution Control Division ,c _ Notice of a Proposed Project or Activity Warranting Public DPHE Comment Website Title: Aka Energy Group, LLC - Speer Gas Plant - Weld County Notice Period Begins: September 26, 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: Aka Energy Group, LLC Facility: Speer Gas Plant Natural gas processing plant SW Section 31 T4N R65W Weld County The proposed project or activity is as follows: Aka Energy Group, LLC proposes to install new equipment at a natural gas processing plant in the ozone nonattainment area of Weld County (centered on UTM coordinates (NAD80, zone 13) of 524296W, 4457253N). The new equipment will provide 60 MMscfd processing capacity. Permitted equipment are compressor engines, generator engines, heaters, liquid loadout, amine sweetening, and flares. 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 Permits 19WE0148, 19WE0149, 19WE0150, 19WE0151, 19WE0152, 19WE0154, 19WE0157, 19WE0160, 19WE0161, 19WE0162, 19WE0163, 19WE0164, 19WE0165, and 19WE0166 have been filed with the Weld County Clerk's office. A copy of the draft permits and the Division's analyses are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us (COLORADO Department of Fublte I I Health 6 Entironmext • Send comments to our mailing address: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 'COLORADO Depamnent of Public 2 Health 6 Envimnmexi Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 SW _ 4N t , Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) Q Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks Liquid Loading SP300 tC 19WE0165 7ermatnital ;scuance • / 002 NG Heater HTR-703 No 15WE1029.XP No PEN Required Permit Exempt 004 Natural Gas RICE C-601 Yes 19WE0148 Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes _ 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes _ 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes _ 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater +570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE — Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attair ment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.S If yes, attach a copy of Technical Services Unit modeling resilts 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 PMR10 TSP HAPs Prevention of Significant Deterioration (PSD) J J Title V Operating Permits (OP) . J I Non-Attainment New Source Review (NANSR) Is this stationary source a major source? Nc If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSR •P HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ■ [ k Non-Attainment New Source Review (NANSR) Summary of Preliminary Analysis - NG RICE. Company Name Aka Energy Group, LLC Permit No. 19WE0148 Facility Name Speer Gas Plant AIRS 123/9DF7/004 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-601 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired, naturally aspirated,4SLB reciprocating internal combustion engine, site rated at 1380 horsepower.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used for inlet gas compression. Natural Gas Consumption Hours of Operation Requested (mmscf/yr) 91.77 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 7.79 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/set) 981 BSCF(Btu/hp-hr) 7447 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM 10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 6.66 6.66 6.66 0.0% VOC 12.13 3.03 12.13 75.0% CO 35.85 2.51 35.85 93.0% SOx 0.03 0.03 0.03 0.0% TSP 0.45 0.45 0.45 0.0% PM 10 0.45 0.45 0.45 0.0% PM2.5 0.45 0.45 0.45 0.0% Total HAPs* 0.0 0.0 7.0 82.8% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 11460 1146 11460 90 . 0% Acetaldehyde 753 376 753 50 . 0% Toluene 734 367 734 50 . 0% Acrolein 463 231 463 50 . 0% Methanol 225 50 . 0% Benzene * * 117 50 . 0% n- Hexane * * 100 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E . E Standards (g/hp- hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) source requirements? Is this engine subject to NSPS JJJJ ? NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted i ito Reg 6 . Comments/Notes Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the hig 'ier HAP emission factor between AP-42 and GRI HAPCaIc literature/tests . COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name _Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 , 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 p 'evious taken from May 2018 tab Previous Permitted Factlit total 0.0 0. 0 0 0 0. 0 0. 6 94. 1 0. 0 1. 1 0. 7 0. 0 0.0 0. 0 0. 0 0. 6 12. 9 0.0 1. 1 0. 2 001 19WE0165 Truck loaduut of condensate 8.9 0.2 8.90 0.2 :-;P300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" - 0(.0 ; cancelled Fia 1 Tice/led under new facility configuration 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " -_ 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 00/ 19WE0151 Caterpillar G3516J, Sit TBD 0.5 0.5 0.0 6.7 12. 1 35.Q 7 n 0 5 0 5 0.0 6.7 3.03 2.51 1 .2 "C-604" "C-410" Requested combined limit of 8760 hr/yr 008 19WE0152 Caterpillar G3512B, sn TBD 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/7 between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 012 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 "C-653" 013 19WE0157 Caterpillar G3516C , sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013,014,and 015. 014 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-772 015 19WE0157 Caterpillar G3516C, sn: TBD "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr _ 017 19WE0161 Hot oil heater. 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening. 60 MMscfci 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " ,021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7. 4 7.4 0. 0 1. 8 80. 6 755. 9 99. 2 447. 5 219. 0 7. 4 7 42 0. 0 1. 8 80. 6 73. 8 9.8 86.5 23.6 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 7. 4 7. 4 0.0 1. 8 80. 0 60.9 9.8 85. 4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive)_ _ 70. 7 _ i Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/11 /2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lips per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene ' TOTAL (tpy) I Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 I 0 .2 002 15WE1029 .XP Hot oil heater. 6 .96 MMBtu/hr 51 45 46 129 81 108 173 0 . 5 00,3 ul;C-eil 004 19WE0148 Caterpillar (3351 5J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 211 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 73 164 1 18 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 40 5 . 9 011 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C . sn : TBD 21259 1054 648 164 1027 34 140 315 32 34 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 32 34 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10.4 MMBtu/hv 77 67 68 93 120 161 88 259 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 30362 14458 145 1446 2892 216872 0.29 1446 133. 8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3 .4 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 .0 0 . 0 TOTAL (tpy) 56.8 4. 3 2.5 17.4 12.9 0. 7 1 .5 10. 6 110.3 0.9 0. 7 0. 6 0. 2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0148 (version 1 ) 9/11 /2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane MeOH 224 TMP H2S Styrene , 3-bra TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr r 1 45 46 129 81 108 59 173 127 21 0 . 5 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 . 2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 I 367 2 12 50 113 11 12 1 .2 008 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 1 9 37 82 8 0 . 9 009 19WE0152 Caterpillar G3512B , sn : TBD 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 19 r_--: H 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 19 7 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD t 015 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 514 3 17 7 158 1 . 9 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 192 120 161 88 259 189 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 1 299 163 i 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 1518 723 72 145 10844 0 .01 72 6 . 7 020 19WE0164 Plant Flare 108 108 22 540 32 1 0 .2 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 743 i ' 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 5.9 2. 2 1 . 3 1 .4 2. 7 0.6 0. 5 1 . 6 6.3 0. 8 0. 0 0 . 6 0. 2 24 . 03 , 6 19WE0148 (version 1 ) 9/11 /2019 Colorado Department of Public Health and Environment Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum PM2.5 Addendum.pdf Reviewed by: Bradley Rink Summary Speer Gas Plant operated by Aka Energy Group will be modified to include a 60 MMSCRF processing train to dehydrate and treat natural gas. The equipment to be installed is a combination of compressor engines, compressor drivers,oil and gas heaters and flares with a combined output of 81.7 TPY of NOX and 7.65 TPY of PM2.5. The facility,AIRS ID 123-9DF7, is located within the DMNFR ozone nonattainment area in Weld County,centered on the UTM Coordinates(NAD83,zone 13)of 524296W,4457253N. As the emission rates for NOX and PM2.5 are in excess of modeling thresholds modeling was submitted to demonstrate compliance with the appropriate NAAQS/CAAQS. The NAAQS and CAAQS currently in effect are CO(1-hr and 8-hr),Pb(3-month rolling average),NO2(1-hr and annual),PM10(24-hr),PM2.5 (24-hr and annual),SO2(1-hr and 3-hr),and ozone(8-hr).For this facility, quantitative impact analyses are warranted to demonstrate compliance with the following pollutants and averaging periods NAAQS/CAAQS:NO2(1-hr and Annual),and PM2.5(24-hr and annual).The applicant submitted modeling analyses for all these pollutants and averaging periods. The ambient impact analyses performed by the applicant and revised by the MEIU show that the permitted facility does not cause or contribute to a modeled violation of the following NAAQS: 1-hr NO2,Annual NO2,24hr PM2.5,annual PM2.5,.Such compliance demonstration is valid under the following configuration(recommended permit conditions): 1)Modeled impacts were estimated assuming the following stack heights(these values are recommended permit conditions by MEIU): Source Type Source ID Stack Height(m) Cat G3516J C601 10.67 Cat G3516J C602 10.67 Cat G3516J C603 10.67 Cat G3516J C604 10.67 Cat G3512B C410 9.14 Cat G3512B C411 9.14 Cat G3608 C651 10.1 Cat G3609 C652 10.1 Cat G3610 C653 10.1 Cat G3516C G771 6.4 Date Printed: 9/23/2019 Page 1 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum P1112.5 Addendum.pdf Reviewed by: Bradley Rink Cat G3516C G772 6.4 Cat G3516C G773 6.4 Amine hot oil heater H290 7.01 Regen gas heater H310 4.84 Cryogenic hot oil heater H570 5.5 Stabilizer hot oil heater HTR703 5.54 Amine flare FL992 13.18 Plant flare FL991 38.76 2)Hours of Operation-Modeled impacts were estimated assuming that the only restrictions to hours of operation are based on the following source groups: Source Group Allowable Combined Hours of Max#of Engines In Operation Per Year Operation at any time C410,C411 8760 1 of 2 C651,C652,C653 17520 2 of 3 G771,G772,G773 17520 2 of 3 MEIU performed initial sensitivity analysis to determine the combination of sources by group that result in the highest impacts,all subsequent models were run with that most irnpactful combination. Therefore,there are no restrictions as to which combination of engines are in operation only that at most one of C410-C411 for a combined total of 8760 hours per year,at most two of C651 -C653 for a combined total of 17520 hours per year, and at most two of G771 -G773 are in operation at any time for a total of 17520 hours.per year. 3)The permit should contain a condition that,for the duration of permit effectiveness,the source operator shall maintain continuous fencing along the boundary depicted in Figure 3.2 of the Speer Gas Plant Air Quality Impact Analysis document submitted with the application.Public access into these areas shall be precluded. 4)Layout of Sources-Modeled impacts were estimated assuming the layout of the sources within the facility correspond to the one indicated in Figure 2.2 Speer Air Quality Impact Analysis reviewed for this report.The permit should contain a condition that for the duration of permit effectiveness,the facility should be operated with the layout depicted in the aforementioned Figure 2.2. Date Printed: 9/23/2019 Page 2 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum PA12.5 Addendum.pdf Reviewed by: Bradley Rink For the PM2.5 24-hr and annual averaging periods Significant Impact Analysis,the maximum PM2.5 modeled concentrations are shown in the following table: Pollutant Averaging Period Year* Max Modeled Conc. SIL PM2.5 24 hr .2009 4.39 µg/m3 1.2 ug/m3 PM2.5 Annual 2009 1.14 µg/m3 0.3 ug/m3 *One year(2009)of meteorological data from the Ft. St.Vrain met site was used in all these demonstrations The 24-hr value is the highest of the receptor-specific value of the first high 24-hr modeled concentration;the annual value is the highest of the receptor-specific value of the annual modeled concentrations. Given that both SIL(s)were exceeded,cumulative impact analyses were conducted and the results are shown in the table below. This cumulative analysis included impacts from nearby sources and a background concentration provided by the Division. The guidelines to include a particular source were made by screening facilities for proximity to the significant receptor grid combined with significant impacts and facilities farther away that represent large emission sources. Pollutant Averaging Year Max Modeled Background Total Impact NAAQS Period Conc.(ug/m3) Conc.(ug/m3) (ug/m3) (ug/m3) PM2.5 24-hr 2009 7.62 22 29.6 35 PM2.5 Annual 2009 1.56 7 8.56 12 The 24-hr value is the highest of the first high 24-hr modeled concentration at any receptor;the annual value is the highest first high of the annual modeled concentration at any receptor. As the maximum impact for both particulate averaging periods is not in excess of the NAAQS the impacts from the Speer facility do not cause or contribute to an exceedance of the NAAQS. For the NO2 1-hr and NO2 Annual Significant Impact Analysis,the maximum concentration modeled as the highest first high 24-hr average of the one year modeled,is shown in the following table: Pollutant Averaging Year* Max Modeled SIL Period Conc.(ug/m3) (µg/m3) NO2 1-hr 2009 129.35 7.5 NO2 Annual 2009 1.56 1.0 Since the SIL(s)for both averaging periods were exceeded,a cumulative impact analysis was conducted and the results are shown in the table below: The cumulative analysis analysis included impacts from nearby sources and Date Printed: 9/23/2019 Page 3 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum PM2.5 Addendunzpdf Reviewed by: Bradley Rink a background concentration provided by the Division. The guidelines to include a particular nearby source contribution were made by screening facilities for proximity to the significant receptor grid combined with significant impacts and facilities farther away that represent large emission sources. Pollutant Averaging Speer Facility Nearby Sources Cumulative* NAAQS Period Impact(ug/m3) Impact(ug/m3) Impact(ug/m3) (ug/m3) NO2 1-hr 0.000327 188.0035 188.0038 188.16 NO2 Annual 0.029 16.61 16.64 100 *A seasonal NO2 background(by hour)was provided by MEIU and incorporated into the model formulation The Annual NO2 cumulative impact demonstration resulted in no values in excess of the NAAQS,the value in the table is the highest impact that is less than the 1-hr NO2 NAAQS. The 1-hr NO2 cumulative impact demonstration resulted in 749 values in excess of the NAAQS,the maximum contribution from the Speer Facility in any of these exceedances is 1.01 ug/m3. The Speer facility's contribution to any of these modeled violations are all less than the significant impact level for 1-hr NO2,therefore the impacts • from the Speer facility do not cause or contribute to an exceedance of the NAAQS. Design cocentrations below the first high were verified through the 13th ranked value; no NAAQS violations were found below that rank. Review Checklist 1.Topographic Map with Site and Receptor Locations Satisfactory All necessary information to verify the modeling was easily generated from available information contained in the submittals 2.Plant/Site Plot Plan Satisfactory Plant/site plot plan found in Attachment G of original submittal; all necessary information to verify the modeling was available. 3.Building Dimension Data Satisfactory Original submittal included building locations/dimensions.`Modeled data verified with Figure 2.2 of original submittal. 4.Determination of Fenceline Satisfactory Maps and figures showing the fence line were submitted with the application(Figures 2- 1 and 2-2 as well as Appendix A).Ambient air boundary receptors were placed accordingly and receptors were properly excluded from within the ambient air boundary. Date Printed: 9/23/2019 Page 4 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdfand subsequent addendum PM2.5 Addendum.pdf Reviewed by: Bradley Rink 5.Identification of Nearby Nonattainment Areas Satisfactory Original submital appropriately identified the ozone non attainment area and noted the site was within that area 6.Identification of Pollutants/Averaging Periods to Model Satisfactory The original submittal was only a demonstration of NOX compliance and included analyses for the Annual and 1-hr NO2 standard. Subsequently,an addendum was submitted to demonstrate compliance with the 24-hr and Annual PM2.5 NAAQS. 7.On-Site NAAQS/Non-Criteria Pollutant Emission Inventory Satisfactory Verified information from original submittal and subsequent addendum and the modeled values with information in APENs approved by the Permit Engineer 8.On-Site PSD Increment Emission Inventory Not Applicable A preliminary determination in June 1998 from the Colorado Attorney General's office suggests that rulemaking would be necessary before compliance with PSD increments is a requirement of permit issuance for minor sources and minor modifications.Therefore, increment consumption from minor source growth is assessed only during the modeling process for new sources and modifications subject to PSD rules and during periodic increment studies. 9.Off-Site NAAQS/Non-Criteria Pollutant Emission Inventory Satisfactory Detailed in facility selection criteria, including missing data and especially discussions with MEIU staff on how to determine if a site should be included in inventory. 10.Off-Site PSD Increment Emission Inventory Not Applicable See#8 above. 11.Background Concentration(s) Satisfactory Provided by Nancy Chick for NO2 and PM2.5 and included in all cumulative modeling for all pollutants and averaging periods. 12.Selection of Model(s) Satisfactory The original submittal included(at the time)appropriate model selection. MEN ran Date Printed: 9/23/2019 Page 5 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum P1112.5 Addendum.pdf Reviewed by: Bradley Rink significant and cumulative demonstrations using AERMET 19191,AERMAP 18081, and AERMOD 19191. 13.Selection of Modeling Parameters Satisfactory Regulatory defaults have been used. 14.Receptor Network Satisfactory The final receptor grid network was regenerated by MEM using NEDs and the most recent version of AERMAP, 18081. Elevations and hill heights for significant receptors were regenerated using AERMAP 18081,elevations and hill heights for the expanded cumulative grids(to include hot spots)were rerun with AERMAP 18081. The original receptor grid used by the applicant has the following receptor spacing: -Boundary receptors spaced at 50 meter intervals. -From the boundary to approximately 1 kilometer the receptors are spaced at 100 meter intervals. -From the 100-meter spaced grid to approximately 3 kilometer,the receptors are spaced at 250 meter intervals. -From the 250-meter spaced grid to approximately 10 kilometers,the receptors are spaced at 500 meter intervals. -From the 500-meter grid to approximately 20 kilometers,the receptors are spaced at 1000 meters 15.Treatment of Atmospheric Chemistry(NOx conversion) Satisfactory A seasonal NO2 profile was provided by MEN. The Ozone Limiting Method(OLM) was used,seasonal ozone profile provided by MEIU. NOX/NO2 in-stack ratios for all sources was set to 50%,approved by Permit Engineer. 16.Standard Temperature Pressure Corrections Not Applicable The Division does not require correction of model results to STP.Thus,the approach used is consistent with current modeling guidance. 17.Meteorological Data for Model(s) Satisfactory Meteorological data from the Ft. St.Vrain NWS surface station and the Denver- Stapletone upper air station for 2009 were found to be unrepresentative of the dispersion conditions at the project site.AERMOD-ready files were provided by the MEIU to the applicant.The modeling efforts of the MEIU were completed using data processed with Date Printed: 9/23/2019 Page 6 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum PM2.5 Addendum.pdf Reviewed by: Bradley Rink AERMET 19191. The complete meteorological determination is shown here: Re:met data request 1 message Malone-CDPHE,Emmett<emmett.malone@state.co.us>Thu,Feb 22,2018 at 8:16 AM To:Joe Miller<jmiller@mtn-air.com> Cc:Rosendo Majano<rosendo.majano@state.co.us>,Marie Bernardo-CDPHE <marie.bernardo@state.co.us>,Kira Shonkwiler-CDPHE <kira.shonkwiler@state.co.us> The Division has completed the AERMOD meteorological determination for: Source: Speer Gas Plant Approximate Location:524409.01 E,4457060.59 N,UTM NAD83,Zone 13 There are no existing meteorological data,to the Division's knowledge,that are adequately representative of dispersion conditions expected at this site.Consequently, the applicant may either collect a year of site-specific meteorological data(see option 1) to support a refined AERMOD modeling analysis,or the applicant may perform a screening impact analysis with AERMOD and the hourly meteorology presented in option 2.If AERMOD is used in a screening type mode with hourly meteorological data, design value restrictions will apply.The applicant is welcome to provide additional information to assist the meteorological determination process. OPTION 1: Collect at least one year of site specific meteorological data with a tower setup and location approved by the Division.The monitoring program must be performed in accordance with U.S.EPA accepted procedures as approved by the Division.If this option is pursued,it is strongly recommended that a monitoring plan be prepared and submitted to the Division for review prior to collection of the data.Once data has been collected and approved by the Division,contact the Division for site-specific AERMET processing guidance. OPTION 2: SURFACE METEOROLOGY Met Site:Ft St Vrain 2009 Tower LAT/LONG:40.254N, 104.872W Tower type:private Data period:2009 Date Printed: 9/23/2019 Page 7 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 • Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum Pi112.5 Addendum.pdf Reviewed by: Bradley Rink Data type: 15-minute site-specific Anemometer height: 10,30,60 m Profile Base Elevation:4776 ft Met site(cloud cover) Met Site: Denver DIA Tower LAT/LONG:39.847N, 104.656W Tower type:National Weather Service pre ASOS Tower Elevation: 5413 ft Data period: 1997 Data type:Integrated Surface Hourly(ISH)variable ASCII format(aka,ISHD, ISH, ISD,TD 3505) Anemometer height: 10 meters Data availability:attached UPPER AIR METEOROLOGY Site:KDEN(Denver,Colorado)WBAN number:23062 Data type:Radiosonde Site LAT/LONG:39.77N, 104.88W Collected by:National Weather Service Data format:NOAA Forecast Systems Laboratory(fsl)format Data availability: attached AERMOD Screening Impact Analysis Design Concentrations(for use with hourly met data of Option 2): *Use the highest modeled impact in the compliance demonstration from the"high 1st high"for averages less than or equal to 24 hours for short-term standards and"1st high" for annual standards from individual years.If the meteorology associated with the"high 1st high"is not plausible at the source location,please contact me for a re-evaluation of the design value. *For demonstrating compliance with standards that are attained from a multi-year average(e.g.,3-year average of the 98th percentile of the daily maximum 1-hour NO2 concentrations or 3-year average of the annual mean PM2.5 concentrations),the procedure above may be refined by using the maximum n-year average of the 1st-high corresponding averaging period concentrations determined on a receptor-by-receptor basis(where n equals the number of years modeled). *When determining compliance with the 1-hr NO2 standard,use 100%conversion of Date Printed: 9/23/2019 Page 8 of 12 Air Pollution Control Division /Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQJA.pdfand subsequent addendum PM2.5 Addendum.pdf Reviewed by: Bradley Rink NO to NO2. When determining compliance with the annual NO2 standard,use either the Tier 1 (100%conversion of NO to NO2)or Tier 2(multiply the Tier 1 estimate(s)by 0.75,the recommended empirically-derived NO2/NOx value for Colorado)approach from 40 CFR 51 Appendix W.If a different NO2 conversion approach than those listed above is needed for estimating either 1-hr or annual NO2 concentrations,contact Rosendo Majano(rosendo.majano@state.co.us)for details. This determination is not applicable for an unlimited period and may expire if there is a substantial delay between the date of this determination and the submittal of the permit application.If the location of the source moves or if additional modeling is warranted in the future at this site,contact the Division to confirm if this met determination is still valid.This determination is applicable provided that the permit application is not subject to the PSD rules.If the permitti ng action is subject to PSD rules,please contact the Division for a PSD pre-construction monitoring determination. FAQs on Air Quality Modeling Data and Techniques are available here http://www.colorado.gov/airquality/permits/FAQsOnAirQualityModel ingDataAndTechni quesl3Jul.pdf.National elevation data files are available here: http://vvww.colorado.gov/airquality/quad_selector_map.aspx.If there are questions, please contact Rosendo Majano(rosendo.majano@state.co.us). The completeness checklist for modeling submittals is available here: http://www.colorado.gov/airquality/permits/CompletenessChecklist- ModelingSubmittal l 4Feb.p df. State law requires that the Division determine the completeness of an application or any supplemental information requested for the application by the Division within 60 days of receipt.If the application(this includes the modeling submittal)is deemed incomplete, the applicant will be notified regarding the deficiencies and asked to either supplement the application or submit a new complete application.It is important to note that our review will not begin until a complete application has been received. Emmett Malone Supervisor Modeling and Emissions Inventory Unit Technical Services Program Date Printed: 9/23/2019 Page 9 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum PrlM2.5 Addendum.pdf Reviewed by: Bradley Rink Air Pollution Control Division Colorado Department of Public Health and Environment APCD-TS-B 1 4300 Cherry Creek Drive South Denver,CO 80246-1530 303-692-31361Emmett.Malone@state.co.us 18.Other Modeling Data Satisfactory Sensitivity runs were performed by MEIU to determine which combination of groups of engines identified in the submittal as either operating or serving as a backup would result in the highest impacts-all models were run with the combination of engines that produced the highest impacts(see recommendation#2) 19.Modeling Input/Output Files Provided Electronically Satisfactory Modeling files for NO2 demonstration and subsequent PM2.5 demonstration provided electronically. 20.Comparison of Impacts with Significance Levels Satisfactory Impacts verified with MEIU using most up to date versions of AERMET,AERMAP, and AERMOD. 21.Comparison of Impacts with Class I 24hr lug/m3 Rule Not Applicable Only applicable for major sources subject to PSD review 22.Compliance with"75% of Applicable Increment"Rule Not Applicable PSD increment modeling is not required for minor modifications under current Colorado rules. 23.Selection of Geographic Area for Full Impact Analysis Satisfactory The original modeling grid included with the submittal was a 20KIM x 20HIv1 grid, centered on the project site. The original NO2 cumulative receptor grid submitted to MEIU,comprised of the significant receptor grid and ten 2KM x 2KM'hot spot'areas was expanded to include an 11th hot spot. The final cumulative grid spanned a 31 KM by 36 KM area centered on the facility. The original PM2.5 grid submitted for the cumulative analysis was simply the significant receptor grid for each analysis-there are no large sources of PM2.5 in the area. 24.Compliance with Class I PSD Increments Date Printed: 9/23/2019 Page 10 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum Pr112.5 Addendum.pdf Reviewed by: Bradley Rink Not Applicable The proposed facility is not subject to PSD requirements. 25.Compliance with Class II PSD Increments Not Applicable The proposed facility is not subject to PSD requirements. 26.Compliance with NAAQS and State Standards Satisfactory Modeling analysis revised by MEIU demonstrate compliance with all appropriate NAAQS. 27.Compliance with Non-Criteria Pollutant Thresholds Not Applicable Not applicable. 28.Determination of Pre-/Post-Monitoring Requirements Not Applicable Pre/Post-construction montoring requirements are not triggered. 29.Visibility Impairment and AQRV Analyses Not Applicable Only applicable for major sources subject to PSD review 30.Anticpated Growth/SoilsNegetation Analyses Not Applicable Not applicable as long as the source is not subject to PSD rules. 31.Compliance with Regulations in Affected Adjacent States Not Applicable Source is not subject to PSD rules. 32.Risk Assessment Not Applicable Risk assessments and review of impacts from hazardous air pollutants are not performed on a routine basis and are only performed when a specific request is made by the Stationary Sources Program. SSP did not request a risk assessment for this modification. Date Printed: 9/23/2019 Page 11 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit Modeling Review Comments APCD/TSP/MMEIU Project ID: 522-190910 Review Completed: 9/12/2019 Plant/Site Name: SPEER Gas Plant Document Reviewed: Original submittal Speer AQIA.pdf and subsequent addendum PMY12.5 Addendum.pdf Reviewed by: Bradley Rink Access to data,notes,and files: All information necessary to form the basis of the air quality compliance demonstration is transmitted to the permit reviewer for inclusion in the permit file. In some cases,the Technical Services Program retains ambient air monitoring and modeling data,ambient monitoring and modeling plans and reports,electronic modeling input/output files,and other files.These files may contain documents that are considered to be part of a deliberative process. Date Printed: 9/23/2019 Page 12 of 12 Air Pollution Control Division/Technical Services Program Modeling, Meteorology, and Emission Inventory Unit cD E ! COLORADO CO I Air Pollution Control Division Department of Pi;btc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0148 Issuance: 1 Date Issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired, naturally aspirated, 4SLB C-601 004 reciprocating internal combustion engine, site rated at 1380 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for inlet gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516J engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. 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 Page 1 of 18 * CE ' COLORADO CO i Air Pollution Control Division Department of Pubhc feelth 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator o 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section TILE.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. Page 2 of 18 * CDPHE ( COLORADO jA 1 CO I € Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NO,t VOC CO C-601 004 1,132 515 426 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO. VOC CO C-601 004 6.7 3.0 2.5 Point 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 be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. Page 3 of 18 cDA E COLORADO CO Air Pollution Control Division Department of Publac Health$Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit(Reference: Regulation No.3, Part B, Section III E.) Facility AIRS Pollutants Equipment Control Device ID Point Controlled C-601 004 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs PROCESS LIMITATIONS AND RECORDS 10. 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 3, Part B,'II.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID C-601 004 Consumption of natural gas as a fuel 1 7.79 MMscf/f/yr MMscf/month Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer-provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 Page 4 of 18 ,A, CDPHE COLORADO CO o Air Pollution Control Division # Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 11. The permit number and AIRS ID point number(e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. OPERATING & MAINTENANCE REQUIREMENTS 15. 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 No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. A source initial compliance test shall be conducted on emissions point 004 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Page 5 of 18 CDPHE ; COLORADO CO I Air Pollution Control Division 3 Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice(APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources(NO),)in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one(1) ton per year or more or five percent, whichever is greater,above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five(5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. Page 6 of 18 cE iCOLORADO CO I Air Pollution Control Division 3 Department of F ublic Health 6 Environment Dedicated to protecting and improving the health and environment of the people of C olorado 19. The exhaust stacks) for the following emission points) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 O-652 011 10.1 O-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 20. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Maximum Number Combined Hours of Engines in Facility Equipment of Operation Per Operation at Any IDs AIRS Points Year Time C-410 and C-411 008,009 8760 1 of 2 C-651, O-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 21. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 22. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) Page 7 of 18 CO c 4.1 EAir Poitutio' COLORADO Pollution Control Division i .. 3 Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Equipment AIRS Equipment Current Pollutant ID Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J' VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 8 of 18 CDPHE ! COLORADO CO . ! Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO , 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 24. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. 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 No. 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 Page 9 of 18 A CDPHE ' COLORADO CO ":" i Air Pollution Control Division Department of Pubtic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. 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. 27. 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. 28. 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. 29. 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. 30. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 18 h CDP E COLORADO tA CO Air Pollution Control Division " i Department of PI bIx Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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: httpsaitwww.colorado.qov/pacific/cdphe/aacc-reps 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the,operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Are the Controlled Emission AIRS Pollutant CAS# Rate emissions Emission Point (Ib/yr) reportable? Rate(Ib/yr) Formaldehyde 50000 11,460 Yes 1,146 Acetaldehyde 75070 753 Yes 376 Toluene 108883 734 Yes 367 004 Acrolein 107028 463 Yes 231 Methanol 67561 225 No 113 Benzene 71432 117 No 59 n-Hexane 110543 100 No 50 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.1480 0.50 0.1480 0.50 CO 0.7964 2.69 0.0557 0.19 VOC 0.2694 0.91 0.0673 0.23 50000 Formaldehyde 0.1273 0.43 0.0127 0.04 75070 Acetaldehyde 0.0084 0.03 0.0042 0.01 108883 Toluene 0.0082 0.03 0.0041 0.01 107028 Acrolein 0.0051 0.02 0.0026 0.01 Page 11 of 18 CDPHE COLORADO CO ' Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr 67561 Methanol 0.0025 0.001 0.0013 0.0004 71432 Benzene 0.0013 0.0004 0.00065 0.0002 110543 n-Hexane 0.0011 0.0003 0.000555 0.0002 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7447 Btu/hp-hr,a site- rated horsepower value of 1380, and a fuel heat value of 981 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer No control. CO Manufacturer Applicant requested. VOC Manufacturer; sum of Applicant requested. NMNEHC + HCHO 50000 Formaldehyde Manufacturer Applicant requested. 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 108883 Toluene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 71432 Benzene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 110543 n-Hexane " AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). 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 on the EPA website at: http://www.epa.govittn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8.A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.00v/ttn/atw/area/arearules.html Page 12 of 18 CDPHE I COLORADO Co I Air Pollution Control Division I Department of Public Health fr Environment Dedicated to protecting and improvinn the health and environment of the people of Colorado 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of:VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of:VOC MACT ZZZZ Area Source Requirements: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 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)CXXXXX 11) A self-certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification Page 13 of 18 A CDPHE COLORADO CO i E Air Pollution Control Division Department of public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS,and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period."Permanent"is defined as in the same service for more than 90 operating days in any 12 month period.The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. `The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement,the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable Page 14 of 18 ,� CDPHE COLORADO CO Is.a. ► Air Pollution Control Division # Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This A0S cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer)as found on the Division's web site at: w ww.colorado.bov/cdphe/portable-analyzer-mon itorinq-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation Page 15 of 18 4 CDYHE ICOLORADO CO IrI Air Pollution Control Division 1 Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg.3, Part B§ II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology(RACT)for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Page 16 of 18 CDPHE ICOLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that,it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1,2008 2.0 4.0 1.0 100<Hp<500 January 1,2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,3 50 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation Page 17 of 18 CDPHE ' COLORADO CO I Air Pollution Control Division " l Department 0 Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing,engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site,an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 18 of 18 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 SW 31 4N Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) Q Ozone (NOx & vOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 0C Liquid Loading SP300-10 Ye=: 19WE0165 Yes Permit Initial Issuance 002 NG Heater HTR-703 No 15WE1029.XP No APEN Required / Permit Exempt 004 Natural Gas RICE C-601 Yes 19WE0148 Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 — Yes $ 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 `,'es 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE _ C-653 Yes 19WE0156 _ _ Yes Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 — No 19WE0160 _ Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the em ission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.S 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: SO? , NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ✓ ✓ H ✓ Non-Attainment New Source Review (NANSR) `/ Is this stationary source a major source? If yes, explain what programs and which pollutants here: SO? NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) - R i_1 ■ . E__ Non-Attainment New Source Review (NANSR) Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0149 Facility Name Speer Gas Plant AIRS 123/9DF7/005 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-602 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1)Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired, naturally aspirated,4SLB reciprocating internal combustion engine, site rated at 1380 horsepower.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used for inlet gas compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 91.77 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 7.79 Permit limits calculated at(hpy) 8760 Puel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 7447 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 6.66 6.66 6.66 0.0% VOC 12.13 3.03 12.13 75.0% CO 35.85 2.51 35.85 93.0% SOx 0.03 0.03 0.03 0.0% TSP 0.45 0.45 0.45 0.0% PM 10 0.45 0.45 0.45 0.0% PM2.5 0.45 0.45 0.45 0.0% Total HAPs* 0.0 0.0 7.0 82.8% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( lb/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 11460 1146 11460 90 . 0% Acetaldehyde 753 376 753 50 . 0% Toluene 734 367 734 50 . 0% Acrolein 463 231 463 50 . 0% Methanol 225 50 . 0% Benzene * * 117 50 . 0% n- Hexane * * 100 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E Standards (g/hp- hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area Yes source requirements? Is this engine subject to NSPS JJJJ ? Yes NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCalc literature/tests . COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 '13.2 0.0 3.6 0.2 Trevious taken from May 2018 tab Previous Permitted Facilit/ total 0.0 0.0 0. 0 0. 0 0. 6 94. 1 0. 0 1. 1 0. 7 0. 0 0. 0 0. 0 0. 0 0. 6 12. 9 0. 0 1. 1 0.2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" (X13 Canc Feilac of e- ::.a;icell&d under new facility configuration - 004 19WE0148 , Caterpillar G3516J, sn: TBD - 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0- 6.7 3.03 2.51 1 .2 "C-601 " 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5, 0.5 i 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" .. 006 19WE0150 Caterpillar O3516J, sn: TBD 0.5 0.5 ` 0.0. 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" 008 19WE0152 Caterpillar G3512B, sn: TBD "C-410" Requested combined limit of 8760 hr/yr 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2 .66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-652" 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013,014,and 015. 014 19WE0157 Caterpillar G3516C, sn: TBD "G-772" 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 015 19WE0157 Caterpillar G3516C , sn: TBD "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 Hot oil heater, 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leak.-i 99.2 3.4 9.8 0.5 "LEAKS" ',PEN-Exempt / Insignificants 0.0 0.0 _ 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81.7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH. & Total 7777: Syn Minor Permitted Facility Total 7 4 7 4 0. 0 1 8 80 6 755. 9 99. 2 447 5 219 0 7 4 1 42: 0. 0 1. 8 80. 6 73. 8 9. 8 86.5 23. 6 Excludes units exempt from permits/APENs (o) Change in Permitted Emissions 7. 4 7. 4 0. 0 1. 8 80.0 60.9 9. 8 85. 4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83.8 Facility is eligible for GP02 because < 90 tpy (zi) Change in Total Permitted VOC emissions (point and fugitive) _ 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/11 /2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene , ,. ,,r,,,.,,., TOTAL (tpY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 51 46 129 108 59 173 127 21 0 . 5 00,E :aricei eu l , - ax c} 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 . 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 . 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 73 164 16 18 5 . 6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 40 5 . 9 011 19WE0154 Caterpillar G3608 , sn : TBD , 7725 1255 771 195 1223 e, 41 167 375 38 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10.4 MMBtu/hi 77 67 68 93 120 161 88 259 31 0 .7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43. 3 30362 14458 145 1446 2892 216872 0 .29 1446 133 . 8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3 .4 0 . 0 APEN-Exempt / Insipnificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 56. 8 4. 3 2.5 17.4 12. 9 0.7 1 . 5 10. 6 110.3 0. 9 0.7 0.6 0. 2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0149 . CP1 9/11 /2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene TOTAL (tPY) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr r1 45 46 129 108 173 127 21 0 . 5 .;anceit :c _ 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 008 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 1 9 37 82 8 9 0 . 9 009 19WE0152 Caterpillar G3512B , sn : TBD 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 19 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 21 83 188 19 20 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 _ 158 16 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 16 17 1 . 9 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 192 120 161 88 259 189 31 0 . 7 017 19WE0161 Hot oil heater, 19 .33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd =13 . 3 1518 723 72 145 10844 72 6 . 7 020 19WE0164 Plant Flare 108 108 22 540 32 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 743 0 . 5 0 . 0 APEN-Exempt / lnsignificants 0 . 0 0 . 0 0 . 0 1 0 . 0 TOTAL (tpy) 5.9 2. 2 1 . 3 1 .4 2.7 0. 6 0. 5 1 . 6 I 6.3 0. 8 0. 0 0.6 0. 2 24 . 03 6 19WE0149 . CP1 9/11 /2019 A c PE COLORADO CO �. Air Pollution Control Division Department of Pubtic Health a Environment Dedicated to protecting and improving the health and environ rnent of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0149 Issuance: 1 Date Issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Equipment ID Point Description One (1) Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired,naturally aspirated, 4SLB G-602 005 reciprocating internal combustion engine, site rated at 1380 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for inlet gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516J engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.ciov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Page 1 of 18 A CDPHE ' COLORADO CO I" Mr Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 per Regulation No. 3, Part B, lll.F4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section TILE.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, TILE.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. Page 2 of 18 A `DPHE COLORADO CO Air Pollution Control Division i Department of Public Health&Environment Dedicated to protecting and im proving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NO. VOC CO C-602 005 1,132 515 426 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO. VOC CO C-602 005 6.7 3.0 2.5 Point 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 be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. Page 3 of 18 ,^ CD! E ICOLORADO CO If Air Pollution Control Division i Department of Pubthc Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section IIIE.) Facility AIRS Pollutants Equipment Control Device ID Point Controlled C-602 005 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs PROCESS LIMITATIONS AND RECORDS', 10. 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 3, Part B, I I.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID C-602 005 Consumption of natural gas as a fuel 1 7.79 MMscf/f/yr MMscf/month Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer-provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 Page 4 of 18 CDPHE COLORADO CO 5 Air Pollution Control Division Department of public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 11. The permit number and AIRS ID point number (e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. OPERATING & MAINTENANCE REQUIREMENTS 15. 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 No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. A source initial compliance test shall be conducted on emissions point 005 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Page 5 of 18 4 CDPHE COLORADO CO I Air Pollution Control Division t Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice(APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources(NOr)in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less,above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five(5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. Page 6 of 18 ,^ CDPH COLORADO CO Air Pollution Control Division Department of Public Health E+Environment Dedicated to protecting and improving the health and environment of the people of Colorado 19. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 20. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Maximum Number Facility Equipment Combined Hours of Engines in q p ment of Operation Per Operation at Any IDs AIRS Points Year Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 21. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 22. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) Page 7 of 18 4 cD�E ICOLORADO CO i Air Pollution Control Division iDepartment of Public Health&Environment Dedicated to protecting and improving the health and environ rnent of the people of Colorado 23. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Equipment AIRS Equipment Current ID Point Description Pollutant P Threshold ' Permit Limit SP300-10 001 Load out V0C 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 8 of 18 ,^ CDP1HE 1COLORADO CO Li I Air Pollution Control Division 1 ,„ 1 Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 ` 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 24. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. 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 No. 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 Page 9 of 18 4 CDPHE COLORADO CO ��. Air Pollution Control Division Department of Pub?tc Health&£nvironrnent Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. 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. 27. 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. 28. 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. 29. 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. 30. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 18 A C��E ' COLORADO CO I" 1 Air Pollution Control Division I Department of PubItc Health&Environment Dedicated to protecting and improving the health and environ rnent of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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/pacifidbdphe/aqcc-reqs 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. Uncontrolled Are the Controlled AIRS Pollutant CAS# Emission emissions ' Emission Point Rate` reportable? Rate(lb/yr) (Ib/yr) Formaldehyde 50000 11,460 Yes 1,146 Acetaldehyde 75070 753 Yes 376 Toluene 108883 734 Yes 367 005 Acrolein 107028 463 Yes 231 Methanol 67561 225 No 113 Benzene 71432 117 No 59 n-Hexane 110543 100 No 50 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.1480 0.50 0.1480 0.50 CO 0.7964 2.69 0.0557 0.19 VOC 0.2694 0.91 0.0673 0.23 50000 Formaldehyde 0.1273 0.43 0.0127 0.04 75070 Acetaldehyde 0.0084 0.03 0.0042 0.01 108883 Toluene 0.0082 0.03 0.0041 0.01 107028 Acrolein 0.0051 0.02 0.0026 0.01 Page 11 of 18 CDPHE COLORADO Co �E-�1 j Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr 67561 Methanol 0.0025 0.001 0.0013 0.0004 71432 Benzene 0.0013 0.0004 0.00065 0.0002 110543 n-Hexane 0.0011 0.0003 0.000555 0.0002 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7447 Btu/hp-hr,a site- rated horsepower value of 1380, and a fuel heat value of 981 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer No control. CO Manufacturer Applicant requested. VOC Manufacturer; sum of Applicant requested. NMNEHC + HCHO 50000 Formaldehyde Manufacturer Applicant requested. 75070 Acetaldehyde AP-42; Table 3.2-2(7/2000); Applicant requested. Natural Gas 108883 Toluene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 107028 Acrolein AP-42; Table 3.2-2(7/2000); Applicant requested. Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 71432 Benzene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 110543 n-Hexane AP-42; Table 3.2-2(7/2000); Applicant requested. Natural Gas 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). 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 on the EPA website at: http://www.epa.00vittn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8.A copy of the complete subpart is available on the EPA website at: http://www.epa.aov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.00v/ttn/atw/area/arearules.html Page 12 of 18 `DPHE COLORADO CO I Air Pollution Control Division Department of Pubhc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of:VOC MACT ZZZZ Area Source Requirements: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 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 11) A self-certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.qov/pacific/cdphe/air-permit-self-certification Page 13 of 18 CDPHE ' COLORADO CO I Air Pollution Control Division Department of Pubiac Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period."Permanent"is defined as in the same service for more than 90 operating days in any 12 month period.The 90;days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement,the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable Page 14 of 18 46, CDPHE COLORADO COQ. 1 Air Pollution Control Division i Department of Piratic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colo.rado..gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's web site at: www.colorado.gov/cdphe/portable-analyzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation Page 15 of 18 ADO CDPHE 1 C O LuO R OYD ODivision CO Department or Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B§ II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology(RACT)for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and N0X are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Page 16 of 18 CDRHE ! COLORADO CO trfAir Pollution Control Division Department of public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation Page 17 of 18 * CDPHE ICOLORADO CO ' Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site;an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 18 of 18 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 SW 31 . Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) ✓ Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 001 Liquid Loading SP300-10 19WE0165 CP1 _ Permit F rtialissuance 002 NG Heater HTR-703 N 15WE1029.XP XP No APEN Required / _ Permit Exempt 14 Natural Gas RICE C-601 Yes 19WE0148 Yes _ 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 CP1 Yes Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE _. 3 Yes 19WE0159 Yes 016 _ NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 r'es Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required ? Yes If yes, for what pollutants? NOx, PM2.5 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? YE., If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) •,/ Q Non-Attainment New Source Review (NANSR) `I Is this stationary source a major source? If yes, explain what programs and which pollutants here: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) , Title V Operating Permits (OP) I] , n A , . . Non-Attainment New Source Review (NANSR) Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0150 Facility Name Speer Gas Plant AIRS 123/9DF7/006 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-603 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1)Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired, naturally aspirated,4SLB reciprocating internal combustion engine, site rated at 1380 horsepower.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used for inlet gas compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 91.77 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 7.79 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 7447 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 6.66 6.66 6.66 0.0% VOC 12.13 3.03 12.13 75.0% CO 35.85 2.51 35.85 93.0% SOx 0.03 0.03 0.03 0.0% TSP 0.45 0.45 0.45 0.0% PM10 0.45 0.45 0.45 0.0% PM2.5 0.45 0.45 0.45 0.0% Total HAPs* 0.0 0.0 7.0 82.8% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 11460 1146 11460 90 . 0% Acetaldehyde 753 376 753 50 . 0% Toluene 734 367 734 50 . 0% Acrolein 463 231 463 50 . 0% Methanol 225 50 . 0% Benzene * * 117 50 . 0% n- Hexane * * 100 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minims Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E Standards (g/hp- hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) Ye:: source requirements? Is this engine subject to NSPS JJJJ ? Yes NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCaIc literature/tests . COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 revious taken frf May 2018 tab Previous Permitted Facility total 0. 0 0. 0 0.0 0.0 0. 6 94. 1 0.0 1. 1 0. 7 0. 0 0. 0 0. 0 0. 0 0. 6 12. 9 0. 0 1. 1 0.2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 , 0.5 "HTR-703" c:;f.i... `' ' r ` mc,%elIed under new rac;iity configuration 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " _ 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0, 6.7' 12. 1 35.9 7.0 0.5, 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" _ 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" 008 19WE0152 Caterpillar G3512B, sn: TBD "C-410" Requested combined limit of 8760 hr/yr 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn. TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G3516C , sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013,014,and 015. 014 19WE0157 Caterpillar G35160 , sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 "G-772" 015 19WE0157 Caterpillar G3516C , sn: TBD "G-773" _ 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr Btu/hr 017 19WE0161 Hot oil heater. 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfci 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, 1, n-hex, HCHO, McOH . & Total 7777: Syn Minor Permitted Facility Total , 7. 4 7. 4 0.0 1. 8 80. 6 755. 9 99. 2 447 5 219. 0 7. 4 7. 42 0. 0 1. 8 80. 6 73. 8 9.8 86.5 23.6 Excludes units exempt from permits/APENs (n) Change in Permitted Emissions 7 4 7. 4 0. 0 1. 8 80. 0 60.9 9. 8 85. 4 Pubcom required. Modeling required for NOy and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 tpy (o, Change in Total Permitted VOC emissions (point and fugitive) _ 70. 7 _ Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/11/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene °s,7 ,,.. TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 D 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 , 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 51 45 46 129 108 173 21 , 0 . 5 ((//.�JJ!(gyp n ,tea t! ,{ ) /arc; 003 Jau(ct;1Ieu ra 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 18 73 164 16 18 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 41 167 375 _ 38 40 5 . 9 011 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 41 167 375 38 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 _ 34 140 315 32 34 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 32 34 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 120 161 88 259 1 ri 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 _ 376 205 605 443 r 73 1 . 6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 30362 14458 145 1446 2892 216872 0.29 1446 133. 8 020 19WE0164 Plant Flare 2161 2161 _ 22 432 10805 648 22 8 . 1 021 , 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3 .4 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 _ 0 . 0 0 . 0 TOTAL (tpy) 56.8 4.3 2.5 17.4 12. 9 0. 7 1 . 5 10.6 _ 110. 3 0. 9 0.7 0. 6 0. 2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0150 . CP1 9/11 /2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene - TOTAL (tpy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr 45 46 129 81 108 59 173 '� 21 0 . 5 ance /eta 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 _ 50 113 11 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 008 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 1 9 37 82 8 9 0 . 9 009 19WE0152 Caterpillar G3512B , sn : TBD 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 19 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 21 83 188 19 20 1 .4 012 19WE0154 Caterpillar G3608, sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 17 70 158 16 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82. 514 17 70 158 16 17 1 . 9 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 192 120 4 161 88 259 189 31 0 .7 017 19WE0161 Hot oil heater, 19 .33 MMBtu/hr I 143 4 125 127 172 358 4 224 299 163 481 352 58 1 .3 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 .3 1518 723 7 72 145 10844 c r 72 6 . 7 020 19WE0164 Plant Flare 108 108 1 22 540 32 i 0 . 2 0.4 021 19WE0166 Facility fugitive equipment leaks 65 67 1 743 ;I; 0 . 5 0 .0 APEN-Exempt / Insignificants 0 .0 0 .0 _ 0. 0 0 . 0 TOTAL (tpy) 5.9 2.2 1 .3 1 .4 2.7 0. 6 0. 5 1 . 6 6.3 . 0.8 0. 0 0.6 0. 2 24 .03 I 6 19WE0150 . CP1 9/11 /2019 cD'HE COLORADO CO sr Air Pollution Control Division k Department of Pubhc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE01 50 Issuance: 1 Date Issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired, naturally aspirated, 4SLB C-603 006 reciprocating internal combustion engine, site rated at 1380 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for inlet gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516J engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.qov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Page 1 of 18 ,^ COPE ! COLORADO CO I Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 per Regulation No. 3, Part B, II1.F.4.b. (Reference: Regulation No. 3, part B, Iil.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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • ' manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. Page 2 of 18 A C��E COLORADO CO sr Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point Emission Type NO, VOC CO C-603 006 1,132 515 426 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons per Year Equipment ID Point Emission Type NO„ VOC CO C-603 006 6.7 3.0 2.5 Point 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 be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. Page 3 of 18 ct E COLORADO CO ,. ! Air Pollution Control Division 4 Department of Pubtc Health&Environment Dedicated to protecting and im proving the health and environment of the people of Colorado 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit(Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Control Device ID Point Controlled C-603 006 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs PROCESS LIMITATIONS AND RECORDS 10. 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 3, Part B, ll.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID C-603 006 Consumption of natural gas as a fuel 91.77 7.79 MMscf/yr MMscf/month Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer-provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined o 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 Page 4 of 18 A CDPHE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 11. The permit number and AIRS ID point number(e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. OPERATING & MAINTENANCE REQUIREMENTS 15. 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 No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. A source initial compliance test shall be conducted on emissions point 006 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Page 5 of 18 CDPHE COLORADO CO Air Pollution Control Division Department of public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice(APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources(NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one(1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five(5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. Page 6 of 18 A CDP E COLORADO l Air Pollution Control Division Department of Public Health&Environment CO Sc. Dedicated to protecting and improving the health and environment of the people of Colorado 19. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 20. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Maximum Number Combined Hours of Engines in Facility Equipment of Operation Per Operation at Any IDs AIRS Points Year Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 21. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 22. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) Page 7 of 18 4, cD1E COLORADO CO ? Air Pollution Control Division 1 Department or Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of.the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 8 of 18 A CCTPHE COLORADO '-1 CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 24. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. 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 No. 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 Page 9 of 18 A CDPHE ICOLORADO CO Air Pollution Control Division - I Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. 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. 27. 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. 28. 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. 29. 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. 30. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 18 cDP E COLORADO CO If Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and im proving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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.co lo rado.qov/pacific/cdp he/aqcc-req s 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. Uncontrolled Are the Controlled AIRS Pollutant CAS# Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (Ib/yr) Formaldehyde 50000 11,460 Yes 1,146 Acetaldehyde 75070 753 Yes 376 Toluene 108883 734 Yes 367 006 Acrolein 107028 463 Yes 231 Methanol 67561 225 No 113 Benzene 71432 117 No 59 n-Hexane 110543 100 No 50 5) The emission levels contained in this permit are based on the following emission factors: Point 006: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 0.1480 0.50 0.1480 0.50 CO 0.7964 2.69 0.0557 0.19 VOC 0.2694 0.91 0.0673 0.23 50000 Formaldehyde 0.1273 0.43 0.0127 0.04 75070 Acetaldehyde 0.0084 0.03 0.0042 0.01 108883 Toluene 0.0082 0.03 0.0041 0.01 107028 Acrolein 0.0051 0.02 0.0026 0.01 Page 11 of 18 DPHE COLORADO CO Air Pollution Control Division Department of Public Health Et Enrironment Dedicated to protecting and improving the health and environment of the people of Colorado Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr 67561 Methanol 0.0025 0.001 0.0013 0.0004 71432 Benzene 0.0013 0.0004 0.00065 0.0002 110543 n-Hexane 0.0011 0.0003 0.000555 0.0002 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7447 Btu/hp-hr,a site- rated horsepower value of 1380, and a fuel heat value of 981 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer No control. CO Manufacturer Applicant requested. VOC Manufacturer; sum of Applicant requested. NMNEHC + HCHO 50000 Formaldehyde Manufacturer Applicant requested. 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 108883 Toluene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 71432 Benzene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). 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 on the EPA website at: http://www.epa.povittn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8.A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.pov/ttn/atw/area/arearules.html Page 12 of 18 4 CDPHE COLORADO Co If I Air Pollution Control Division " Department of Public Health fa Environment Dedicated to protecting and improvinct the health and environment of the people of Colorado 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene,toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: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 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 XXX)O(X 11) A self-certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification Page 13 of 18 c� e 1COLORADO CO Air Pollution Control Division 1 Department of Public Health&£nironment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS,and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or • permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period."Permanent"is defined as in the same service for more than 90 operating days in any 12 month period.The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this A0S are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable Page 14 of 18 4, cPHE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's web site at: www.colorado.gov/cdphe/portable-analyzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation Page 15 of 18 cDPHE_ COLORADO CO 1' Air Pollution Control Division IDepartment of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B§ II.DD.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology(RACT)for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Page 16 of 18 4 P'HE ( COLORADO CO Air Pollution Control Division i " I Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1,2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation Page 17 of 18 4 c��E COLORADO CO I Air Pollution Control Division I Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site;an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 18 of 18 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 c'v'/ 31 4N 65 Plant AIRS ID: 90F7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) Q Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 0C ' Liquid Loading SP300-10 Ye 19WE0165 Yes Permit Initial issuance APEN Required / 002 NG Heater HTR-703 No 15WE1029.XP No Permit Exempt 004 Natural Gas RICE C-601 Yes 19WE0148 — Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes I9WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 No _9WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 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: SO? NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ./ pi 1 J Non-Attainment New Source Review (NANSR) I J Is this stationary source a major source? No If yes, explain what programs and which pollutants here: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) II n 1.1 ■ Non-Attainment New Source Review (NANSR) Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0151 Facility Name Speer Gas Plant AIRS 123/9DF7/007 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-604 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired, naturally aspirated,4SLB reciprocating internal combustion engine, site rated at 1380 horsepower.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used for inlet gas compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 91.77 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 7.79 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 7447 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM 10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 6.66 6.66 6.66 0.0% VOC 12.13 3.03 12.13 75.0% CO 35.85 2.51 35.85 93.0% SOx 0.03 0.03 0.03 0.0% TSP 0.45 0.45 0.45 0.0% PM 10 0.45 0.45 0.45 0.0% PM2.5 0.45 0.45 0.45 0.0% Total HAPs* 0.0 0.0 7.0 82.8% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( lb/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 11460 1146 11460 90 . 0% Acetaldehyde 753 376 753 50 . 0% Toluene 734 367 734 50 . 0% Acrolein 463 231 463 50 . 0% Methanol * 225 50 . 0% Benzene * 117 50 . 0% n-Hexane * * 100 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Standards (g/hp-hr) Reg 7 XVI . B (Ozone NAA Yes requirements) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) Yes source requirements? Is this engine subject to NSPS JJJJ ? Yes NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCalc literature/tests . COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date [ 4/2/2019 Plant AIRS ID 9DF7 Ozone Status I Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 'revious taken from May 2018 tab Previous Permitted Facilit/ total 0.0 0. 0 0.0 0.0 0. 6 94. 1 0 0 1. 1 0. 7 0.0 0. 0 0. 0 0. 0 0. 6 12.9 0.0 1 . 1 0.2 1 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" 003 cancelled Fla;c -,r)ceiled under feWV let v configuration 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" 008 19WE0152 Caterpillar G3512B, sn TBD "C-410" Requested combined limit of 8760 hr/yr 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B. sn_ TBE) "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hrlyr _between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 012 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 "C-653" 013 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hrl; between points 013,014,and 015. 014 19WE0157 Caterpillar G35160, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-772 015 19WE0157 Caterpillar G3516C, sn: TBD "G-773" Heater for dehy regen, 10.4 016 19WE0160 /Heater hr 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu017 19WE0161 Hot oil heater. 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 0.0 . 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH , & Total 7777: Syn Minor Permitted Facility Total i 7. 4 7. 4 0. 0 1. 8 80. 6 755. 9 99. 2 447. 5 219. 0 7. 4 7. 42 0. 0 1. 8 80. 6 73. 8 9. 8 86. 5 23.6 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 7. 4 7. 4 0. 0 1. 8 80. 0 60. 9 9. 8 85. 4 Pubcom required. Modeling required for NOx - and PM2.5. Total VOC Facility Emissions (point and fugitive) 83.8 Facility is eligible for GP02 because < 90 tpy ,A) Change in Total Permitted VOC emissions (point and fugitive _ 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/11/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled ( lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene " `''` TOTAL (tPY) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr 45 46 62 129 108 59 173 127 : ' i 0 . 5 03 lanceitei 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 4 753 463 117 734 4 25 100 225 23 4 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 _ 7 . 0 007 19\A/E0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 73 164 16 18 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 40 5 . 9 011 19WE0154 Caterpillar 63608, sn : TBD 7725 1255 771 195 1223 c 41 167 375 38 40 5 . 9 012 19WE0154 , Caterpillar G3608, sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 32 34 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 32 34 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 ': 120 88 259 31 0 . 7 017 19WE0161 Hot oil heater, 19 .33 MMBtu/hr 143 125 127 172 _ 358 224 299 163 481 352 58 1 . 3 018 _ 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 _ 1 .6 019 19VVE0163 Amine sweetening , 60 MMscfd 43 .3 T 30362 14458 145 1446 2892 216872 0.29 1446 133. 8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 r 5292 143 6 3 .4 0 . 0 APEN-Exempt / Insignificants 0 .0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 56. 8 4. 3 2.5 17.4 12.9 0.7 1 . 5 10. 6 110. 3 0 . 9 0.7 0. 6 0. 2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0151 . CP1 9/11 /2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene TOTAL (tpY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP • Hot oil heater, 6 .96 MMBtu/hr : { 45 46 62 129 108 59 173 21 0 . 5 Out,. 2a/ice:H&c/ , 004 19WE0148 Caterpillar G3516J , sn : TBD _ 1146 376 231 59 367 2 12 50 113 _ 11 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 007 19VVE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 T 2 12 50 113 11 12 1 .2 008 19VVE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 1 9 37 82 8 9 0 . 9 009 19VVE0152 Caterpillar G3512B , sn : TBD 010 19WE0154 Caterpillar G3608 , sn : TBD 772 _ 627 386 98 612 3 1 21 83 188 19 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 ? 21 83 188 19 20 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 16 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 16 17 1 . 9 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 192 120 161 7 88 259 189 w 31 0. 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening . 60 MMscfd 43 . 3 1518 723 7 72 145 10844 0.01 72 6 . 7 020 19WE0164 Plant Flare 108 108 1 22 540 32 1 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 1 15 743 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 .0 0 . 0 TOTAL (tpy) 5.9 2. 2 1 .3 1 .4 2.7 0. 6 0.5 1 .6 6.3 0. 8 0.0 0. 6 0. 2 24 . 03 6 19WE0151 .CP1 9/11 /2019 =D%itE COLORADO CO Is Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0151 Issuance: 1 Date Issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3516J, Serial Number To Be Determined, natural gas-fired, naturally aspirated, 4SLB C-604 007 reciprocating internal combustion engine, site rated at 1380 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for inlet gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516J engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. 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 Page 1 of 18 'h C H E = COLORADO CO i ; Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, IIl.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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. Page 2 of 18 CDPHE COLORADO CO ' Air Pollution Control Division Department of Putatac Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NOX VOC CO C-604 007 1,132 515 426 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 Iblmonth. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons Per Year Emission Type Equipment ID Point NOX VOC CO C-604 007 6.7 3.0 2.5 Point 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 be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. Page 3 of 18 CDPHE COLORADO CO ' Air Pollution Control Division Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment,which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E) Facility AIRS Pollutants Equipment Control Device ID Point Controlled C-604 _ 007 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs PROCESS LIMITATIONS AND RECORDS 10. 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 3, Part B, Il.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID C-604 007 Consumption of natural gas as a fuel 91.77 7.79 MMscf/yr MMscf/month Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer-provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 Page 4 of 18 + CDPHE ! COLORADO CO Air Pollution Control Division IDepartment of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 11. The permit number and AIRS ID point number (e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 13. This source is subject to, the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. OPERATING & MAINTENANCE REQUIREMENTS 15. 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 No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. A source initial compliance test shall be conducted on emissions point 007 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Page 5of18 CDPHE COLORADO CO ? Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice(APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources(NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one(1) ton per year or more or five,percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50%or five(5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. Page 6 of 18 C COLORADO CO �'ia Air Pollution,Control Division Department of Pub' Health&Environment Dedicated to,protecting and irn srovinet the health and environment of the people ofColorado 19. The exhaust stacks) for the following emission points) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-"773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 20. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Maximum Number Combined Hours_ of Engines in Facility Equipment of Operation Per Operation at Any IDs AIRS Points Year Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, n 013, 014, 015 17520 2 of 3 21. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as ar result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section HI B.5.) 22. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section lll.B.5.) Page 7 of 18 * CDPHE 1COLORADO CO 1 Air Pollution Control Division I Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit SP300-10 001 Loadout V0C 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 8 of 18 ,A c��E COLORADO CO 1.:-/ {44{ Air Pollution Control Division 1 Department of Pubtic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 ' 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 24. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. 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 No. 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 Page 9 of 18 CDPHE ' COLORADO Air Pollution Control Division COV ! Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. 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. 27. 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. 28. 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 nitio. 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. 29. 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. 30. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 18 CDPHHE COLORADO CO ice. Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and im proving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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:I/www colorado.gov/pacific/cdphe/aqcc-reqs 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. Uncontrolled Are the Controlled Emission AIRS Pollutant CAS# Rate emissions Emission Point (Ib/yr) reportable? Rate(lb/yr) Formaldehyde 50000 11,460 Yes 1,146 Acetaldehyde 75070 753 Yes 376 Toluene 108883 734 Yes 367 007 Acrolein 107028 463 Yes 231 Methanol 67561 225 No 113 Benzene 71432 117 No 59 n-Hexane 110543 100 No 50 5) The emission levels contained in this permit are based on the following emission factors: Point 007: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.1480 0.50 0.1480 0.50 CO 0.7964 2.69 0.0557 0.19 VOC 0.2694 0.91 0.0673 0.23 50000 Formaldehyde 0.1273 0.43 0.0127 0.04 75070 Acetaldehyde 0.0084 0.03 0.0042 0.01 108883 Toluene 0.0082 0.03 0.0041 0.01 107028 Acrolein 0.0051 _ 0.02 0.0026 0.01 Page 11 of 18 c0PHE COLORADO Co 9 I Air Pollution Control Division - Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr 67561 Methanol 0.0025 0.001 0.0013 0.0004 71432 Benzene 0.0013 0.0004 0.00065 0.0002 110543 n-Hexane 0.0011 0.0003 0.000555 0.0002 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7447 Btu/hp-hr, a site- rated horsepower value of 1380, and a fuel heat value of 981 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer No control. CO Manufacturer Applicant requested. VOC Manufacturer; sum of Applicant requested. NMNEHC + HCHO 50000 Formaldehyde Manufacturer Applicant requested. 75070 Acetaldehyde AP-42; Table 3.2-2(7/2000); Applicant requested. Natural Gas 108883 Toluene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 107028 Acrolein AP-42; Table 3.2-2(7/2000); Applicant requested. Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 71432 Benzene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 110543 n-Hexane AP-42;Table 3.2-2(7/2000); Applicant requested. Natural Gas 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). 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 on the EPA website at: http://www.epa.covittn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8.A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.pov/ttn/atw/area/arearules.html Page 12 of 18 CDPHE 1 COLORCOLORADO CO Air Pollution Control Division Departmeht of Public Health fa Environment Dedicated to protecting and improving the health and environment of the people of Colorado 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of:VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of:VOC MACT ZZZZ Area Source Requirements: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.govt 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 11) A self-certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification Page 13 of 18 cDPHE COLORADO CO Se Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The folowing Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS,and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period."Permanent"is defined as in the same service for more than 90 operating days in any 12 month period.The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this A0S are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable Page 14 of 18 ,^ C E COLORADO CO Air Pollution Control Division r Department of Pubtc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado„cjov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true,accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's web site at: www.colorado.gov/cdphe/portable-analvzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation Page 15 of 18 A CAE COLORADO CO Sr ; Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and unprovinct the health and environment of the people of Colorado the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent,Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B§ I1„D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology(RACT)for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Page 16 of 18 CDPHE COLORADO Air Pollution Control Division CO I 1 Department of Pub₹ic Heaith&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the,engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1,2008 2.0 4.0 1.0 100<Hp<500 January 1,2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition tos that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes• of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation Page 17 of 18 CO DPHO C E A Con O L O R DtroDivision 1 Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado No. 6, Part B, § LB (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site,an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 18 of 18 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 4N ES Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? ll Carbon Monoxide (CO) ■ Particulate Matter (PM) ./ Ozone (NOA 84 VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 001 Liquid Loan{ i-- SP300-?G 19WE0165 Yes Permit ir, attssuance APEN Required / 002 NG Heater HTR-703 R-703 No 15WE1029.XP No Permit Exempt 004 Natural Gas RICE C-601 Yes 19WE0148 Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit Initial CP1 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 _ NG Heater H-310 No 19VVE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes — 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leak_; LEAKS .---s 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 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) Title V Operating Permits (OP) J R J Non-Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) n [I Title V Operating Permits (OP) i . ~ . . Non-Attainment New Source Review (NANSR) Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0152 Facility Name Speer Gas Plant AIRS 123/9DF7/008 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-410 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3512B, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine,site rated at 1035 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used for propane compression. Natural Gas Consumption Hours of Operation- Requested(mmscf/yr) 67.04 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 5.69 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 7254 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 5.00 5.00 5.00 0.0% VOC 18.19 4.55 18.19 75.0% CO 27.98 1.96 27.98 93.0% SOx 0.02 0.02 0.02 0.0% TSP 0.33 0.33 0.33 0.0% PM10 0.33 0.33 0.33 0.0% PM2.5 0.33 0.33 0.33 0.0% Total HAPs* 0.0 0.0 5.6 83.4% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( lb/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 9395 939 9395 90 . 0% Acetaldehyde 550 275 550 50 . 0% Toluene 536 268 536 50 . 0% Acrolein 338 169 338 50 . 0% Methanol 164 50 . 0% I Benzene * * 85 50 . 0% n- Hexane * * 73 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E Standards (g/hp-hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) source requirements? Is this engine subject to NSPS JJJJ ? NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 8760 hr/yr between points 008 and 009 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCalc literature/tests . Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0152 Facility Name Speer Gas Plant AIRS 123/9DF7/009 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-411 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1)Caterpillar, Model G3512B, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine,site rated at 1035 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used for propane compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 67.04 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 5.69 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 7254 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 5.00 5.00 5.00 0.0% VOC 18.19 4.55 18.19 75.0% CO 27.98 1.96 27.98 93.0% SOx 0.02 0.02 0.02 0.0% TSP 0.33 0.33 0.33 0.0% PM10 0.33 0.33 0.33 0.0% PM2.5 0.33 0.33 0.33 0.0% Total HAPs* 0.0 0.0 5.6 83.4% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 9395 939 9395 90 . 0% Acetaldehyde 550 275 550 50 . 0% Toluene 536 268 536 50 . 0% Acrolein 338 169 338 50 . 0% Methanol * 164 50 . 0% Benzene * * 85 50 . 0% n-Hexane * * 73 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E Standards (g/hp-hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) source requirements? Is this engine subject to NSPS JJJJ ? NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 8760 hr/yr between points 008 and 009 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCaIc literature/tests . Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package U: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 SW 31 4N 65 Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) ../ Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit tt Issuance # Action Control? Required? Remarks 001 Liquid Loading SP300-10 • 19WE0165 CP1 Yes ;'k' rat !noialissuance APEN Required / 002 NG Heater HTR-703 15WE1029.XP XP No Permit Exempt 004 Natural Gas RICE C-601 Yes 19WE0148 Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes «— • 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 res 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 - Natural Gas RICE C-653 — Yes 19WE0156 CP1 Yes _ Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit f AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 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 : SO? NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) J 4 ri .., Non-Attainment New Source Review (NANSR) J Is this stationary source a major source? No If yes, explain what programs and which pollutants here: SO? NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) 8 ■ Non-Attainment New Source Review (NANSR) f 1 Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0152 Facility Name Speer Gas Plant AIRS 123/9DF7/008 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-410 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3512B, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine,site rated at 1035 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used for propane compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 67.04 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 5.69 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 7254 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOx AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM 10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 5.00 5.00 5.00 0.0% VOC 18.19 4.55 18.19 75.0% CO 27.98 1.96 27.98 93.0% SOx 0.02 0.02 0.02 0.0% TSP 0.33 0.33 0.33 0.0% PM 10 0.33 0.33 0.33 0.0% PM2.5 0.33 0.33 0.33 0.0% Total HAPs* 0.0 0.0 5.6 83.4% " *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 9395 939 9395 90 . 0% I Acetaldehyde 550 275 550 50 . 0% Toluene 536 268 536 50 . 0% Acrolein 338 169 338 50 . 0% Methanol 164 50 . 0% Benzene * * 85 50 . 0% n- Hexane * * 73 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E Standards (g/hp- hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area Yes source requirements? Is this engine subject to NSPS JJJJ ? Yes NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 8760 hr/yr between points 008 and 009 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCaIc literature/tests . COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/212019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL _ 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 revious taken from May 2018 tab Previous Permitted Facilit/ total 0.0 0. 0 0. 0 0.0 0. 6 94. 1 0. 0 1. 1 0. 7 0. 0 0. 0 0. 0 0. 0 0. 6 12. 9 0.0 1 1 0.2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" u(_)„ :a1?ce%le' FJalcnew i. , ,rr;,eil: r1 ur�cer facility uortngu►a�ro: I 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " - 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03, 2.51 1 .2 "0-604" 008 19WE0152 Caterpillar G3512B, sn TBD "C-410" Requested combined limit of 8760 hr/yr 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-G51 " Requested combined limit of 17520 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-652" 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G3516C, sn TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013,014,and 015. 014 19WE0157 Caterpillar gg 3516 , sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 "G-772" 015 19WE0157 Caterpillar , sn: TBD _ "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 Hot oil heater, 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 _ 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" _ 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4, 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5, 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 0.0 0.0 0.0 0.0 , 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH . & Total 7777: Syn Minor Permitted Facility Total 7. 4 7. 4 0. 0 1. 8 80. 6 755. 9 99. 2 447 5 219. 0 7, 4 7 42 0. 0 1. 8 80. 6 73.8 9. 8 86.5 23. 6 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 1 7. 4 7. 4 0. 0 1. 8 80. 0 60.9 9.8 85. 4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83.8 Facility is eligible for GP02 because < 90 tpy ;A) Change in Total Permitted VOC emissions 'point and fugitive) 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/12/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lips per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene TOTAL (tPy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr 5 r 46 n ? 129 81 108 59 173 127 21 0 . 5 0 �; 3'rC r,u U 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 18 73 164 16 18 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 41 I 167 375 38 40 5 . 9 011 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 41 167 375 38 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 1G . I 1027 5 34 _ 140 315 32 34 12 .4 014 19WE0157 sn : TBD Caterpillar G3516C , 21259 1054 648 164 1027 5 34 140 315 32 34 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 i 68 93 192 120 161 88 259 1 I 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 .3 30362 14458 145 1446 2892 216872 0 .29 1446 133. 8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3 .4 0 . 0 APEN-Exempt / lnsignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 56.8 4.3 2.5 17.4 12. 9 0.7 1 .5 10.6 110.3 0.9 0.7 0. 6 0. 2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0152 . point008 . CP1 9/12/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane MeOH 224 TMP H2S styrene • TOTAL (MY) ! Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr I 45 46 129 81 108 59 173 127 21 0 . 5 Uua iwiceilea 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 4 376 231 59 367 12 50 113 11 12 1 . 2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 11 12 1 . 2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 11 12 1 . 2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 11 12 1 . 2 008 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 9 37 82 8 9 0 . 9 009 19WE0152 Caterpillar G3512B , sn : TBD 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 4 21 83 188 19 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 21 83 188 19 20 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 16 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 16 17 1 . 9 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 4 192 120 161 88 259 189 31 0 . 7 017 19WE0161 Hot oil heater, 19. 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater. 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 4 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 1518 723 7 72 145 10844 72 6 . 7 020 19WE0164 Plant Flare 108 108 1 22 540 32 0 .4 021 19WE0166 _ Facility fugitive equipment leaks 65 4 67 1 15 743 15 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 5.9 4 2. 2 1 .3 1 .4 4 2.7 0.6 0. 5 4 1 .6 6.3 0. 8 0. 0 0.6 0 . 2 24 . 03 6 19WE0152 . point008 . CP1 9/12/2019 4 CDPHE COLORADO Co Air Pollution Control Division I Department of Pub,4c Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WEO152 Issuance: 1 Date Issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3512B, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB C-410 008 reciprocating internal combustion engine, site rated at 1035 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for propane compression. One (1) Caterpillar, Model G3512B, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB C-411 009 reciprocating internal combustion engine, site rated at 1035 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for propane compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3512B engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: Page 1 of 20 cnE COLORADO CO c Air Pollution Control Division IDepartment of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.qov/cdphe/air/manaqe-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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; (ii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. Points 008 and 009: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. Page 2 of 20 cDP E COLORADO CO If Air Pollution Control Division [ Department of PubIc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NO,t VOC CO C-410 008 849 772 333 Point C-411 009 849 772 333 Point Points 008 and 009 849 772 333 Point Combined (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month, Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons per Year Equipment ID Point Emission Type NO,t VOC CO C-410 008 5.0 4.5 2.0 Point C-411 009 5.0 4.5 2.0 Point Points 008 and 009 5.0 4.5 2.0 Point Combined 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 be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) Page 3 of 20 CDPHE COLORADO CO Air Pollution Control Division I Department of Public Heath&Environment Dedicated to protecting and improving the health and environment of the people of Colorado from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit(Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Control Device Point Controlled ID C-410 008 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs C-411 009 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs PROCESS LIMITATIONS AND RECORDS 10. 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 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID C-410 008 Consumption of natural gas as a fuel 67.04 5.69 MMscf/yr MMscf/month C-411 009 Consumption of natural gas as a fuel 67.04 5.69 MMscf/yr MMscf/month Points 008 and 009 Consumption of natural gas as a fuel 67.04 5.69 Combined MMscf/yr MMscf/month Page 4 of 20 A CD E iCOLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer-provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 11. The permit number and AIRS ID point number(e.g. 123/9DF7/x(x)shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)(State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1 &4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst is required. OPERATING & MAINTENANCE REQUIREMENTS 15. 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 No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 008: A source initial compliance test shall be conducted on emissions point 008 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and Page 5 of 20 A cDPHE ICOLORADO CO I Air Pollution Control Division I Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde 17. Point 009: A source initial compliance test shall be conducted on emissions point 009 to measure the emission rate(s) for the pollutants listed below in order to demonstrate • compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Periodic Testing Requirements 18. Points 008 and 009: This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice(APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or Page 6 of 20 A` tD E COLORADO CO Air Pollution Control Division Department of Pub c Health&Environment ,Dedicated to protecting and improving the health and environment of the people of Colorado For volatile organic compounds(VOC)and nitrogen oxides sources(NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five(5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 20. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ED Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 Page 7 of 20 A CDPHE COLORADO CO { Air Pollution Control Division Department o;Pubtc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado AMINE 019 13.18 FL-991 020 38.76 21. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Maximum Number Combined Hours of Engines in Facility Equipment of Operation Per Operation at Any IDs AIRS Points Year Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 22. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 23. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section IIl.B5.) 24. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to - otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D,V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 Page 8 of 20 ,^ CD PE ICOLORADO CO # .Air Pollution Control Division , Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL 991 020 ` Plant flare VOC 100 16.3 HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 Page 9 of 20 CDPHE COLORADO CO Air Pollution Control Division Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 25. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 26. If this permit specifically states that final authorization has been granted,.then= he 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 No. 3, Part B Section I II.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. 27. 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. 28. 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. 29. 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. Page 10 of 20 c £ ; COLORADO CO I Air Pollution Control Division " 1 Department of Polak Health&Ermroarnent Dedicated to protecting and improving the health and environment of the people of Colorado 30. 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. 31. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date ' Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 11 of 20 A CDPHE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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.qovipacifidcdphe/aqcc-reqs 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. Uncontrolled Are the Controlled Emission AIRS Pollutant CAS# Rate emissions Emission Point (Ib/yr) reportable? Rate(Ib/yr) Formaldehyde 50000 9,395 Yes 939 Acetaldehyde 75070 550 Yes 275 Toluene 108883 536 Yes 268 008 Acrolein 107028 338 Yes 169 Methanol 67561 164 No 82 Benzene 71432 85 No 43 n-Hexane 110543 73 No 37 Formaldehyde 50000 9,395 Yes 939 Acetaldehyde 75070 550 Yes 275 Toluene 108883 536 Yes 268 009 Acrolein 107028 338 Yes 169 Methanol 67561 164 No 82 Benzene 71432 85 No 43 n-Hexane 110543 73 No 37 Page 12 of 20 A CDPHE { COLORADO '��CO Air Pollution Control Division " i Department of Pubhc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Are the Controlled AIRS Pollutant CAS# Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (Ib/yr) Formaldehyde 50000 9,395 Yes 939 Acetaldehyde 75070 550 Yes 275 008 Toluene 108883 536 Yes 268 and 009 Acrolein 107028 338 Yes 169 (com- Methanol 67561 164 No 82 bined) Benzene 71432 85 No 43 n-Hexane 110543 73 No 37 5) The emission levels contained in this permit are based on the following emission factors: Points 008 and 009 (each): Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.1520 0.50 0.1520 0.50 CO 0.8510 2.80 0.0596 0.20 VOC 0.5531 1.82 0.1383 0.46 50000 Formaldehyde 0.1428 0.47 0.0143 0.05 75070 Acetaldehyde 0.0084 0.03 0.0042 0.01 108883 Toluene 0.0082` 0.03 0.0041 0.01 107028 Acrolein 0.0051 0.02 0.0026 0.01 67561 Methanol 0.0025 0.008 0.0013 0.004 71432 Benzene 0.0013 0.004 0.0007 0.002 110543 n-Hexane 0.0011 0.004 0.0006 0.002 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7254 Btu/hp-hr,a site- rated horsepower value of 1035, and a fuel heat value of 981 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer No control. CO Manufacturer Applicant requested. VOC Manufacturer; sum of Applicant requested. NMNEHC +HCHO 50000 Formaldehyde Manufacturer Applicant requested. 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 108883 Toluene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas Page 13 of 20 CDPHE COLORADO CO i Air Pollution Control Division - I Department of Public Health$Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS Pollutant Uncontrolled EFSource Controlled EF Source 71432 Benzene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). 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 on the EPA website at: j://wA ww.epa.qov/ttn/atw/area/fr1.8 i a08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,2008 Federal Register posting -effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines ≤ 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8.A copy of the complete subpart is available on the EPA website at: http://www.epa.00v/ttniatw/area/fr18ia08.Ddf Additional information regarding area source standards can be found on the EPA website at: hftp://www.epagovittn/atwiarea/arearules.html 9) This facility is classified as follows: Applicable. Status Requirement Operating Permit Synthetic Minor Source of: VOC,GO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: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 Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 14 of 20 4 c��E COLORADO I CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1-63.599 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 11) A self-certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification Page 15 of 20 A CDPHE COLORADO � 1 CO � j Air Pollution Control Division E Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period."Permanent"is defined as in the same service for more than 90 operating days in any 12 month period.The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this A0S are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement,the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable Page 16 of 20 A CDPHHE ' COLORADO CO Air Pollution Control Division " ! Department of Pubbc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.coloradogov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing_, Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's web site at: www.colorado.gov/cdphe/portable-analvzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation Page 17 of 20 CDPHE COLORADO CO Air Pollution Control Division Department of Pubhc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B§ ll.DD.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply ReasonatlyAvailable Control Technology(RACT)for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone, RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the,Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC.'The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Page 18 of 20 4 CDPHE COLORADO CO .; Air Pollution Control Division Department of Public Heath&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1,2008 2.0 4.0 1.0 100<Hp<500 January 1,2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3:3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation Page 19 of 20 A c��E COLORADO CO Is Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site;an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 20 of 20 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 SW 31 4N 65 Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) Q Ozone (NOx & vOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRS Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 001 Liquid Loading 5P300-10 Ye 19WE0165 Yes Permit hRiatIssuance 002 NG Heater HTR-703 Nc: 15WE1029.XP No APEN Required / Permit Exempt 004 Natural Gas RICE C-601 Yes 19WE0148 Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Y'es 008 Natural Gas RICE C-410 Yes 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit Initial - 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance - 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 (es 019 Amine Sweetening Unit AMINE Yes 19WE0163 `(es .»0 Process Flare FL-991 Yes 19WE0164 Yes � ...1 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than S tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enccosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 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: 502 NOx # CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ✓ ✓ .1Non-Attainment New Source Review (NANSR) ✓ Is this stationary source a major source? No If yes, explain what programs and which pollutants here: ,c )2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) 9 , ■ ■ Non-Attainment New Source Review (NANSR) Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0154 Facility Name Speer Gas Plant AIRS 123/9DF7/010 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-651 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1)Caterpillar, Model G3608, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine, site rated at 2500 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used for residue gas compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 152.99 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 12.99 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 6853 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 7.24 7.24 7.24 0.0% VOC 10.62 2.66 10.62 75.0% CO 62.28 4.36 62.28 93.0% SOx 0.04 0.04 0.04 0.0% TSP 0.75 0.75 0.75 0.0% PM 10 0.75 0.75 0.75 0.0% PM2.5 0.75 0.75 0.75 0.0% Total HAPs* 0.0 0.0 6.0 75.9% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 7725 772 7725 90 . 0% Acetaldehyde 1255 627 1255 50 . 0% Toluene 1223 612 1223 50 . 0% Acrolein 771 386 771 50 . 0% Methanol 375 188 375 50 . 0% Benzene 195 50 . 0% n- Hexane * * 167 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E . E Standards (g/hp-hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements ) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) source requirements? Is this engine subject to NSPS JJJJ ? NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 17520 hr/yr between points 010/011 /012 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCalc literature/tests . Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0154 Facility Name Speer Gas Plant AIRS 123/9DF7/011 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-652 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3608, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine,site rated at 2500 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used for residue gas compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 152.99 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 12.99 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 6853 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM 10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 7.24 7.24 7.24 0.0% VOC 10.62 2.66 10.62 75.0% CO 62.28 4.36 62.28 93.0% SOx 0.04 0.04 0.04 0.0% TSP 0.75 0.75 0.75 0.0% PM 10 0.75 0.75 0.75 0.0% PM2.5 0.75 0.75 0.75 0.0% Total HAPs* 0.0 0.0 6.0 75.9% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calcufated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 7725 772 7725 90 . 0% Acetaldehyde 1255 627 1255 50 . 0% Toluene 1223 612 1223 50 . 0% Acrolein 771 386 771 50 . 0% Methanol 375 188 375 50 . 0% Benzene 195 50 . 0% n- Hexane * * 167 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a(n) Area Source Reg 7 XVII . E Standards (g/hp-hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) source requirements? Is this engine subject to NSPS JJJJ ? NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 17520 hr/yr between points 010/011 /012 . Exact engine information is not yet available ; I assume a manufacture date of 1 / 1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCaIc literature/tests . Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0154 Facility Name Speer Gas Plant AIRS 123/9DF7/012 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID C-653 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3608, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine, site rated at 2500 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used for residue gas compression. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 152.99 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 12.99 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 6853 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Nabual Gas No Control TSP AP-42;Table 3.2-2(7/2000);Nabaral Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Nabiral Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 7.24 7.24 7.24 0.0% VOC 10.62 2.66 10.62 75.0% CO 62.28 4.36 62.28 93.0% SOx 0.04 0.04 0.04 0.0% TSP 0.75 0.75 0.75 0.0% PM10 0.75 0.75 0.75 0.0% PM2.5 0.75 0.75 0.75 0.0% Total HAPs* 0.0 0.0 6.0 75.9% "Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 7725 772 7725 90 . 0% Acetaldehyde 1255 627 1255 50 . 0% Toluene 1223 612 1223 50 . 0% Acrolein 771 386 771 50 . 0% Methanol 375 188 375 50 . 0% Benzene 195 50 . 0% n- Hexane * * 167 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Standards (g/hp-hr) Reg 7 XVI . B (Ozone NAA Yes requirements) applies? MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area Yes source requirements? Is this engine subject to NSPS JJJJ ? Yes NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 17520 hr/yr between points 010/011 /012 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCalc literature/tests . COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Enerqy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 , 0. 1 3.6 0.7 0.2 0.2 , 0.0 2. 1 . 13.2 0.0 3.6 i 0.2 !evi : ken from May 2018 tab Previous Permitted Facility total 0.0 0. 0 0 0 0.0 0. 6 94. 1 0.0 1. 1 0. 7 0. 0 0. 0 0. 0 0. 0 0. 6 12. 9 0.0 1 1 0.2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5, 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" r.': ' ) cancelled F..ia t "srriJc lied uncei new facility configuration 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " 005 19WE0149 Caterpillar G3516J, sn. TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5- 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" "C-410" Requested combined limit of 8760 hr/yr 008 19WE0152 Caterpillar G3512B, sn: TBD 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G3516C , sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013,014,and 015. 014 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 "G-772" 015 19WE0157 Caterpillar G3516C, sn: TBD "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 Hot oil heater, 19.33 MMBtu/hr 0.6 0.6, 0. 1 2.1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8, 0.8 0. 1 , 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6, 0.6 1 .4 5.0_ 289.2 42.5 133.8 0.6 0.6 , 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" APFN-Exempt / Insignificants 0.0 0.0 0.0 _ 0.0 o.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B. T. n-hex, HCHO. McOH, & Total 7777: Syn Minor Permitted Facility Total 7. 4 7.4 0. 0 1. 8 80. 6 755. 9 99. 2 447. 5 219. 0 7. 4 7. 42 0.0 1. 8 80. 6 73. 8 , 9. 8 4 86.5 23. 6 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 7. 4 7. 4 0. 0 1. 8 80. 0 60. 9 9. 8 85. 4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive: 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 1 of 3 Printed 9/12/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene , TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 45 46 62 129 81 108 5 173 127 0 . 5 oo 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD . 11460 753 463 117 734 4 25 100 225 23 24 7. 0 006 19WE0150 Caterpillar G3516J , sn : TBD i 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 18 73 164 16 18 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 r 41 167 375 38 40 5 . 9 011 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 41 167 375 38 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 140 315 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/h, 77 67 68 93 120 161 88 259 31 0. 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 _ 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 30362 14458 145 1446 2892 216872 0 .29 1446 133.8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 . 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3 .4 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy_) 56. 8 4.3 2.5 17.4 12.9 0.7 1 .5 10.6 110.3 0.9 0.7 0.6 0.2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 2 19WE0154 . point010 . CP1 9/12/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane MeOH 224 TMP H2S Styrene TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19VVE0165 Truck loadout of condensate .. 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 45 46 129 81 108 59 173 127 21 0 . 5 002 :. , 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 008 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 1 9 37 82 8 9 0 . 9 009 19WE0152 Caterpillar G3512B , sn : TBD 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 71 83 188 19 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 19 20 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17. 70 158 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 17 1 . 9 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/h, 77 67 68 93 192 120 88 259 189 31 0 .7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 163 352 58 1 .3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 ir 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 1518 723 72 145 10844 0 .01 72 6 .7 020 19WE0164 Plant Flare 108 108 22 540 32 1 II H 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 743 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 .0 0 .0 0 .0 0 .0 TOTAL (tpy) 5.9 2. 2 1 .3 1 .4 2.7 0.6 0. 5 1 .6 6.3 0.8 0.0 0.6 0. 2 24 . 03 3 19WE0154 . point010 . CP1 9/12/2019 4 CDPHE COLORADO CO ri Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE01 54 Issuance: 1 Date Issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3608, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB C-651 010 reciprocating internal combustion engine, site rated at 2500 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for residue gas compression. O5: (1) Caterpillar, Model G3608, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB C-652 011 reprocating internal combustion engine, site rated at 200 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for residue gas compression. One (1) Caterpillar, Model G3608, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB C-653 012 reciprocating internal combustion engine, site rated at 2500 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used for residue gas compression. Page 1 of 20 CDPHE ' COLORADO . CO ! Air Pollution Control Division ; 1 Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3608 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. • 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 sea), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.00v/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 No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty.days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II I.G.2). 3. This permit shall expire if the owner or operator o 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; (ii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. Points 010, 011 and 012 (each): The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number Page 2 of 20 4 CDPHHE COLORADO Air Pollution Control Division Department of Pubbc Health&Emsiroerient Dedicated to protecting and improving the health and environment of the people of Colorado This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, TILE.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NO. VOC CO C-651 010 1,230 451 741 =Point C-652 011 1,230 451 741 Point C-653 012 1,230 451 741 Point Points 010,011 and 012 2,460 902 1,482 Point Combined (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. ''''The facility-wide emission limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO. VOC CO C-651 010 7.2 2.7 4.4 Point C-652 011 7.2 2.7 4.4 Point C-653 012 7.2 2.7 4.4 Point Points 010, 011 and 012 14.5 5.3 8.7 Point Combined 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 be less than 8.0 tpy. Page 3 of 20 * CDPHE COLORADO CO s I Air Pollution Control Division IDepartment of Pubte Health&£nvtroament Dedicated to protecting and improving the health and environment of the people of Colorado Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emission limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment,which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID C-651 010 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs C-652 011 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs C-653 012 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs PROCESS LIMITATIONS AND RECORDS 10. 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 3, Part B, II.A.4) Page 4 of 20 4, C E COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID C-651 010 Consumption of natural gas as a fuel 152.99 12.99 MMscf/yr MMscf/month C-652 011 Consumption of natural gas as a fuel 152.99 12.99 MMscf/yr MMscf/month C-653 012 Consumption of natural gas as a fuel 152.99 12.99 MMscf/yr MMscf/month Points 010, 011 and 012 Consumption of natural gas as a fuel 305.97 25.99 Combined MMscf/yr MMscf/month Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer-provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 11. The permit number and AIRS ID point number(e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst is required. Page 5 of 20 44, CDPHE COLORADO CO Z [ Air Pollution Control Division I Department of Pu f c Health&Emma mant Dedicated to protecting and improving the health and environment of the people of Colorado OPERATING & MAINTENANCE REQUIREMENTS 15. 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) &M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 010: A source initial compliance test shall be conducted on emissions point 010 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section lll.G3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde . 17. Point 011: A source initial compliance test shall be conducted on emissions point 011 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde 18. Point 012: A source initial compliance test shall be conducted on emissions point 012 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance Page 6 of 20 4 CDDP E COLORADO CO i Air Pollution Control Division Department of Pub13c Health&Enuiroi went Dedicated to protecting and improving the health and environ rnent of the people of Colorado with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Periodic Testing Requirements 19. Points 010, 011, and 012: This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 3c? whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources(NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five(5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Page 7 of 20 cnE 1COLORADO CO Air Pollution Control Division IDepartment of Public Health C Environment Dedicated to protecting and improving the health and environment of the people of Colorado d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 21. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) 0=601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 22. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Maximum Number Combined Hours of Engines in Facility Equipment of Operation Per Operation at Any IDs AIRS Points Year Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 23. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) Page 8 of 20 4 c��E ; COLORADO CO i ! Air Pollution Control Division 9 � " 1 Department of Public Health Er Env,rommment Dedicated to protecting and improving the health and environment of the people of Colorado 24. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 25. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J` VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 9 of 20 A CDP E COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant ID Point Description Threshold Current Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO. 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hat oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 26. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 27. 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 No. 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-certificaion of all points has been reviewed and approved by the Page 10 of 20 * DP COLORADO CO Aix Pollution Control Division y ,. I Department of Public.Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 28. 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. 29. 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. 30. 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 ao initio. This permit:may be revoked at any time priori() 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. 31. 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. 32. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 11 of 20 CDPHE [ COLORADO CO sr I Air Pollution Control Division € Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section W.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.ciovipacifidcdphe/aqcc-reqs 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 i the source(s)operate at the permitted limitations. Uncontrolled Are the Controlled AIRS Pollutant CAS# Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (Ib/yr) Formaldehyde 50000 7,725 Yes 772 Acetaldehyde 75070 1,255 Yes 627 Toluene 108883 1,223 Yes 612 010 Acrolein 107028 771 Yes 386 Methanol 67561 375 Yes 188 Benzene 71432 195 No 98 n-Hexane 110543 167 No 83 Formaldehyde 50000 7,725 Yes 772 Acetaldehyde 75070 1,255 Yes 627 Toluene 108883 1,223 Yes 612 011 Acrolein 107028 771 Yes 386 Methanol 67561 375 Yes 188 Benzene 71432 195 No 98 n-Hexane 110543 167 No 83 Formaldehyde 50000 7,725 Yes 772 012 Acetaldehyde 75070 1,255 Yes 627 Page 12 of 20 4 CDP COLORADO CO P Air Pollution Control Division '" l Department of Pubtr Health S Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Are the Controlled Emission AIRS Pollutant CAS# Rate emissions Emission Point (Ib/yr) reportable? Rate(Ib/yr) Toluene 108883 1,223 Yes 612 Acrolein 107028 771 Yes 386 Methanol 67561 375 Yes 188 Benzene 71432 195 No 98 n-Hexane 110543 167 No 83 Formaldehyde 50000 15,450 1,545 Acetaldehyde 75070 2,509 1,255 010 and Toluene 108883 2,446 1,223 011 and 012 Acrolein 107028 1,543 771 (com- Methanol 67561 750 375 biped) Benzene 71432 390 195 n-Hexane 110543 333 167 5) The emission levels contained in this permit are based on the following emission factors: Points 010,011,and 012(each): Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.0965 0.30 0.0965 0.30 CO 0.8300 2.58 0.0581 0.18 VOC 0.1415 0.44 0.0354 0.11 50000 Formaldehyde 0.0515 0.16 0.0051 0.02 75070 Acetaldehyde 0.0084 0.03 0.0042 0.01 108883 Toluene 0.0082 0.03 0.0041 0.01 107028 Acrolein 0.0051 0.02 0.0026 0.01 67561 Methanol 0.0025 0.01 0.0013 0.004 71432 Benzene 0.0013 0.004 0.0007 0.002 110543 n-Hexane 0.0011 0.003 0.0006 0.002 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6853 Btu/hp-hr,a site- rated horsepower value of 2500, and a fuel heat value of 981 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer No control. CO Manufacturer Applicant requested. VOC Manufacturer; sum of Applicant requested. NMNEHC + HCHO 50000 Formaldehyde Manufacturer Applicant requested. Page 13 of 20 CDPH COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS Pollutant Uncontrolled EFSource Controlled EF Source 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 108883 Toluene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 71432 Benzene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 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 Divisio n at (303)-692-3150. 7) -This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This ride has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: littp://www.epa.povittn/atwiareaiftl,8ia08.pdf 8) This engine is subject to 40 CFR; Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air-Pollutants for Reciprocating Internal Combustion Engines. (See January 18,2008 Federal Register posting -effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been ncorporated into Colorado Air Quality Control Commission's Regulation No. 8.A copy of the complete subpart is-available on the EPA website at: http://www.epapovittnfatw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.00v/ttn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs(total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: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/ Page 14 of 20 CDPHE ; COLORADO CO -- € Air Pollution Control Division I Department of PubIc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 11) A self-certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.aov/pacific/cdphe/air-permit-self-certification Page 15 of 20 A cDPHe COLORADO CO CO ,,. Air Pollution Control Division I Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS,and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into„this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period."Permanent"is defined as in the same service for more than 90 operating days in any 12 month period.The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic,monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement,the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable Page 16 of 20 * CDPHE COLORADO t CO Air Pollution Control Division C I Department of Publ#c Health£r Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.coloradogov/cdphe/air/AOS. This submittal shall be accompanied by a certification from-the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete"_ This AOS cannot be used for-permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7)calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's web site at: www.colorado.gov/cdphe/portable-an alyzer-mon itoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation Page 17 of 20 CDPHE '.COLORADO ,41 CO If Air Pollution Control Division I Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.31 Reasonably Available Control Technology(RACT): Reg 3, Part B§ II!,;D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology(RACT)for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and N0X are precursors for ozone: RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements:Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Page 18 of 20 CDPHE COLORADO CO I" Air Pollution Control Division '" Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVILE—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that"it achieves the emission standards required in the table below: Construction � .or Emission Standards in G/hp-hr Max Engine HP Relocation date NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1,2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500<Hp - July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. P3 r III' 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation Page 19 of 20 CO i Air Pollution Control Division " i Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado No. 6, Part B, § l.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced corstructionpermit review. The AOS cannot be`used for additional new emission points for any site,an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 20 of 20 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy true( Package #: 393231 ':,b� „, r . eaakin•- > nt*waReceived Date: 2/11/2019 of °a._ ` eeea°`'°'' s�q' o '5 Review Start Date: 3/12/2019 <li ' g `�� i Section 01 - Facility Information Company Name: Aka Lrnergy Group, LLC Quadrant Section Township Range County AIRS ID: 123 :, ,y Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ill Carbon Monoxide (CO) ■ Particulate Matter (PM) © Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks Liquid Loading 5P300-10 Ye_: 19WE0165 Permit inttidf Issuance 002 NG Heater HTR-703 No 1SWE1029,XF No APEN Required / Permit Exempt 004 Natural Gas RICE C-601 Yes 19WE0148 Yes - 005 Natural Gas RICE C-601. Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 00.:` Natural Gas RICE C-604 Yes 19WE01S1 Yes 008 Natural Gas RICE C-410 Yes - 19WE0152 Yes —^ DC ' Natural Gas RICE C-411 — tis 19WE0153 Yes 01 `: Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 1.9WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes , Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section OS - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 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? ,(D Is this stationary source a synthetic minor? Y If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) .../ f/1 D Non-Attainment New Source Review (NANSR) J Is this stationary source a major source? N If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits ( DP) ❑ . Non-Attainment New Source Review (NANSR) , Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0157 Facility Name Speer Gas Plant AIRS 123/9DF7/013 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID G-771 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine, site rated at 2077 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used to drive a generator set. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 128.51 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 10.91 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/set) 981 BSCF(Btu/hp-hr) 6929 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 10.03 10.03 10.03 0.0% VOC 21.86 5.47 21.86 75.0% CO 46.13 3.23 46.13 93.0% SOx 0.04 0.04 0.04 0.0% TSP 0.63 0.63 0.63 0.0% PM 10 0.63 0.63 0.63 0.0% PM2.5 0.63 0.63 0.63 0.0% Total HAPs* 0.0 0.0 12.4 84.3% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( lb/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested i PTE Efficiency Formaldehyde 21259 2126 21259 90 . 0% Acetaldehyde 1054 527 1054 50 . 0% Toluene 1027 514 1027 50 . 0% . Acrolein 648 324 648 50 . 0% Methanol 315 158 315 50 . 0% Benzene 164 50 . 0% n- Hexane * * 140 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minims Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVI I . E Standards (g/hp- hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements; applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ (area source) Yes source requirements? Is this engine subject to NSPS JJJJ ? Yes NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 17520 hr/yr between points 013/014/015 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCalc literature/tests . Applicant derated the output by 0 . 955 deration factor per manufacturer's data . Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0157 Facility Name Speer Gas Plant AIRS 123/9DF7/014 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID G-772 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine, site rated at 2077 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used to drive a generator set. Natural Gas Consumption Hours of Operation Requested (mmscf/yr) 128.51 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 10.91 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF(Btu/hp-hr) 6929 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM 10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 10.03 10.03 10.03 0.0% VOC 21.86 5.47 21.86 75.0% CO 46.13 3.23 46.13 93.0% SOx 0.04 0.04 0.04 0.0% TSP 0.63 0.63 0.63 0.0% PM 10 0.63 0.63 0.63 0.0% PM2.5 0.63 0.63 0.63 0.0% Total HAPs* 0.0 0.0 12.4 84.3% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 21259 2126 21259 90 . 0% Acetaldehyde 1054 527 1054 50 . 0% Toluene 1027 514 1027 50 . 0% Acrolein 648 324 648 50 . 0% Methanol 315 158 315 50 . 0% Benzene 164 50 . 0% n- Hexane * * 140 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E Standards (g/hp-hr) NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Reg 7 XVI . B (Ozone NAA Yes requirements) applies? Is this engine subject to MACT ZZZZ area MACT ZZZZ ( area source) source requirements? Is this engine subject to NSPS JJJJ ? NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 17520 hr/yr between points 013/014/015 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCaIc literature/tests . Applicant derated the output by 0 . 955 deration factor per manufacturer's data . Summary of Preliminary Analysis - NG RICE Company Name Aka Energy Group, LLC Permit No. 19WE0157 Facility Name Speer Gas Plant AIRS 123/9DF7/015 Facility Location SW Sec 31 T4N R65W Review Date 03/26/2019 Facility Equipment ID G-773 Permit Engineer Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One(1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas-fired,turbo-charged,4SLB reciprocating internal combustion engine, site rated at 2077 horsepower.This engine shall be equipped with an oxidation catalyst and air- fuel ratio control.This emission unit is used to drive a generator set. Natural Gas Consumption Hours of Operation Requested(mmscf/yr) 128.51 PTE Calculated at(hpy) 8760 Requested(mmscf/m) 10.91 Permit limits calculated at(hpy) 8760 Fuel Heat Value(btu/scf) 981 BSCF (Btu/hp-hr) 6929 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer No control. VOC Applicant requested. Manufacturer;sum of NMNEHC+HCHO CO Manufacturer Applicant requested. Formaldehyde Manufacturer Applicant requested. SOX AP-42;Table 3.2-2(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM 10 AP-42;Table 3.2-2(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-2(7/2000);Natural Gas No Control Other Pollutants AP-42;Table 3.2-2(7/2000);Natural Gas Applicant Point Summary of Criteria Emissions(tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 10.03 10.03 10.03 0.0% VOC 21.86 5.47 21.86 75.0% CO 46.13 3.23 46.13 93.0% SOx 0.04 0.04 0.04 0.0% TSP 0.63 0.63 0.63 0.0% PM 10 0.63 0.63 0.63 0.0% PM2.5 0.63 0.63 0.63 0.0% Total HAPs* 0.0 0.0 12.4 84.3% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants ( Ib/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 21259 2126 21259 90 . 0% Acetaldehyde 1054 527 1054 50 . 0% Toluene 1027 514 1027 50 . 0% Acrolein 648 324 648 50 . 0% Methanol 315 158 315 50 . 0% Benzene 164 50 . 0% n- Hexane * 140 50 . 0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts No NAAQS violations expected (see details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SLB over 500 HP located at a (n) Area Source Reg 7 XVII . E NOx : 1 . 0 CO : 2 . 0 VOC : 0 . 7 Standards (g/hp-hr) Reg 7 XVI . B (Ozone NAA Yes requirements) applies? MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area Yes source requirements? Is this engine subject to NSPS JJJJ ? Yes NSPS JJJJ Note : JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6 . Comments/Notes Applicant requested a federally enforceable limit on operation of 17520 hr/yr between points 013/014/015 . Exact engine information is not yet available ; I assume a manufacture date of 1 /1 /2019 for regulatory applicability purposes . Applicant conservatively applied the higher HAP emission factor between AP-42 and GRI HAPCatc literature/tests . Applicant derated the output by 0 . 955 deration factor per manufacturer's data . COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 13.2 0.0 - 3.6 0.2 Previous taken from May 2018 tab Previous Permitted Facility total 0.0 0.0 0.0 0.0 0. 6 94. 1 0. 0 1 . 1 0. 7 0.0 0.0 0.0 i 0.0 0. 6 12.9 0.0 1 . 1 i 0.2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0.16 2.51 0.5 "HTR-703" ., . cancelled :are . ancelled under new facility configuration 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12.1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601" 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12.1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0, 0.5 0.5, 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12.1 35.9 7.0_ 0.5 0.5 0.0 , 6.7 3.03 2.51 1 .2 "C-604" 008 19WE0152 Caterpillar G3512B, sn: TBD "C-410" Requested combined limit of 8760 hr/yr 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411" , "C-651" Requested combined limit of 17520 hr/yr 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 012 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 "C-653" 013 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771" Requested combined limit of 17520 hr/yr between points 013,014,and 015. 014 19WE0157 Caterpillar G3516C, sn: TBD 015 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 GG--773 772 016 19WE0160 Heater for dehy regen, 10.4 MMBtult I 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1.1 0.25 1 .87 0.7 "H-310" 017 19WE0161 Hot oil heater, 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 , 0.5 3.5 1 .3� 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 , 0. 1 2.7_ 0.6 4.4 1 .6 0.8 0.8 0.1 2.7 0.57 , 4.36 1 .6 "H-570" _ 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7.1 _ 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" II APEN-Exempt / Insignificants 0.0 0.0 0.0 0.0 fr 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSO and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7.4 7. 4 0.0 1. 8 80 6 755.9 99.2 447.5 219 0 7 4 7 42 0.0 1. 8 80 6 73. 8 9.8 86.5 23.6 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 7.4 7 4 0.0 1. 8 80.0 60.9 9.8 85.4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 1 of 3 Printed 9/12/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled ( lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene . 3-b""M TOTAL (tpy) IPreviousFAC1L1TYTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 270 0. 2 002 15WE1029. XP Hot oil heater, 6. 96 MMBtu/hr 81 108 59 173 21 0. 5 e._ 004 19WE0148 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 25 100 225 23 24 7. 0 _ 005 19WE0149 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 25 100 225 23 24 7. 0 006 19WE0150 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 25 100 225 23 24 7. 0 007 19WE0151 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 25 100 225 23 24 7. 0 008 19WE0152 Caterpillar G3512B, sn: TBD 9395 550 338 85 536 18 73 164 16 18 5. 6 009 19WE0152 Caterpillar G3512B. sn: TBD 0. 0 010 19WE0154 Caterpillar G3608 , sn: TBD 7725 I 1255 771 195 1223 41 167 375 i 38 40 5. 9 011 19WE0154 Caterpillar G3608, sn : TBD 7725 1255 771 195 1223 41 167 375 38 40 5. 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C, sn: TBD 21259 1054 648 164 1027 - 34 140 315 32 34 12.4 014 19WE0157 Caterpillar G3516C, sn: TBD 21259 1054 648 164 1027 34 140 315 32 34 12.4 015 19WE0157 i Caterpillar G3516C. sn: TBD _ 016 19WE0160 Heater for dehy regen, 10.4 MMBtu/hr 77 67 68 93 120 161 88 259 189 31 0. 7 017 19WE0161 Hot oil heater. 19. 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater. 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening, 60 MMscfd 43. 3 30362 14458 145 1446 2892 216872 0. 29 1446 133. 8 020 19WE0164 Plant Flare _ 2161 2161 22 432 10805 648 22 8. 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3.4 0. 0 APEN-Exempt / Insignificants 0. 0 0. 0 0. 0 0. 0 TOTAL (tpy) 56.8 4.3 2.5 17.4 12.9 0.7 1 .5 10.6 110.3 0.9 0.7 0.6 0.2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 2 1239DF7 9/ 12/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls ( lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S styrene ;-,,,,,,,... TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 270 0. 2 002 15WE1029.XP Hot oil heater, 6. 96 MMBtu/hr 108 59 173 21 0. 5 oanr'ellec4 _larf 004 19WE0148 Caterpillar G3516J , sn: TBD 1146 376 231 59 367 12 50 113 11 12 1 . 2 005 19WE0149 Caterpillar G3516J , sn: TBD 1146 376 231 59 367 _ 12 50 113 11 12 1 . 2 006 19WE0150 Caterpillar G3516J , sn: TBD 1146 376 231 59 367 ,1 12 50 113 11 i 12 1 .2 007 19WE0151 Caterpillar G3516J , sn: TBD i 1146 376 231 59 367 12 50 113 11 12 1 . 2 008 19WE0152 Caterpillar G3512B, sn: TBD 939 275 169 43 268 9 37 82 8 9 0. 9 009 19WE0152 Caterpillar G3512B, sn: TBD 010 19WE0154 Caterpillar G3608, sn : TBD 772 627 386 98 612 21 83 188 19 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 21 83 188 19 20 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C, sn : TBD 2126 527 324 82 514 17 70 158 16 17 1 . 9 014 19WE0157 Caterpillar G3516C, sn : TBD 2126 527 324 82 514 n 17 70 158 16 17 1 . 9 015 19WE0157 Caterpillar G3516C, sn: TBD 016 19WE0160 Heater for dehy regen, 10.4 MMBtu/hr 77 67 68 93 192 120 161 88 259 189 31 0. 7 017 19WE0161 Hot oil heater. 19. 33 MMBtu/hr 143 125 127 _ 172 358 _ 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening, 60 MMscfd 43. 3 1518 723 7 72 145 10844 72 6. 7 020 19WE0164 Plant Flare 108 108 1 i 22 540 32 1 0.4 021 19WE0166 Facility fugitive equipment leaks 65 67 113 743 0. 5 0. 0 APEN-Exempt / Insignificants 0. 0 0. 0 0. 0 0. 0 TOTAL (tpy; 5.9 2.2 1 .3 1 .4 2.7 0.6 0.5 1 .6 6.3 0.8 0.0 0.6 0.2 24. 03 A 3 1239DF7 9/ 12/2019 A CDPHE COLORADO CO I I Air Pollution Control Division • I Department of Pubic Heath&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE01 57 Issuance: 1 Date Issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Description Equipment ID Point One (1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SL6. G-771 013 reciprocating internal combustion engine, site rated at 2077 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used to drive a generator set. One (1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB G-772 014 reciprocating internal combustion engine, site rated at 2077 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used to drive a generator set. One (1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas-fired, turbo-charged, 4SLB G-773 015 reciprocating internal combustion engine, site rated at 2077 horsepower. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used to drive a generator set. Page 1 of 20 ,A c�jE ! COLORADO co , ₹ Air Pollution Control Division I Department of Publtc Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516C engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manaqe-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty,days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. Points 013, 014 and 015 (each): The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number Page 2 of 20 * CDPHE COLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Month Emission Type Equipment ID Point NO. VOC CO G-771 013 1,703 928 548 Point G-772 014 1,703 928 548 Point G-773 015 1,703 928 548 Point Points 013, 014 and 015 3407 1857 1097 Point Combined (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. The facility-wide emission limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO. VOC CO G-771 013 10.0 5.5 3.2 Point G-772 014 10.0 5.5 3.2 Point G-773 015 10.0 5.5 3.2 Point Points 013, 014 and 015 20.1 10.9 6.5 Point Combined 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 be less than 8.0 tpy. Page 3 of 20 CDPHE ICOLORADO CO Air Pollution Control Division Department of Pubhc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emission limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment,which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID G-771 013 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs G-772 014 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs G-773 015 Oxidation catalyst and air/fuel ratio controller VOC, CO, HAPs PROCESS LIMITATIONS AND RECORDS 10. 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 3, Part B, II.A.4) Page 4 of 20 cje COLORADO co Air Pollution Control Division Beoartment of Public Health a Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID G-771 013 Consumption of natural gas as a fuel 128.51 10.91 MMscf/yr MMscf/month G-772 014 Consumption of natural gas as a fuel 128.51 10.91 MMscf/yr MMscf/month G-773 015 Consumption of natural gas as a fuel 128.51 10.91 MMscf/yr MMscf/month Points 013, 014 and 015 Consumption of natural gas as a fuel 257.02 21.83 Combined MMscf/yr MMscf/month Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility-wide fuel meter attributed to fuel consumption rating and hours of operation; or mall fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 11. The permit number and AIRS ID point number(e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent(20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. &4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst is required. Page 5 of 20 * GDPHE ICOLORADO CO Air Pollution Control Division E Department of Pubh c Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado OPERATING & MAINTENANCE REQUIREMENTS 15. 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 No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 013: A source initial compliance test shall be conducted on emissions point 013 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde 17. Point 014: A source initial compliance test shall be conducted on emissions point 014 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde 18. Point 015: A source initial compliance test shall be conducted on emissions point 015 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance Page 6 of 20 CDP E COLORADO f tr Pollution Control Division COit V Dpartment of Pubt Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde Periodic Testing Requirements 19. Points 013, 014, and 015: This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice(APEN)shall be filed:,(Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources(NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Page 7 of 20 cagrtE COLORADO co Air Pollution Control Division [ Department or Pubt Hea3th&Environment Dedicated to protecting and improving the health and environment of the people of Colorado d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 21. The exhaust stack(s) for the following emission points) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602, ` 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 22. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Maximum Number Combined Hours of Engines in Facility Equipment of Operation Per Operation at Any IDs AIRS Points Year Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 21 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 23. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) Page 8 of 20 CDPHE COLORADO CO Air Pollution Control Division l Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 24. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 25. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions- tons per year ;Equipment AIRS Equipment PolEutant ID Point Description Threshold Current Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J` VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 9 of 20 ,^ C�E ( COLORADO CO tIf Air Pollution Control Division 1 Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 26. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 27. 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 No. 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 Page 10 of 20 CDPHE ( COLORADO C O Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 28. 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. 29. 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. 30. 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. 31. 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. 32. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 11 of 20 cDPHE COLORADO CO Air Pollution Control Division Department of PublIc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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.qovipacificicdphe/aqcc-reqs 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. Uncontrolled Are the Controlled AIRS Pollutant_ CAS# Emission emissions Emission Point Rate reportable? Rate(lb/yr) (Ib/yr) Formaldehyde 50000 21,259 Yes 2,126 Acetaldehyde 75070 1,054 Yes 527 Toluene 108883 1,027 Yes 514 013 Acrolein 107028 648 Yes 324 Methanol 67561 315 Yes 158 Benzene 71432 164 No 82 n-Hexane 110543 140 No 70 Formaldehyde 50000 21,259 Yes 2,126 Acetaldehyde 75070 1,054 Yes 527 Toluene 108883 1,027 Yes 514 014 Acrolein 107028 648 Yes 324 Methanol 67561 315 Yes 158 Benzene 71432 164 No 82 n-Hexane 110543 140 No 70 Formaldehyde 50000 21,259 Yes 2,126 015 Acetaldehyde 75070 1,054 Yes 527 Page 12 of 20 ,� cr�E COLORADO CO ie Air Pollution Control Division ' Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Are the Controlled AIRS Pollutant CAS# Emission emissions Emission Point Rate reportable? Rate(Ib/yr) (Ib/yr) Toluene 108883 1,027 Yes 514 Acrolein 107028 648 Yes 324 Methanol 67561 315 Yes 158 Benzene 71432 164 No 82 n-Hexane 110543 140 No 70 Formaldehyde 50000 42,519 4,252 Acetaldehyde 75070 2,108 1,054 013 and Toluene 108883 2,055 1027 014 and 015 Acrolein 107028 1,296 648 (tom- Methanol 67561 630 315 (com- bined) Benzene 71432 328 164 n-Hexane 110543 280 140 5) The emission levels contained in this permit are based on the following emission factors: Points 013, 014,and 015(each): Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.1591 0.50 0.1591 0.50 CO 0.7318 2.30 0.0512 0.16 VOC 0.3468 1.09 0.0867 0.27 50000 Formaldehyde 0.1686 0.53 0.0169 0.05 75070 Acetaldehyde 0.0084 0.03 0.0042 0.01 108883 Toluene 0.0082 0.03 0.0041 0.01 107028 Acrolein 0.0051 0.02 0.0026 0.01 67561 Methanol 0.0025 0.008 0.0013 0.004 71432 Benzene 0.0013 0.004 0.0007 0.002 110543 n-Hexane 0.0011 0.003 0.0006 0.002 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 6929 Btu/hp-hr,a site- rated horsepower value of 2077, and a fuel heat value of 981 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer No control. CO Manufacturer Applicant requested. VOC Manufacturer; sum of Applicant requested. NMNEHC + HCHO 50000 Formaldehyde Manufacturer Applicant requested. Page 13 of 20 CAE ICOLORADO CO Air Pollution Control Division Department of Public Health E Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS Pollutant Uncontrolled EFSource Controlled EF Source 75070 Acetaldehyde AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 108883 Toluene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 107028 Acrolein AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 67561 Methanol AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 71432 Benzene GRI HAPCalc 3.0; Literature; Applicant requested. Natural Gas 110543 n-Hexane AP-42; Table 3.2-2 (7/2000); Applicant requested. Natural Gas 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 engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). 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'on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18i a08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,2008 Federal Register posting -effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated,into Colorado Air Quality Control Commission's Regulation No. 8.A copy of the complete subpart,is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.ciov/ttn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of:VOC, CO, HAPs(total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of:VOC MACT ZZZZ Area Source Requirements: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/ Page 14 of 20 CDP COLORADO CO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 11)A self-certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification Page 15 of 20 CDP E COLORADO CO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2.Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. 'Temporary' is defined as in the same service for 90 operating days or less in,any 12 month period."Permanent"is defined as in the same service for more than 90 operating days in any 12 month period.The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable Page 16 of 20 CDPHE COLORADO CO -0' Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.coloradogov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer)as found on the Division's web site at: www.colorado.qov/cdphe/portable-analvzer-mon itorinq-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation Page 17 of 20 CDP ICOLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B§ II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology(RACT)for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and N0X are precursors for ozone, RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to N0X and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State- Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Page 18 of 20 ,v, ceCOLORADO CO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1,2008 2.0 4.0 1.0 100<Hp<500 January 1,2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation Page 19 of 20 C E COLORADO co p Air Pollution Control Division " ! Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado No. 6, Part B, § l.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site;an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 20 of 20 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Sectio-i 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 1 4N 65 Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? Yes If yes, 'or what pollutant? ■ Carbon Monoxide (CO) ■ Particulate Matter (PM) a O'cre (INC- S. VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 001 Liquid Loading SP300-10 Yes 19WE01GJ5 ''t' . _ i errnit Initial1r;, --c.: 002 NG Heater HTR-703 No 15WE1029.XP • No APEN RegU t�C I Permit 004 Natural Gas RICE C-602 Yes 19WE014E Yes _ 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes _ 19WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 0.18 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Ye:- 19WE0164 Yes 021 Fugitive Component Leaks LEAKS '. .9WE0166 Yes Section 03 - Description of Project New natural gas process ng plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy; the modeling report was submitted in February 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 1SWE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? `' If yes, for what pollutants? . .. .. If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? n.- Is this stationary source a synthetic minor? e If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits ( JP) J J _ ■ J Non-Attainment New Source Review (NANSR) J Is this stationary source a major source? If yes, explain what programs and which pollutants her( SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) rl rTitle 'I Operating Permits (OP) . ■ Non-Attainment New Sour:e Review (NANSR) Natural Gas Heater Emissions Inventory 016 NG Heater 123 9DF7 016 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Heater Information Fuel Type Natural Gas Number of Heaters 1 One (1) Purpose ectupr$r v -.reg l"attot; heat_{ Make: TED Model: TEED Serial Number: ISO Design Heat Input Rate: 10,4 MMBtu/hr Equipped with Low-NOx burners: Equipped with Add-On Control Equipment: One (1) natural gas heater(s) (Make: TBD, Model: TBD, Serial Number: TAD) each with a design heat input rate of 10.4 MMBtu/hr. Each unit is equipped with low-NOx burners. Each unit is a molecular sieve regeneration heater. Detailed Emissions Unit Description: No add-on control equipment Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency W. Low NOx combustion system is considered an integral control device. Section 03 - Processing Rate Information for Emissions Estimates Design Heat Input Rate = 10.4 MMBtu/hr Heat content of waste gas= 981 Btu/scf Actual Hours of Operation = 8760 hrs/year Requested Hours of Operation = 8.760 hrs/year Requested heat input rate = 91,104.00 MMBTU per year Actual Fuel Consumption = 92.87 MMscf/year Requested Fuel Consumption = 92.87 MMscf/year Requested Monthly Throughput = 7.9 MMscf per month Potential to Emit (PTE) Fuel Consumption = 92.87 MMscf/year Section 04 - Emissions Factors & Methodologies Emission Factors Natural Gas Heaters Uncontrolled Uncontrolled lb/MMBtu lb/MMscf Emission Factor Source Pollutant (Fuel Heat (Fuel Combusted) Consumption) PM10 0.00745098 7.309411765 ,A 42 4 ft? ' PM2.5 0.00745098 7.309411765 AF 42'!3 ° ,fir t �� ,, r b<A ,� SOx 0000588235 0.577058824 AP4? T _.. ap � � c4 NOx 0.025 24.525 Manufacturer CO 0.041 40.221 tlranttf'teeturer VOC 0.005392151 5.289705882 AP-42 Table 1.4 M� �;z, v ;_, Formaldehyde 0.000844009 0.827972829 CR1 Field Test � ��' �/. ��w"u'' Benzene 0.000748047 0.733834107 Gill Field Test Toluene 0001016331 0.997020711 GRI field Tint Ethylbenzene 0.002112822 2.072678382 GPI Field Test Xylenes 0,001320514 1.295424234 66Rt f-ie&d Test • 2,2,4-Trimethylpentane 0.002841758 2.787764598 R3 F1&d lest n-Hexane 0.001764706 1.731176471 AP-+ 2 Toble 1• •z fir;.H.?.;arN5.1 Styrene 0.002078896 2.039396976 Gai ;c it.. ?:c:..1.; Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.34 0.34 0.34 0.34 0.34 58 PM2.5 0.34 0.34 0.34 0.34 0.34 58 SOx 0.03 0.03 0.03 0.03 0.03 5 NOx 1.14 1.14 1.14 1.14 1.14 193 CO 1.87 1.87 1.87 1.87 1.87 317 VOC 0.25 0.25 _ 0.25 0.25 0.25 42 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Formaldehyde 77 77 77 77 77 Benzene 68 68 68 68 68 Toluene 93 93 93 93 93 Ethylbenzene 192 192 192 192 192 Xylenes 120 120 120 120 120 2,2,4-Trimethylpentane 259 259 259 259 259 n-Hexane 161 161 161 161 161 Styrene 189 189 189 189 189 2 of 5 K:\PA\2019\19WE0160.CP1 Natural Gas Heater Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 1, Section VI Based on the requested emissions and emission factor, compliance is presumed. Regulation 1, Section III & Regulation 6, Part B, Section II Based on the design heat input rate, the source is subject to Regulation 1 Section III.A.l.b. and Regulation 6, Part B, Section II.C.2. and 3. Based on the request Regulation 6, Part A, Subpart Db, SO2 Standards Source is not subject to NSPS Db. Regulation 6, Part A, Subpart Db, NOx Standards Source is not subject to NSPS Db. Regulation 6, Part A, Subpart Dc Source is subject to NSPS Dc. Regulation 7, Section XVI.D Source is not subject to Regulation 7, Section XVI.D. Regulation 8, Part E, MACT Subpart DDDDD Source is not subject to MACT DDDDD. (See regulatory applicability worksieet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Is the project close to the 40 tpy modeling / NANSR threshold for NOx? If yes, stack-testing should be required for NOx, as well as for CO. Is the operator limiting their heat input rate below the design rate? IMMIX If yes, stack-testing should be required for NOx, as well as for CO. Is the project close to the 5 tpy modeling threshold for PM 2.5? project is over 5 tpy PM2.5 If yes, stack-testing should be required for PM 2.5 Does the company use AP-42 emission factors (or more conservative factors)? Yes If no and testing hasn't already been required due to proximity to modeling thresholds, testing should be required for any pollutants for which alternative emission factors have been used. If testing is being done for only NOx or only CO, the other should be included as well. Section 08 - Technical Analysis Notes Applicant did provide manufacturer spec sheet from Tulsa Heaters Midstream which specified NOx and CO emissions in terms of Ib/MMBtu. Stack testing is required to confirm NOx and CO emission factors of the actual unit. For HAP uncontrolled emission factors, the applicant used the higher of AP-42 or GRI field /test data. ......a,...5. ,..... ,.u.sXA.. 1.y,,,,\ ra Os..t �. Rt. <. ..l :..\ t .:�. . . ": .•.i' l: , s\,:. .\ Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 016 01 3-10-004-04: Industrial Process; Oil & Gas Production; Process Heaters; Natural Gas (MMscf) PM10 7.309 0 lb/MMscf Burned PM2.5 7.309 0 lb/MMscf Burned SOx 0.577 0 lb/MMscf Burned NOx 24.525 0 lb/MMscf Burned CO 40.221 0 lb/MMscf Burned VOC 5.290 0 lb/MMscf Burned Formaldehyde 0.828 0 lb/MMscf Burned Benzene 0.734 0 lb/MMscf Burned Toluene 0.997 0 lb/MMscf Burned Ethylbenzene 2.073 0 lb/MMscf Burned Xylenes 1.295 0 lb/MMscf Burned 2,2,4-TrimethylpentE 2.788 0 lb/MMscf Burned n-Hexane 1.731 0 lb/MMscf Burned Styrene 2.039 0 lb/MMscf Burned 3 of 6 K:\PA\2019\19WE0160.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS T VOC HAPs VOC HAPs AIRS Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 _ 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 Previous taken from May 2018 tab Previous Permitted Facility total 0.0 0.0 0.0 _ 0.0 0. 6 94. 1 0.0 1. 1 0. 7 0.0 0. 0 0. 0 0. 0 0. 6 12. 9 0.0 1. 1 0. 2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1O29.X Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" - cl'. ;al ncel!et !die ;ariCeiled wider new facility configuration 004 19WE0148 Caterpillar G3516J, sn TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " 005 19WE0149 , Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03, 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2_"C-604" 008 19WE0152 Caterpillar G3512B, sn: TBD "C-410" Requested combined limit of 8760 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 hr/yr between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 1752C hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn. TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-652" 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" "G-771 " Requested combined limit of 013 19WE0157 Caterpillar G3516C, sn: TB ( 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 17520 hr/yr between points 013,014 and 014 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-772 015 19WE0157 , Caterpillar G3516C, sn: TBD "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 Hot oil heaters 19.33 MMBtu/hi 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 , 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4, 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0, 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 i 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7. 4 7. 4 , 0. 0 1. 8 80. 6 755. 9 99. 2 447.5 219.0 7. 4 7. 42 0.0 1. 8 80. 6 73. 8 9. 8 86.5 23.6 Excludes units exempt from (A) Change in Permitted Emissions 7. 4 7. 4 0.0 1. 8 80.0 60. 9 9. 8 85. 4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 ;A) Change in Total Permitted VOC emissions (point and fugitive; 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/13/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene ' " "te TOTAL (tpY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 51 46 62 129 81 108 59 17,_ I 0 . 5 3 , canceilea 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 i 23 24 7 . 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 i 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 73 164 18 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD _ 7725 1255 i 771 195 1223 6 41 167 375 1 40 5 . 9 011 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 } I 40 5 .9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 _ 1054 648 164 1027 5 34 140 315 34 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 140 315 34 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMB 77 67 68 93 120 161 88 259 189 31 0 .7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 30362 14458 145 1446 2892 216872 0 . 29 ### 133 . 8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3 .4 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 + 0 . 0 0 .0 TOTAL (tpy) 56 .8 4. 3 2. 5 17.4 12. 9 0.7 1 . 5 10.6 110. 3 0.9 0.7 0.6 0. 2 219 .4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0160. CP1 9/13/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) _ POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene -UU!dthrne TOTAL (tpY) IPrev1ousFAC1L1Th' TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr 81 108 59 127 0 .5 003 cancelled :"are 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 11 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 I 59 367 12 50 113 11 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 -11 12 1 .2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 11 12 1 . 2 008 19WE0152 Caterpillar G3512B , sn : TBD 009 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 9 82 8 r; 0 . 9 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 21 188 19 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 21 188 19 ;% 0 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 i r 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 015 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 " 7 70 158 1 17 1 . 9 016 19WE0160 Heater for dehy regen , 10 .4 MMB 77 67 68 93 192 120 161 88 259 189 31 0 .7 017 19WE0161 Hot oil heater, 19. 33 MMBtu/hr I 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 1518 723 r 72 145 10844 0 .01 1 72 6 .7 020 19WE0164 Plant Flare 108 108 22 540 32 1 0 .2 0 .4 021 19\A/E0166 Facility fugitive equipment leaks 65 67 743 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 5.9 2.2 1 .3 1 .4 2.7 0.6 0. 5 1 .6 6.3 0.8 0.0 0.6 0. 2 24 . 03 6 19WE0160. CP1 9/13/2019 At .-1,-,. COLORADO Air Pollution Control Division . . Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0160 Issuance: 1 Date issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description One (1) natural gas heater (Make: TBD, Model: TBD, Serial Number: TBD) with a design heat input rate of 10.4 H-310 016 MMBtu/hr. This unit is equipped with None low-NOx burners. This unit is used as a molecular sieve regeneration gas heater. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be Page 1 of 13 r•��M COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. Point 016: The following information must be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit: • Manufacturer • Model number • Serial number This information must be included with the Notice of Startup submitted for the equipment. (Regulation Number 3, Part B, III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Monthly Limits: AIRS Pounds per Month Emission Equipment ID Point PM2.5 NO,t VOC CO Type H-310 016 --- 193 42 317 Point Note: Monthly limits are based on a 31-day month. The owner or operator must calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant must not exceed 1,359 pounds per month. Facility-wide emissions of total hazardous air pollutants must not exceed 4,006 pounds per month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 13 Ya COLORADO Air Pollution Control Division Department of Public Health 0 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type H-310 016 --- 1.1 0.3 1.9 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 23.6 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the,previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 25 tons per year of total hazardous air pollutants (HAP). PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Page 3 of 13 -s- COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit Monthly Limit ID Point (31 days) H-310 016 Consumption of 92.9 MMscf 7.9 MMscf natural gas as a fuel The owner or operator must calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Point 016: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas combusted as fuel for this heater using an operational continuous flow meter at the inlet. The owner or operator must use monthly fuel consumption records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten-digit AIRS ID number assigned by the Division (e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 13. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions must not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation Number 1, Section II.A.1. £t 4.) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. This source is subject to the New Source Performance Standards requirements of Regulation Number 6, Part A Subpart Dc, Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units including, but not limited to, the following: a) The owner or operator of the facility must record and maintain records of the amount of fuel combusted during each month (40 CFR 60.48c(g)). Page 4 of 13 g •-.:,., COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado b) Monthly records of fuel combusted required under this permit condition must be maintained by the owner or operator of the facility for a period of two years following the date of such monthly record (40 CFR Part 60.48c(i)). 16. This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of Regulation 1, and the New Source Performance Standards requirements of Regulation 6, Part B, including, but not limited to, the following: No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel- burning equipment, particulate matter in the flue gases which exceeds the following (Regulation 1, Section III.A.1 and Regulation 6, Part B, Section II): i. For fuel burning equipment with designed heat inputs greater than 1x106 Btu per hour, but less than or equal to. 250x106 Btu per hour heat input, the following equation will be used to determine the allowable particulate emission limitation. PE = 0.5(FI)-o.z6 Where: PE = Particulate emissions in pounds per million Btu heat input. Fl = Fuel input in million Btu per hour. ii. Greater than 20 percent opacity. (Regulation Number 6, Part B, II.C.3) 17. This source is subject to the requirements of Regulation Number 6, Part A, Subpart A, General Provisions, including but not limited to the following: a) At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40 CFR 60.11(d)) b) No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§60.12) c) Written notification of construction and initial startup dates shall be submitted to the Division as required under §60.7. d) Records of startups, shutdowns, and malfunctions shall be maintained, as required under §60.7. e) Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under § 60.7. Page 5 of 13 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado f) Excess Emission and Monitoring System Performance Reports shall be submitted as required under § 60.7. g) Performance tests shall be conducted as required under §60.8. h) Compliance with opacity standards shall be demonstrated according to § 60.11. OPERATING a MAINTENANCE REQUIREMENTS 18. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. Point 016: A source initial compliance test shall be conducted on this heater to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one(1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. Page 6 of 13 ��'� COLORADO �Y Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 23. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Maximum Number of Facility Equipment Allowable Combined Hours Engines in Operation IDs AIRS Points of Operation Per Year at Any Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 24. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of Page 7 of 13 •r..-,. COLORADO g Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 25. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 26. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Emissions - tons per year . AIRS Equipment Equipment Pollutant Current ID Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC _ 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 8 of 13 4 COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 27. 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. 28. 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 Page 9 of 13 �•-� COLORADO % Air Pollution Control Division ® Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 29. 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. 30. 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. 31. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission(AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 32. 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. 33. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 13 a -x °°� COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing 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 Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Formaldehyde 50000 77 77 Benzene 71432 68 68 Toluene 108883 93 93 Ethylbenzene 100414 192 192 016 Xylenes 1330207 120 120 n-Hexane 110543 161 161 2,2,4-Trimethlpentane 540841 259 259 Styrene 100425 189 189 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 11 of 13 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Emission Pollutant CAS # Factors Source lb/MMscf PM10 7.3094 AP-42 Table 1.4-2 PM2.5 7.3094 AP-42 Table 1.4-2 SOx 0.577 AP-42 Table 1.4-2 NOx 24.525 Manufacturer (Tulsa Heaters Midstream) CO 40.221 Manufacturer (Tulsa Heaters Midstream) VOC 5.2897 AP-42 Table 1.4-2 Formaldehyde 50000 0.8280 GRI Field Test Benzene 71432 0.7338 GRI Field Test Toluene 108883 0.9970 GRI Field Test Ethylbenzene 100414 2.0727 GRI Field Test Xylenes 1330207 1.2954 GRI Field Test n-Hexane 110543 1.7312 AP-42 Table 1.4-3 2,2,4-Trimethlpentane 540841 2.7878 GRI Field Test Styrene 100425 2.0394 GRI Field Test Note: Emission factors are based on a fuel heat value of 981 Btu/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO 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://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources Page 12 of 13 r•�M. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 13 of 13 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 333291 Received Date: 2.'11/2019 Review Start Date: 3,'12/2019 Section 01 - Facility Information Company Name: A to Energy Group, i.LC Quadrant Section Township Range County AIRS ID: 123 . , . Plant AIRS ID: 9•JF7 Facility Name: Speer Gas Plant Physical Address/Location: S'N quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) El Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks Liquid Loading SP30C ?9WE0165 - Pet mit lritial Issuance 0(:: NG Heater HTR-703 15W E1029.XP No APEN Required / Permit 004 Natural Gas RICE C-601 19WE0148 Yes 005 Natural Gas RICE C-602 �:a 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE01 S1 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 1.9WE015S Yes 010 Natural Gas RICE C-651 Yes 19WE0154 .''' s 011 Natural Gas RICE C-652 Yes 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit Initia 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 _ NG Heater H-290 No 19WE01b1 Yes 018 NG Heater H-570 No 19WE0162 _ Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Le--: - LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy; . the modeling report was submitted in February 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a t-ue minor? No Is this stationary source a sjnthetic minor? If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ill Title V Operating Permits (OP) Fl .1 ,7, R 1 ■ El Non-Attainment New Source Review (NANSR) Is this stationary source a major source? No If yes, explain what programs and which pollutants her( SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) MR . . Non-Attainment New Source Review (NANSR) Natural Gas Heater Emissions Inventory 017 NG Heater =' ` % 017 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Heater Information Fuel Type Natural Gas Number of Heaters 1 One (1) • Purpose ri iil `Y>zi x. Make: TBD Model: ISO Serial Number TBD Design Heat Input Rate: 19.33 MMBtu/hr Equipped with Low-NOx burners: r zit% I , i£ bx9�ze0 Equipped with Add-On Control Equipment: w U�rat r ` ;s f fr a,t, " a One (1) natural gas heater(s) (Make: TBD, Model: TBD, Serial Number: TBD) each with a design heat input rate of 19.33 MMBtu/hr. Each unit is equipped with low-NOx burners. Each unit is an amine regeneration heater. Detailed Emissions Unit Description: No add-on control equipment Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency%: Low NOx combustion system is considered an integral control device. Section 03 - Processing Rate Information for Emissions Estimates Design Heat Input Rate = 19.3 MMBtu/hr Heat content of waste gas= 981, Btu/scf Actual Hours of Operation = 8760 hrs/year Requested Hours of Operation = 8760 hrs/year Requested heat input rate = 169,330.80 MMBTU per year Actual Fuel Consumption = 172.61 MMscf/year Requested Fuel Consumption = 172.61 MMscf/year Requested Monthly Throughput = 14.7 MMscf per month Potential to Emit (PTE) Fuel Consumption = 172.61 MMscf/year Section 04 - Emissions Factors & Methodologies Emission Factors Natural Gas Heaters Uncontrolled Uncontrolled lb/MMBtu lb/MMscf Emission Factor Source Pollutant (Fuel Heat (Fuel Combusted) Consumption) PM10 0,00745098 7.3094 •. , PM2.5 0.00745098 7.3094 AP--42 T.*b:e 3,.4-2 ;Ptv 1C+l. •;i �Wy�r .wE.O `,:; 1f K Y35 SOx 0.000588235 0.5771 fl-42 Table 1..4x2 tsox) :. NOx 0.025 24.525 Ma Met c;urer CO 0.04:, 40.221 Manufacturer VOC 0.005392.15: 5.2897 AP-4'2 Table 1.4-2 ` Formaldehyde 0.000844009 0.8280 GRI Field Test Benzene 0.000748047 0.7338 GRt Flew Test ` �>f f+ is jj2 i 5 ,< Toluene 0.001016331 0.9970 GRL Field Test . a≥ : t '< Ethylbenzene 0.002112822 2.0727 GRt Field Test l Y Xylenes 0.001320514 1.2954 GP) Field Test 2,2,4-Trimethylpentane 0.002841758 2.7878 Gal field Test n-Hexane 0.001764706 1.7312 Ai' " I -'•' Y .4 Styrene 0.0020788% 2.0394 L,';, Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.63 0.63 0.63 0.63 0.63 107 P M 2.5 0.63 0.63 0.63 0.63 0.63 107 SOx 0.05 0.05 0.05 0.05 0.05 8 NOx 2.12 2.12 2.12 2.12 2.12 360 CO 3.47 3.47 3.47 3.47 3.47 590 VOC 0.46 0.46 0.46 0.46 0.46 78 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Formaldehyde 143 143 143 143 143 Benzene 127 127 127 127 127 Toluene 172 172 172 172 172 Ethylbenzene 358 358 358 358 358 Xylenes 224 224 224 224 224 2,2,4-Trimethylpentane 481 481 481 481 481 n-Hexane 299 299 299 299 299 Styrene 352 352 352 3S2 352 2 of 6 . K:\PA\2019\19WE0161.CP1 Natural Gas Heater Emissions Inventory Section 06 - Re&ulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 1, Section VI Based on the requested emissions and emission factor, compliance is presumed. Regulation 1, Section III & Regulatioi 6, Part B, Section II Based on the design heat input rate, the source is subject to Regulation 1 Section III.A.1.b. and Regulation 6, Part B, Section II.C.2. and 3. Based on the request Regulation 6, Part A, Subpart Db, SO2 Standards Source is not subject to NSPS Db. Regulation 6, Part A, Subpart Db, NCx Standards Source is not subject to NSPS Db. Regulation 6, Part A, Subpart Dc Source is subject to NSPS Dc. Regulation 7, Section XVI.D Source is not subject to Regulation 7, Section XVI.D. Regulation 8, Part E, MACT Subpart JDDDD Source is not subject to MACT DDDDD. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Is the project close to the 40 tpy modeling / NANSR threshold for NOx? MIN If yes, stack-testing should be required for NOx, as well as for CO. Is the operator limiting their heat input rate below the design rate? If yes, stack-testing should be required for NOx, as well as for CO. Is the project close to the 5 tpy modeling threshold for PM 2.5? facility is over 5 tpy PM2.5 If yes, stack-testing should be required for PM 2.5 Does the company use AP-42 emission factors (or more conservative factors)? yes If no and testing hasn't already beer required due to proximity to modeling thresholds, testing should be required for any pollutants for which alternative emission factors have been used. If testing is being done for only NOx or only CO, the other should be included as well. Section 08 - Technical Analysis Notes Applicant did provide manufacturer spec sheet from Tulsa Heaters Midstream which specified NOx and CO emissions in terms of b/MMBtu. Stack testing is required to confirm NOx and CO emission factors of the actual unit. For HAP uncontrolled emission factors, the applicant used the higher of AP-42 or GRI field /test data. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 017 01 3-10-004-04: Industrial Process; Oil & Gas Production; Process Heaters; Natural Gas (MMscf) PM10 7.309 0 Ib/MMscf Burned PM2.5 7.309 0 Ib/MMscf Burned SOx 0.577 0 Ib/MMscf Burned NOx 24.525 0 Ib/MMscf Burned CO 40.221 0 lb/MMscf Burned VOC 5.290 0 Ib/MMscf Burned Formaldehyde 0.828 0 Ib/MMscf Burned Benzene 0.734 0 Ib/MMscf Burned Toluene 0.997 0 Ib/MMscf Burned Ethylbenzene 2.073 0 Ib/MMscf Burned Xylenes 1.295 0 Ib/MMscf Burned 2,2,4-Trimethylpentz 2.788 0 lb/MMscf Burned n-Hexane 1.731 0 lb/MMscf Burned Styrene 2.039 0 lb/MMscf Burned 3 of 6 K:\PA\2019\19WE0161.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LL( County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS T VOC HAPs VOC HAPs AIRS Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 , 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 Rrevious taken from May 2018 tab Previous Permitted Facility total 0. 0 0.0 0.0 0. 0 0. 6 94. 1 0.0 1. 1 0. 7 0.0 0.0 0. 0 0.0 0. 6 12.9 0.0 1. 1 0. 2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 I 15WE1029.X Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0, 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" r:f.; .;ancel/ec . .. . ;& celleci under new facility configuration 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0. 5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" 008 19WE0152 Caterpillar G3512B, sn: TBD "C-410" Requested combined limit of 876( 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 hr/yr between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 D.C 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013,014,and 014 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 "G-772" 015 19WE0157 Caterpillar G3516C, sn: TBD "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 I lot oil heater. 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 , 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater. 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 , 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 , 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" - APEN-Exempt / Insignificants 0.0, 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 '1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7.4 14 0. 0 1. 8 80. 6 7559 . 99. 2 447. 5 219. 0 7. 4 7. 42 0.0 1. 8 80. 6 73. 8 9. 8 _ 86. 5 23. 6 Excludes units exempt from (A) Change in Permitted Emissions 7. 4 7. 4 0.0 1. 8 80. 0 60. 9 9. 8 85. 4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) _ 83. 8 Facility is eligible for GP02 because < 90 ,A' Change in Total Permitted VOC emissions (point and fugitive',, 70. 7 _ _ Note 1 lnsignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/13/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled ( lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene TOTAL Nov) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck Ioadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 51 45 46 62 129 81 108 173 127 21 0 . 5 002> Jocene,,L4:art 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 4 100 225 23 24 7 .0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 .0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 73 164 1 G 18 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 r 38 40 5 . 9 011 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 el 41 167 375 3fi, 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 315 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 I 315 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMB 77 67 68 93 192 120 88 259 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 . 018 19WE0162 Hot oil heater. 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 30362 14458 145 1446 2892 216872 0 .29 #11# 133 .8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 H 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 5292 1? 6 3 .4 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 56.8 4.3 2. 5 17.4 12.9 0.7 1 . 5 10. 6 110. 3 0.9 0.7 0.6 0 . 2 219 .4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0161 . CP1 9/13/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene -' '"' TOTAL (tpY) IPreviousFAC1LITh' TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 1 46 10 21 0 . 5 003 cancelled ==tare 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 . 2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 . 2 008 19WE0152 Caterpillar G3512B , sn: TBD 009 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 9 37 82 9 0. 9 010 19WE0154 Caterpillar G3608, sn : TBD 772 627 386 98 612 21 83 188 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 012 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 -a� 0� 1 .4 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 015 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 1 . 9 016 19WE0160 Heater for dehy regen , 10 .4 MMB 77 67 68 93 192 120 161 88 259 189 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 .3 1518 723 72 145 10844 0 .01 72 6 . 7 020 19WE0164 Plant Flare 108 108 22 540 32 1 0 . 2 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 s 743 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 5.9 2. 2 1 .3 1 .4 2. 7 0. 6 0.5 1 .6 6. 3 0.8 0.0 0. 6 0.2 24 . 03 6 19WE0161 .CP1 9/13/2019 COLORADO Ito Aix Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE0 1 61 Issuance: 1 Date issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description One (1) natural gas heater (Make: TBD, Model: TBD, Serial Number: TBD) with a design heat input rate of 19.33 H-290 017 MMBtu/hr. This unit is equipped with None low-NOx burners. This unit is used as a amine regeneration heater. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify Page 1 of 13 is ,M COLORADO _L.41 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. Point 017: The following information must be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit: • Manufacturer • Model number • Serial number This information must be included with the Notice of Startup submitted for the equipment. (Regulation Number 3, Part B, III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Monthly Limits: AIRS Pounds per Month Emission Equipment ID Point PM2.5 NO,t VOC CO Type H-290 017 --- 360 78 590 Point Note: Monthly limits are based on a 31-day month. The owner or operator must calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant must not exceed 1,359 pounds per month. Facility-wide emissions of total hazardous air pollutants must not exceed 4,006 pounds per month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 13 r.MM COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type X H-290 017 --- 2.1 0.5 3.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 23.6 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. During the first twelve ('12.) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data.The permit holder must calculate actual emissions each month and keep a compliance-record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this any condition, insignificant activities are defined as a activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 25 tons per year of total hazardous air pollutants (HAP). PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Page 3 of 13 COLORADO 4.44, 0 Air Pollution Control Division GDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit Monthly Limit ID Point (31 days) H-290 017 Consumption of 172.6 MMscf 14.7 MMscf natural gas as a fuel The owner or operator must calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Point 017: The owner or operator must continuously monitor and record the volumetric flow rate of natural-gas combusted as fuel for this heater using an operational continuous flow meter at the inlet. The owner or operator must use monthly fuel consumption records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten-digit AIRS ID number assigned by the Division (e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)E.) (State only enforceable) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 13. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions must not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation Number 1, Section II.A.1. Ft 4.) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. This source is subject to the New Source Performance Standards requirements of Regulation Number 6, Part A Subpart Dc, Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units including, but not limited to, the following: a) The owner or operator of the facility must record and maintain records of the amount of fuel combusted during each month (40 CFR 60.48c(g)). Page 4 of 13 a . COLORADO Air Pollution Control Division "3� Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado b) Monthly records of fuel combusted required under this permit condition must be maintained by the owner or operator of the facility for a period of two years following the date of such monthly record (40 CFR Part 60.48c(i)). 16. This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of Regulation 1, and the New Source Performance Standards requirements of Regulation 6, Part B, including, but not limited to, the following: No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel- burning equipment, particulate matter in the flue gases which exceeds the following (Regulation 1, Section III.A.1 and Regulation 6, Part B, Section II): i. For fuel burning equipment with designed heat inputs greater than 1x106 Btu per hour, but less than or equal to 250x106 Btu per hour heat input, the following equation will be used to determine the allowable particulate emission limitation. PE = 0.5(FI)_o.z6 Where: PE = Particulate emissions in pounds per million Btu heat input. Fl = Fuel input in million Btu per hour. ii. Greater than 20 percent opacity. (Regulation Number 6, Part B, II.C.3) 17. This source is subject to the requirements of Regulation Number 6, Part A, Subpart A, General Provisions, including but not limited to the following: a) At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing!emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40 CFR 60.11(d)) b) No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§60.12) c) Written notification of construction and initial startup dates shall be submitted to the Division as required under §60.7. d) Records of startups, shutdowns, and malfunctions shall be maintained, as required under §60.7. e) Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under § 60.7. Page 5 of 13 4440,H.� COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado f) Excess Emission and Monitoring System Performance Reports shall be submitted as required under § 60.7. g) Performance tests shall be conducted as required under §60.8. h) Compliance with opacity standards shall be demonstrated according to § 60.11. OPERATING Et MAINTENANCE REQUIREMENTS 18. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. Point 017: A source initial compliance test shall be conducted on this heater to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: °Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one(1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. Page 6 of 13 COLORADO As ....4„� Air Pollution Control Division �� Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 " 008 9.14 C-411 009 9.14 C-651 _ 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 23. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Maximum Number of Facility Equipment Allowable Combined Hours Engines in Operation IDs AIRS Points of Operation Per Year at Any Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 24. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section 111.8.5.) Page 7 of 13 a ,..y., COLORADO IV Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section 111.8.5.) 26. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Fac Emissions - tons per year ility AIRS Equipment Pollutant Equipment Point Description Threshold Current ID Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 8 of 13 My. COLORADO Y.+11 Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Fac Emissions - tons per year ility AIRS Equipment Pollutant Equipment Point Description Threshold Current ID Permit Limit HTR-703 002 Hot oil heater CO 100 2.5. C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 27. 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. 28. 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 Page 9 of 13 r�Ty COLORADO Air Pollution Control Division �i Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 29. 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. 30. 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. 31. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 32. 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. 33. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 13 arye COLORADO Air Pollution Control Division . Nu- Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in. this permit as soon as possible, but„ no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Formaldehyde 50000 143 143 Benzene 71432 127 127 Toluene 108883 172 172 Ethylbenzene 100414 358 358 017 Xylenes 1330207 224 224 n-Hexane 110543 299 299 2,2,4-Trimethlpentane 540841 481 481 Styrene 100425 352 352 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 11 of 13 •r COLORADO 416---1-11210-4 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Emission Pollutant CAS # Factors Source lb/MMscf PM10 7.3094 AP-42 Table 1.4-2 PM2.5 7.3094 AP-42 Table 1.4-2 SOx 0.577 AP-42 Table 1.4-2 NOx 24.525 Manufacturer (Tulsa Heaters Midstream) CO 40.221 Manufacturer (Tulsa Heaters Midstream) VOC 5.2897 AP-42 Table 1.4-2 Formaldehyde 50000 0.8280 GRI Field Test Benzene 71432 0.7338 GRI Field Test Toluene 108883 0.9970 GRI Field Test Ethylbenzene 100414 2.0727 GRI Field Test Xylenes 1330207 1.2954 GRI Field Test n-Hexane 110543 1.7312 AP-42 Table 1.4-3 2,2,4-Trimethlpentane 540841 2.7878 GRI Field Test Styrene 100425 2.0394 GRI Field Test Note: Emission factors are based on a fuel heat value of 981 Btu/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO 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://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources Page 12 of 13 a COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 13 of 13 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 3 )3291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: A .3 Energy Group, LLC Quadrant Section Township Range County AIRS D: 123 - . 31 tIN 65 Plant AIRS ID: 93F7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant What industry segment? Oil & Natural Gas Production & Processing Is this facility bcated in a NAAQS non-attainment area? Yes If yes, for what pollutant? ■ Carbon Monoxide (CO) ■ Particulate Matter (PM) El Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks Liquid Loading SP300-10 Yes 19WE0165 Yes Permit Initial Issuance 002 NG Heater HTR-703 No 1SWE1029.XP No APEN Required / Permit 004 Natural Gas RICE C-601 Yes 19WE0148 Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 005 Natural Gas RICE C-603 Yes 19WE01S0 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 003 Natural Gas RICE C-410 Yes - 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 _ — Yes 011 Natural Gas RICE C-652 Yes 19WE015S Yes 012 Natural Gas RICE C-653 Yes 19W£0156 Yes Permit initia 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0153 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes =9WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description o' Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy; the modeling report was submitted in February 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed f are) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requiremeni Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 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? Tes If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention jf Significant Deterioration (PSD) Title V Operating Permits (OP) 11 1_J I " 1 I . I. ./ Non-Attainment New Source Review (NANSR) , J Is this stationary source a major source? Na If yes, explain what programs and which pollutants hen SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention pf Significant Deterioration (PSD) Title V Operating Permits (OP) 11 A I ■ Non-Attainment New Source Review (NANSR) Natural Gas Heater Emissions Inventory 018 NG Heater 123 901,7 018 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Heater Information Fuel Type Natural Gas Number of Heaters I. One (1) a�. .gbi.:r v ...,r > ru>.a a:,tr,A?'nw�'(u e� Purpose s,•>..,�y < ,,:x�h44, �.. `s, °,L# . _° Make: T$O Model: TBfl Serial Number. 'rap Design Heat Input Rate: 24.3 MMBtu/hr Equipped with Low-NOx burners: y ,c - '� h„ f': Equipped with Add-On Control Equipment: One (1) natural gas heater(s) (Make: TBD, Model: TBD, Serial Number: TBD) each with a design heat input rate of 24.3 MMBtu/hr. Each unit is equipped with low-NOx burners. Each unit is a hot oil heater for the cryo unit. Detailed Emissions Unit Description: No add-on control equipment Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Low NOx combustion system is considered an integral control device. Section 03 - Processing Rate Information for Emissions Estimates Design Heat Input Rate = 24.3 MMBtu/hr Heat content of waste gas= 981. Btu/scf Actual Hours of Operation = 8760 hrs/year Requested Hours of Operation = 8760 hrs/year Requested heat input rate = 212,868.00 MMBTU per year Actual Fuel Consumption = 216.99 MMscf/year Requested Fuel Consumption = 216.99 MMscf/year Requested Monthly Throughput = 18.4 MMscf per month Potential to Emit WTE) Fuel Consumption = 216.99 MMscf/year Section 04 - Emissions Factors & Methodologies Emission Factors Natural Gas Heaters Uncontrolled Uncontrolled Ib/MMBtu lb/MMscf Emission Factor Source Pollutant (Fuel Heat (Fuel Combusted) Consumption) PM 10 0.0074:1098 7.3094 ,try-421 Aiale. 1,4-2 T MI0JPM x :. PM2.5 0.00745098 7.3094 AP 42'Table 1.4-2 (PM10/PrM.2,,, SOx 0.000588235 0.577 AP 42 T=,b? to-2 S0.t) NOx 3.025 24.525 CO 0.041 40.221 VOC 0.005392157 5.2897 AP•42 a?al• .1.4-2 Formaldehyde 0.000844009 0.8280 GRI Field Test . Benzene 0,0007480047 0.7338 GM Ned Test Toluene 0.001.016331 0.9970 GR', fitid Test Ethylbenzene 0.002112822 2.0727 GRA Fiiid Test Xylenes 0.001320514 1.2954 tRt Field Test 2,2,4-Trimethylpentane 0.002841758 2.7878 6Rl Pd Tent n-Hexane 0.001764706 1.7312 AP-42 Table .1.4.-3 (In-He:acne i Styrene 0.002078896 2.0394 GRl Field Test Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.79 0.79 0.79 0.79 0.79 135 PM2.5 0.79 0.79 0.79 0.79 0.79 135 SOx 0.06 0.06 0.06 0.06 0.06 11 NOx 2.66 2.66 2.66 2.66 2.66 452 CO 4.36 .1.36 4.36 4.36 4.36 711 VOC 0.57 0.57 0.57 0.57 0.57 97 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Formaldehyde 180 180 180 180 180 Benzene 159 159 159 .159 159 Toluene 216 216 216 216 216 Ethylbenzene 450 450 450 450 450 Xylenes 281 281 281 281 281 2,2,4-Trimethylpentane 605 605 605 605 605 n-Hexane 376 376 376 376 376 Styrene 443 443 443 443 443 2 of 6 K:\PA\2019\19WE0162.CP1 Natural Gas Heater Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 1, Section VI Based on the requested emissions and emission factor, compliance is presumed. Regulation 1, Section III & Regulation 6, Part B, Section II Based on the design heat input rate, the source is subject to Regulation 1 Section III.A.1.b. and Regulation 6, Part B, Section II.C.2. and 3. Based on the request Regulation 6, Part A, Subpart Db, SC 2 Standards Source is not subject to NSPS Db. Regulation 6, Part A, Subpart Db, NOx Standards Source is not subject to NSPS Db. Regulation 6, Part A, Subpart Dc Source is subject to NSPS Dc. Regulation 7, Section XVI.D Source is not subject to Regulation 7, Section XVI.D. Regulation 8, Part E, MACT Subpart DDDDD Source is not subject to MACT DDDDD. (See regulatory applicability works,eet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Is the project close to the 40 tpy modeling / NANSR threshold for NOx? 11.111 If yes, stack-testing should be required for NOx, as well as for CO. Is the operator limiting their heat input rate below the design rate? If yes, stack-testing should be required for NOx, as well as for CO. Is the project close to the 5 tpy modeling threshold for PM 2.5? t y Facility is over 5 tpy PM2.5 If yes, stack-testing should be required for PM 2.5 Does the company use AP-42 emission factors (or more conservative factors)? If no and testing hasn't already beer required due to proximity to modeling thresholds, testing should be required for any pollutants for which alternative emission factors have been used. If testing is being d)ne for only NOx or only CO, the other should be included as well. Section 08 - Technical Analysis Notes Applicant did provide manufacturer spec sheet from Tulsa Heaters Midstream which specified NOx and CO emissions in terms of Ib/MMBtu. Stack testing is required to confirm NOx and CO emission factors of the actual unit. For HAP uncontrolled emissi Dn factors, the applicant used the higher of AP-42 or GRI field /test data. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point St Process # SCC Code Pollutant Factor Control % Units 018 01 3-10-004-04: Industrial Process; Oil & Gas Production; Process Heaters; Natural Gas (MMscf) PM10 7.309 0 lb/MMscf Burned PM2.5 7.309 0 lb/MMscf Burned SOx 0.577 0 lb/MMscf Burned NOx 24.525 0 lb/MMscf Burned CO 40.221 0 lb/MMscf Burned VOC 5.290 0 lb/MMscf Burned Formaldehyde 0.828 0 lb/MMscf Burned Benzene 0.734 0 Ib/MMscf Burned Toluene 0.997 0 Ib/MMscf Burned Ethylbenzene 2.073 0 Ib/MMscf Burned Xylenes 1.295 0 lb/MMscf Burned 2,2,4-Trimethylpentz 2.788 0 Ib/MMscf Burned n-Hexane 1.731 0 lb/MMscf Burned Styrene 2.039 0 lb/MMscf Burned 3 of 6 K:\PA\2019\19WE0162.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment _ Facility Name _ Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS T VOC HAPs VOC HAPs AIRS Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 'r-evious taken from May 2018 tab Previous Permitted Facility total 0. 0 , 0. 0 0.0 0 0 0. 6 94. 1 0.0 1. 1 0. 7 0. 0 0. 0 0. 0 0. 0 0. 6 12. 9 0.0 1. 1 0. 2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1O29.X Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" 1 ;ariceiPa LL new acltty configuration ". artceJ:C:I Hare �� ;'if'f facility .. 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " _, 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" _ 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0, 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" _ 008 19WE0152 Caterpillar G3512B, sn: TBD "0-410" Requested combined limit of 876` 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 hr/yr between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn TBD 0.8 0.8 0.0 7.2 10.6 62..3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 "C-651 " Requested combined limit of 1752 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 "C-653" 012 19WE0154 Caterpillar G3608, sn: TBD 013 19WE0157 Caterpillar G3516C , sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013,014,and 014 19WE0157 Caterpillar G3516C, sn TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-772 015 19WE0157 Caterpillar G3516C, sn: TBD "G-773" Heater MMBtufor dehy regen, 10.4 016 19WE0160 Heater hr 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" 017 19WE0161 Hot oil heater, 19.33 MMBtu/hr , 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 , 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57, 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 - 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC: Syn Minor (NANSR and OP) NOx: Minor ( NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7. 4 7. 4 0. 0 1. 8 80. 6 755. 9 99. 2 447.5 219. 0 . 14 7. 42+ 0.0 1. 8 80. 6 73. 8 9. 8 86.5 23.6 Excludes units exempt from (A) Change in Permitted Emissions 7. 4 7.4 0.0 1. 8 80. 0 60. 9 9. 8 85. 4 Pubcorn required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 (A) Change in Total Permitted VOC emissions ;point and fugitive, 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/13/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene TOTAL (tpY) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr 45 46 62 129 81 108 , [T `' 173 127 21 0 . 5 003 -mcc,-iieu Flare 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 18 73 164 16 18 5 . 6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 40 5 . 9 011 19WE0154 Caterpillar G3608, sn : TBD 7725 1255 771 195 1223 41 167 375 38 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 ':> 34 140 315 32 34 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 34 140 315 32 34 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10.4 MMB 77 67 68 93 120 12 1 88 259 31 0 . 7 017 19WE0161 Hot oil heater, 19 .33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 .3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 30362 14458 145 1446 2892 216872 0 . 29 #/## 133 .8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 ' ' 5292 143 6 3 .4 0 .0 APEN-Exempt / Insignificants 0 .0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 56.8 4.3 2.5 17.4 12. 9 0.7 1 .5 10. 6 110. 3 0.9 0.7 0.6 0.2 219 .4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0162. CP1 9/13/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) _ POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene L`° TOTAL (tPY) IPreviousFACtL1ThhTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 1 0 . 2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr f -\ 46 108 59 127 21 0 . 5 003 cancelled Flare 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 i 12 1 . 2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 • 12 1 .2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 .2 008 19WE0152 Caterpillar G3512B , sn: TBD 009 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 9 37 82 0 . 9 010 19WE0154 Caterpillar G3608 , sn : TBD 772 1 627 386 98 612 21 83 188 1 .4 011 19WE0154 Caterpillar 63608 , sn : TBD r` 012 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 188 1 .4 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 015 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 17 1 . 9 016 19WE0160 Heater for dehy regen , 10 .4 MMB 77 67 1 68 93 192 120 161 88 259 189 31 0 . 7 017 19WE0161 ' Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 1 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 .3 1518 723 72 145 10844 0 .01 72 6 . 7 020 19WE0164 Plant Flare 108 108 22 540 32 1 I 0 .2 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 i 743 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 5. 9 2.2 1 . 3 1 .4 2.7 0.6 0.5 1 .6 6.3 0.8 0.0 0.6 0.2 24 . 03 6 19WE0162 .CP1 9/13/2019 isCOLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE01 62 Issuance: 1 Date issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description One-(1) natural gas heater (Make: TBD, Model: TBD, Serial Number: TBD) with H-570 O18 a design heat,.input rate of 24.3 None MMBtu/hr. This unit is equipped with low-NOx burners. This unit is used as a hot oil heater for the cryo unit. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify Page 1 of 13 aCOLORADO 411 - Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. Point 018: The following information must be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit: • Manufacturer • Model number • Serial number This information must be included with the Notice of Startup submitted for the equipment. {Regulation Number 3, Part B, 'III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Reference:!Regulation Number 3, Part B, Section II.A.4) Monthly Limits: AIRS Pounds per Month Emission Equipment ID Point PM2.5 NO,t VOC CO Type H-570 018 --- 452 97 741 Point Note: Monthly limits are based on a 31-day month. The owner or operator must calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant must not exceed 1,359 pounds per month. Facility-wide emissions of total hazardous air pollutants must not exceed 4,006 pounds per month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 13 „y. COLORADO Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type,t H-570 018 --- 2.7 0.6 4.4 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 must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 23.6 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. During the first twelve(12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 25 tons per year of total hazardous air pollutants (HAP). PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Page 3 of 13 AO _ COLORADO Air Pollution Control Division COPME Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit Monthly Limit ID Point (31 days) H-570 018 Consumption of 217.0 MMscf 18.4 MMscf natural gas as a fuel The owner or operator must calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Point 018:_ The owner or operator must continuously monitor and record the volumetric flow rate of natural gas combusted as fuel for this heater using an operational continuous flow meter at the inlet. The owner or operator must use monthly fuel consumption records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten-digit AIRS ID number assigned by the Division (e.g. 123/9DF7/xxx) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 13. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions must not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation Number 1, Section II.A.1. 8 4.) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. This source is subject to the New Source Performance Standards requirements of Regulation Number 6, Part A Subpart Dc, Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units including, but not limited to, the following: a) The owner or operator of the facility must record and maintain records of the amount of fuel combusted during each month (40 CFR 60.48c(g)). Page 4 of 13 a COLORADO 4444- 1- Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado b) Monthly records of fuel combusted required under this permit condition must be maintained by the owner or operator of the facility for a period of two years following the date of such monthly record (40 CFR Part 60.48c(i)). 16. This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of Regulation 1, and the New Source Performance Standards requirements of Regulation 6, Part B, including, but not limited to, the following: No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel- burning equipment, particulate matter in the flue gases which exceeds the following (Regulation 1, Section III.A.1 and Regulation 6, Part B, Section II): i. For fuel burning equipment with designed heat inputs greater than 1x106 Btu per hour, but less than or equal to 250x106 Btu per hour heat input, the following • equation will be used to determine the allowable particulate emission limitation. PE = 0.5(FI)-os6 Where: PE = Particulate emissions in pounds per million Btu heat input. Fl = Fuel input in million Btu per hour. ii. Greater than 20 percent opacity. (Regulation Number 6, Part B, II.C.3) 17. This source is subject to the requirements of Regulation Number 6, Part A, Subpart A, General Provisions, including but not limited to the following: a) At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40 CFR 60.11(d)) b) No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (560.12) c) Written notification of construction and initial startup dates shall be submitted to the Division as required under 560.7. d) Records of startups, shutdowns, and malfunctions shall be maintained, as required under §60.7. e) Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under§ 60.7. f) Excess Emission and Monitoring System Performance Reports shall be submitted as required under § 60.7. Page 5 of 13 4 .. . COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado g) Performance tests shall be conducted as required under §60.8. h) Compliance with opacity standards shall be demonstrated according to § 60.11. OPERATING Et MAINTENANCE REQUIREMENTS 18. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. Point 018: A source initial compliance test shall be conducted on this heater to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shalt have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation Number 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Periodic Testing Requirements 20. This source is not required to conduct periodic testing,unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one(1)ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. Page 6 of 13 COLORADO �ii� Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 23. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Maximum Number of Facility Equipment Allowable Combined Hours Engines in Operation IDs AIRS Points of Operation Per Year at Any Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 24. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) Page 7 of 13 -rMy., COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 26. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Fac Emissions - tons per year ility AIRS Equipment Pollutant Current Equipment Point Description Threshold Permit iD Limit SP300-10, 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater %:VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 8 of 13 • .~. - COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Fac Emissions - tons per year ility AIRS Equipment Pollutant Current Equipment Point Description Threshold Permit ID Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 ` 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 27. 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. 28. 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 Page 9 of 13 COLORADO Air Pollution Control Division Department of PubUc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 29. 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. 30. 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. 31. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or .operator of a source may request a hearing before the AQCC for review of the Division's action. 32. 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. 33. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 13 COLORADO Ito Air• Pollution Control Division ® Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing 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 Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (!b/yr) (lb/yr) Formaldehyde 50000 180 180 Benzene 71432 159 159 Toluene 108883 216 216 Ethylbenzene 100414 450 450 018 Xylenes 1330207 281 281 n-Hexane 110543 376 376 2,2,4-Trimethlpentane 540841 605 605 Styrene 100425 443 443 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 11 of 13 g COLORADO Air Pollution Control Division �ii�� Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Emission Pollutant CAS # Factors Source lb/MMscf PM10 7.3094 AP-42 Table 1.4-2 PM2.5 7.3094 AP-42 Table 1.4-2 SOx 0.577 AP-42 Table 1.4-2 NOx 24.525 Manufacturer (Tulsa Heaters Midstream) CO 40.221 Manufacturer (Tulsa Heaters Midstream) VOC 5.2897 AP-42 Table 1.4-2 Formaldehyde 50000 0.8280 GRI Field Test Benzene 71432 0.7338 GRI Field Test Toluene 108883 0.9970 GRI Field Test Ethylbenzene 100414 2.0727 GRI Field Test Xylenes 1330207 1.2954 GRI Field Test n-Hexane 110543 1.7312 AP-42 Table 1.4-3 2,2,4-Trimethtpentane; 540841 2.7878 GRI Field Test Styrene 100425 2.0394 GRI Field Test Note: Emission factors are based on a fuel heat value of 981 Btu/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO 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://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources Page 12 of 13 .�•�„. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 13 of 13 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engireer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Ma Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 31 Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: S N quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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 Matte- (PM) is Ozone (NOx & VOC) Section 02 - Emissions Un is In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks Liquid Loading SP300-10 Yes 19WE0165 CP1 Yes Permit Initial Issuance APEN Required 0C2 NG Heater HTR-703 No 15WE1029.XP XP No / Permit 0C4 Natural Gas RICE C-601 Yes 19WE0148 Yes - 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 0C6 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE 0-410 _ Yes 19WE0152 Yes - 009 Natural Gas RICE C-411 Yes 19WE0152 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0154 Yes 012 Natural Gas RICE C-653 Yes 19WE0154 Yes Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0157 Yes 015 Natural Gas RICE G-773 Yes 19WE0157 Yes - 016 NG Heater H-310 No _ 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas rocessinplant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissionsgreater than 40 tpy, P g Y q q and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previou sly approved to operate under GP07 and is now moved to an indivicual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required ? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air impact Analysis Requirement Was a quantitative modeling analysis required? Yes If yes, for what pollutants' NO; PM2.5 If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a :rue minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: Sr I., NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) . Title V Operating Permits ' OP) ./1 .,/ . J Non-Attainment New Sou-ce Review (NANSR) - J Is this stationary source a major source? If yes, explain what programs and which pollutants her( SO2 NOx ( O VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits OP) IR I_ ■ ■ Non-Attainment New Sou-ce Review (NANSR) Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Aka Energy Group, LLC Permit Number: 19WE0163 Source Location: SW Section 31 T4N R65W Equipment Description: Amine sweetening unit AIRS ID: 123-9DF7-019 Date: 3/28/19 Review Engineer: Andy Gruel Control Engineer: Section 2=Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered"no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? 2/11/2019 Section 4—Source Description AIRS Point Equipment Description One(1) Methyldiethanolamine (MDEA) natural gas sweetening system for acid gas removal with a design capacity of 60 MMSCF per day(make, model, serial number: TBD). 019 This emissions unit is equipped with two(2) amine recirculation pumps (make, model: TBD)with a total design capacity of 209 gallons per minute. This system includes a natural gas/amine contactor, a flash tank, and a natural gas fired amine regeneration reboiler. All emissions are routed to an enclosed combustor. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria x Yes No pollutant? If"yes", for what pollutant? PMio CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PMio CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Page 1 Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 019 Site-specfic using Promax Simulation Model (refer to Section 14 for calculations) Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 019 21900 MMscf per year of sour gas throughput, 209 gallons per minute lean amine circulation rate Basis for Actual Emissions Reported During this APEN Filing(Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 019 21900 MMscf per year of sour gas throughput, 209 gallons per 2020 minute lean amine circulation rate Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 019 21900 MMscf per year of sour gas throughput, 209 gallons per minute lean amine circulation rate Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 019 01 Combustor 95 I Section 6—Emission Summary(tons per year) Point PM10/ "NO VOC CO Single HAP Total HAP PM2.5 PTE: 019 2.8 5.0 289.2 42.5 108.44 (Methanol) 133.8 Uncontrolled point 019 2.8 5.0 289.2 42.5 108.44(Methanol) 133.8 source emission rate: Controlled point 019 2.8 5.0 14.5 42.5 5.42 (Methanol) 6.7 source emission rate: Total APEN Reported 2.8 5.0 14.5 42.5 5.42 (Methanol) 6.7 emissions: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Emission Rate Pollutant CAS# (Ib/yr) Controlled Emission Rate(lb/yr) Benzene 71432 30362 1518 Toluene 110543 14458 723 Ethylbenzene 100414 145 7 Xylenes 1330207 1446 72 n-Hexane 110543 2892 145 2,2,4-Trimethylpentane 540841 0.29 0.01 Methanol 67561 216872 10844 Hydrogen Sulfide 7783064 1446 72 Page 2 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 019 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack Test HAPS Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? VOC,CO, HAPs for Reg. 3, Part B, III.C.1.a (emissions increase>25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient X Yes No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? NOx, PM2.5 AIRS Point Section 12—Regulatory Review Regulation 1 -Particulate,Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, 019 Appendix A(July, 1992)) in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases 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 2—Odor Page 3 Section LA-No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are 019 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 3-APENs. Construction Permits, Operating Permits, PSD Part A-APEN Requirements 019 Criteria Pollutants: Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 019 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section Il.D.3.a) Regulation 6-New Source Performance Standards, NSPS LLL: Each sweetening (amine) unit and each sweetening unit followed by a 019 sulfur recovery unit; manufacturer date after January 24, 1984. Applicant is not subject to NSPS LLL because subject to NSPS OOOOa. NSPS OOOOa: Each sweetening (amine) unit and each sweetening unit followed by a sulfur recovery unit at a natural gas processing plant; construction date after 9/18/15. Applicant is subject to NSPS 0000a because ... 019 • The facility is a natural gas processing plant and the construction date is after 9/18/2015, therefore, source is subject to this subpart. However, because the facility have a design capacity less than 2 long tons/day H2S in the acid gas based on the information submitted in the application. This source will be required by 60.5423a(c)to keep for the life of the equipment an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2S expressed as sulfur. No other requirements apply. Regulation 7—Volatile.Organic Compounds 019 None Regulation 8 Hazardous Air Pollutants 019 None Section 13: see after Section 14 (tables in .docx moved around unexpectedly and couldn't be fixed) Page 4 Section 14—Miscellaneous Application Notes AIRS Point 019 Amine Unit Uncontrolled emissions were modeled using ProMax based on a sour gas inlet rate of 61.6860 MMscfd. This 61.6860 MMscfd is slightly larger than the requested daily limit, which will result in conservative emission factors. Flash tank and acid gas vapors are combined and combusted in a dedicated combustor. Combined emissions are modeled in the"10"stream in the ProMax model provided by the applicant in the Feb 11 2019 application. The model output of the"10" stream reports the concentration of VOC and HAPs in terms of mass fraction. The applicant added a safety buffer by rounding the VOC and HAP concentrations up slightly, as shown in the table below. The mass fractions are then multiplied by the gas quantity(including the pilot gas)to arrive at a lb/MMscf emission factor. Operating hours: 8760 hr/yr Pilot gas: specified by applicant as 80 scf/hr. Flared gas quantity: 84429.583 scf/hr(from Stream "10") Total gas quantity: 84509.583 scfh. =740,303,947 scf/yr Gas molecular weight 37.0700 Ib/Ibmol(from Stream "10") Gas heat content: 208.938 Btu/scf(from Stream "10") Molar volume of gas: 379.62 scf/mol (calculated by applicant from ideal gas constant) Uncontrolled emissions calculated by: Mass fraction *Total Gas quantity/Molar volume of gas*Gas molecular weight/2000 lb/ton Uncontrolled emission factor is calculated by: Uncontrolled Emissions (Ib/yr)/ 60 MMscf/yr Mass Fraction Mass Calculated Uncontrolled Emission Factor from Stream Fraction Uncontrolled (lb/MMscf) "10" Assumed by Emissions Applicant VOC 0.00788 0.0080 289.16 tpy 9638.7631 Benzene 0.00037 0.00042 30362.2 lb/yr 506.0351 Toluene 0.00017 0.0002 14458.2 lb/yr 240.9691 Ethylbenzene 0.0000012 0.000002 144.6 lb/yr 2.4097 Xylenes 0.000018 0.00002 1445.8 lb/yr 24.0969 n-Hexane 0.00003 0.00004 2891.6 lb/yr 48.1938 2,2,4-TMP 0.00000000355 0.000000004 0.3 lb/yr 0.0048 Methanol 0.00281838 0.003 216872.7 lb/yr 3614.5362 H2S 0.0000188359 0.00002 1445.8 lb/yr 24.0969 The amine combustor is granted a control efficiency of 95%. Emissions from combustion at the flare are calculated as follows. Emission factor sources are provided below the table. The heat content of the waste gas is assumed to be 209 Btu/scf(includes assist gas), which is a conservative rounding-up of the Promax modeled heat content of 208.938 Btu/scf. Page 5 Fiore Emissions Emission Factor Pollutant Emission Factor Potential Emissions (Ib/MMscf sour gas) NO 0.0641 lb/MMBtu b 1.13 Ib/hr 5.0 ton/yr 0.4529 CO 0.5496 lb/MMBtu b 9.71 lb/hr 42.5 ton/yr 3.8829 TSP/PM10/PM2.5 0.00745 lb/MMBtu 0.13 lb/hr 0.576 ton/yr 0.0526 SO2 1.76E-02 lb/MMBtu d P 0.31 lb/hr 1.4 ton/yr 0.1243 Formaldehyde 0.00028 Ib/MMBtu a 0.0049 lb/hr 43 lb/yr 0.0020 u Emission factors for flares firing low BTU gas(<1,000 BTU/scf)from"Flares and Vapor Oxidizer?,Texas Natural Resource Conservation Commission,Pubication RG-109,Table 4. c Emission factor for external natural gas combustion from AP-42 Table 1.4-2(7/98 rev.),divided by 1020 Btu/scf per Footnote(a)of that table.All PM is expected to be<1 micron diameter,and the PM10 emission factor therefore also provides an estimate of PM and PM2.5 emissions. d SO2 emission factor calculated based on 0.002 wt%H2S in flared gas converted 100%to SO2 from combustion. Q Emission factor for flare from'Technical Guidance Package for Chemical Sources:Flare Sources",Texas Natural Resource Conservation Commission,New Source Review Division,July 1996,as presented in GRI HAPCalc 3.0 This amine unit has a reboiler(19.33 MMBtu/hr) permitted at Point 017 under 19WE0161. Section 13—Aerometric Information Retrieval System Coding Information Uncontrolled Pollutant/ Fugitive Emission Control Point Process Process Description Emission CAS# (Y/N) Factor Source (nt Factor 9638.7631 VOC Ib/MMscf 0.4529 NOx Ib/MMscf 3.8829 CO lb/MMscf 0.0526 PM10 lb/MMscf 0.0526 PM2.5 Ib/MMscf 0.1243 SOx lb/MMscf ProMax 24.0969 Hydrogen Process Amine Unit lb/MMscf Sulfide No Simulator 95 019 506.0351 Benzene/ based on lb/MMscf 71432 representative 240.9691 Toluene/ sample lb/MMscf 108883 2.4097 Ethylbenzene lb/MMscf /100414 24.0969 Xylenes/ lb/MMscf 1330207 48.1938 n-Hexane/ lb/MMscf 110543 0.0048 224-TMP/ lb/MMscf 540841 3614.5362 Methanol/ lb/MMscf 67561 SCC 31000305—Gas Sweetening; Amine process Emission factors include flash tank and still vent and that factors are based on natural gas processing of 21900 MMscf/yr. Page 6 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group,_LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2.1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 Previous taken from May 2018 tab Previous Permitted Facility total 0.0 0.0 0.0 h 0.0 0. 6 94. 1 0.0 1. 1 0. 7 0.0 0.0 0.0 0.0 0.6 12.9 0.0 1. 1 0.2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE102.9.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" 003 '; C`&1lO.ds tinder new h3ciI dry ca!7; quration 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601" 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5, 0.5 0.0 6.7 3.03 2.51 1 .2_"C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 , 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" 008 19WE0152 Caterpillar G3512B, sn: TBD "C-410" Requested combined limit of 8760 hr/yr 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411" 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-652 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G35160, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771" Requested combined limit of 17520 hr/yr between points 013,014,and 015. 014 19WE0157 Caterpillar G3516O, sn: TED 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-772 015 19WE0157 Caterpillar G3516C, sn: TBD "G-773" _ 016 19WE0160 Heater for dehy regen, 10.4 MMBtu/hr 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" 017 19WE0161 Hot oil heater, 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" _ 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991" 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8 0.5 "LEAKS" ' PEN-Exempt / Insignificants 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7.4 7. 4 0.0 1. 8 80. 6 755.9 99.2 447.5 219.0 7.4 7.42 0.0 1. 8 80.6 73. 8 9.8 86.5 23.6 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 7.4 7.4 0.0 1.8 80.0 60. 9 9.8 85.4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Paw 1 of 3 Printed 9/17/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene ' `-' ' '''("e"` TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0. 2 002 15WE1029.XP Hot oil heater, 6. 96 MMBtu/hr 46 129 108 59 1 127 21 0. 5 004 19WE0148 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 4 25 100 225 23 24 7. 0 005 19WE0149 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 4 25 100 225 23 24 7. 0 006 19WE0150 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 4 25 100 225 23 24 7. 0 007 19WE0151 Caterpillar G3516J , sn: TBD 11460 753 463 117 734 4 25 100 225 23 24 7. 0 008 19WE0152 Caterpillar G3512B, sn: TBD 9395 550 338 85 536 3 18 73 164 16 18 5. 6 009 19WE0152 Caterpillar G3512B, sn: TBD 0. 0 010 19WE0154 Caterpillar G3608, sn: TBD 7725 1255 771 195 1223 6 41 167 375 40 5. 9 011 19WE0154 Caterpillar G3608, sn: TBD 7725 1255 771 195 1223 6 41 167 375 40 5. 9 012 19WE0154 Caterpillar G3608, sn : TBD 013 19WE0157 Caterpillar G3516C, sn: TBD 21259 1054 648 164 1027 5 34 140 315 34 12.4 014 19WE0157 Caterpillar G3516C, sn : TBD 21259 1054 648 164 1027 5 34 140 315 34 12.4 015 19WE0157 Caterpillar G3516C, sn : TBD 016 19WE0160 Heater for dehy regen, 10.4 MMBtu/hr 77 67 68 93 192 120 161 88 259 189 31 0. 7 017 19WE0161 Hot oil heater, 19. 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening, 60 MMscfd 43. 3 30362 14458 145 1446 2892 216872 0.29 1446 133. 8 020 19WE0164 Plant Flare 2161 2161 22 i 432 10805 648 22 8. 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3.4 0. 0 APEN-Exempt / Insignificants 0. 0 0. 0 0. 0 0. 0 TOTAL (tpy; 56.8 4.3 2.5 17.4 12.9 0.7 1 .5 10.6 110.3 0.9 0.7 0.6 0.2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 2 1239DF7 9/ 17/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls ( lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene 13butadene TOTAL (toy) IPreviousFAC1L1TYTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0. 2 002 15WE1029.XP Hot oil heater, 6. 96 MMBtu/hr 46 129 5' 1 21 0. 5 -: ,ice/fed 004 19WE0148 Caterpillar G3516J . sn: TBD 1146 376 231 59 367 2 50 113 11 12 1 . 2 005 19WE0149 Caterpillar G3516J . sn: TBD 1146 376 231 59 367 2 50 113 11 12 1 . 2 006 19WE0150 Caterpillar G3516J , sn: TBD 1146 376 231 59 367 2 50 113 11 _ 12 1 . 2 007 19WE0151 Caterpillar G3516J , sn: TBD 1146 376 231 59 367 2 50 113 11 12 1 . 2 008 19WE0152 Caterpillar G3512B, sn: TBD 939 275 169 268 1 37 82 89 0. 9 009 19WE0152 Caterpillar G3512B, sn: TBD 010 19WE0154 Caterpillar G3608, sn : TBD 772 627 386 98 612 3 83 188 1 . 4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 83 188 1 .4 012 19WE0154 , Caterpillar G3608, sn : TBD 013 19WE0157 Caterpillar G3516C . sn : TBD 2126 527 324 82 514 3 70 158 1 . 9 014 19WE0157 Caterpillar G3516C, sn : TBD 2126 527 324 82 514 3 17 70 158 I . 1 . 9 015 19WE0157 Caterpillar G3516C, sn : TBD 016 19WE0160 Heater for dehy regen, 10.4 MMBtu/hr 77 67 68 93 192 120 161 88 259 189 31 0. 7 017 19WE0161 Hot oil heater. 19. 33 MMBtu/hr 143 125 127 172 358 224 299 163 H1 352 58 1 . 3 018 19WE0162 Hot oil heater. 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening. 60 MMscfd 43. 3 1518 723 7 72 145 10844 0.01 72 6. 7 020 19WE0164 Plant Flare 108 108 1 22 540 32 1 0. 4 021 19WE0166 Facility fugitive equipment leaks 65 67 1 743 1 0. 5 _ 0. 0 APEN-Exempt / Insignificants 0. 0 0. 0 0. 0 0. 0 TOTAL 'tpy) 5.9 2.2 1 . 3 1 .4 2.7 1 0.6 0. 5 1 .6 6.3 0.8 0.0 0.6 0.2 24. 03 3 1239DF7 9/ 17/2019 g COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE01 63 Issuance: 1 Date issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS ` Emissions Control Equipment Equipment Description ID Point Description One (1) Methyldiethanolamine (MDEA) natural gas sweetening system for acid gas removal with a design capacity of 60 MMscf per day (make, model, serial number: TBD). This emissions unit is equipped with two (2) amine recirculation AMINE 019 pumps (make, model: TBD) with a total design Enclosed Flare capacity of 209 gallons per minute. This system includes a natural gas/amine contactor, a flash tank, and a natural gas fired amine regeneration reboiler. The reboiler (AIRS Point 017) is rated at 19.33 MMBtu/hr. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. 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 No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. Page 1 of 13 a COLORADO 4440 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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 per Regulation No. 3, Part B, II I.F.4.b. (Reference: Regulation No. 3, Part B, I I I.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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this,permit. • Amine sweetening system: o Manufacturer, model number, and serial number. • Amine recirculation pumps: a Manufacturer, model number, quantity, and capacity (gallons per minute). This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS Pounds per Year Equipment ID Point SO2 NOx VOC CO Emission Type AMINE 019 232 843 2,456 7,222 Point (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Page 2 of 13 g - ., COLORADO jAir Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Annual Limits: Facility AIRS Tons per Year Equipment ID Point S02 N0x V0C CO Emission Type AMINE 019 1.4 5.0 14.5 42.5 Point 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 be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimus reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve- month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall be less than: • 25 tons per year of total hazardous air pollutants (HAP). 9. Compliance with the emission limits in this permit shall be demonstrated by running the ProMax model on a monthly basis using the most recent amine unit inlet extended gas analysis and recorded operational values (including gas throughput and lean amine recirculation rate). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into ProMax. Page 3 of 13 t COLORADO jAir Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 10. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID AMINE 019 Enclosed combustor VOC and HAPs PROCESS LIMITATIONS AND RECORDS 11. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual natural gas processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Equipment Process Parameter Limit (31 ID Point Limit days) Natural gas throughput 21,900 1,860 AMINE 019 MMscf/yr MMscf/month Combustion of waste gas and pilot 740.3 62.9 gas MMscf/yr MMscf/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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. 12. This unit shall be limited to the maximum lean amine recirculation pump rate of 209 gallons per minute. The lean amine recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) STATE AND FEDERAL REGULATORY REQUIREMENTS 13. The permit number and AIRS ID point number (i.e., 123/9DF7/019) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) Page 4 of 13 ».,. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 14. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &t 4.) 15. 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. (Reference: Regulation No. 1, Section II.A.5.) 16. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 17. The inlet gas stream to the amine unit shall have a total sulfurs concentration, including H2S, of less than or equal to 20 ppm. OPERATING Et MAINTENANCE REQUIREMENTS 18. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your 0&tM plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) 19. The inlet gas temperature and inlet gas pressure shall be measured and recorded weekly. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5) 21. The owner or operator shall complete the initial sour gas analysis testing required by this permit and submit the results to the Division as part of the self-certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III.E.) 22. A source initial compliance test shall be conducted on emissions point 019 to measure the emission rates for the pollutants listed below in order to demonstrate compliance with the emission limits, amine recirculation rate limit, and gas throughput limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. All test results must be submitted to the Division as a Compliance Test Report in accordance with the requirements of the Compliance Test Manual. (Reference: Regulation No. 3, Part B., Section III.G.3) Sulfur Dioxide using EPA approved methods. Oxides of Nitrogen using EPA approved methods. Page 5 of 13 is .r.-- COLORADO �3i_' Air Pollution Control Division wag Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Volatile Organic Compounds using EPA approved methods. Carbon Monoxide using EPA approved methods. Hazardous Air Pollutants using EPA approved methods to include: Methanol, Benzene, Toluene, Ethylbenzene, Xylenes, n-Hexane, and Hydrogen sulfide Periodic Testing Requirements 23. The operator shall sample the inlet gas to the amine unit on an annual basis to determine the concentration of hydrogen sulfide(H2S)in the gas stream. The sample results shall be monitored to demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: S02 Emissions (S60.640(b)). The sample results shall also be monitored to demonstrate compliance with the limit for total sulfurs concentration, including H2S. The testing required by Condition 24 may be used for this demonstration. 24. The owner or operator shall complete an extended sour gas analysis prior to the inlet of the amine unit on an annual basis. Results of the sour gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit. ADDITIONAL REQUIREMENTS 25. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April oh whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Page 6 of 13 COLORADO Air Pollution Control Division CDPHE Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 26. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 27. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Maximum Number of Facility Equipment Allowable Combined Hours Engines in Operation IDs AIRS Points of Operation Per Year at Any Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 28. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 29. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 30. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August Page 7 of 13 a,. T COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oli heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 Page 8 of 13 COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oli heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4 AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 31. 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 U.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 32. 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. 33. 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. Page 9 of 13 COLORADO *40114011- Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 34. 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. 35. 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. 36. 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. 37. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 10 of 13 g ,..1,,, COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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 h.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aocc-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. Uncontrolled Are the Controlled AIRS Emission Rate emissions Emission Rate Point Pollutant CAS # (Ib/yr) reportable? (lb/yr) Benzene 71432 30,362 Yes 1,518 Toluene 108883 14,458 Yes 723 Ethylbenzene 100414 145 No 7 Xylene 1330207 1,446 Yes 72 019 n-Hexane 110543 2,892 Yes 145 Methanol 67561 216,873 Yes 10,844 2,2,4-Trimethylpentane 540841 0.3 No 0.01 Hydrogen Sulfide 7783064 1,446 Yes 72 Page 11 of 13 �•-�� COLORADO Ito Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The VOC and HAP emission levels contained in this permit are based on the ProMax simulation model using an assumed inlet gas analysis submitted with the permit application. NOx, CO, TSP/PM10/PM2.5, 5O2, and formaldehyde emission rates were calculated as follows: Pollutant Emission Factor. NO. 0.0641 Ib/MM13tu CO 0.5496 lb/MMBtu b TSP/PM10/PM2.cr 0.00745 lb/MMBtti SO2 3,76E-02 lb/MMBtu a Formaldehyde 0.00028 Ib/MM8tu' tt Emission factors for flares firing low 8711 gas(<1,000 8T0/scf}from"Flares and Vapor Oxidizers",Texas Natural Resource Conservation Commisst,Publication RG-109,Table 4. Emission factor for external natural gas combustion from AP-42 Table 1.4-2(7/98 rev.),divided by 1020 8tu/scf per footnote la}of mat table, Al'PM is expected to be<1 micron diameter,and the PM10erniss on factor therefore also provides an estimate of PM and PM2.S emissions. SO2 emission factor calculated based on 0.002 wt%H25 in flared gas converted 100%to SO2 from combustion. 'Emission factor for flare from*Technical Guidance Package for Chemical Sources:Flare Sources".Texas Natural Resource Conservation Commission,New Source Review Division,July 1996,as presented in GRi HAPCak 3.0 Actual emissions of VOC and HAPs shall be calculated using ProMax on a monthly basis as described in this permit. Actual emissions of NOx, CO, TSP/PM10/PM2.5, SO2, and formaldehyde shall be calculated on a monthly basis using the lb/MMBtu emission factors listed above and the ProMax results for MMBtu heat content of combusted waste gases. 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 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.federalregister.gov/documents/20 gov/documents/2016/06/03/2016-11971/oil 1 6-1 1 97 1/oil-and-natural- gas-sector-emission-standards-for-new-reconstructed-and-modified-sources Page 12 of 13 a ,. ., COLORADO Ito Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC NSPS 0000a Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.gcfr.Rov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A- Appendix 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 10)A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self- certification Page 13 of 13 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Lne gy Group, LLC Quadrant Section Township Range County AIRS ID: 123 ` `' 1 Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) Q Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 001 Liquid Loading: SP300-10 Yt 19WE016S Yes Permit 1040 i ,u:, .. 002 NG Heater HTR-703 No 15WE1029.XP No APEN Required / Permit 004 Natural Gas RICE C-601 Yes 19WE0148 Yes 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes 19WE0151 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0152 Yes 010 Natural Gas RICE O-651 YE -. 19WE0154 Yes 011 Natural Gas RICE C-652 Yes 19WE0154 Yes 012 Natural Gas RICE C-653 Yes 19WE0154 Yes Permit Initia 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE 6-772 Yes 19WE0157 Yes 015 Natural Gas RICE G-773 Yes 19WE0157 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes — 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New naturai gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required Because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy ; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN tc revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Eet�1%k' CX'��< .y,'U,+'.."r.`.e_-«>ie ::rvTiC:e•, . 9r� -."6e�se.a1 A'.•" s+,.o ^. o-�. ..i.o-, o-sr•F.'b yc°h. M• a 'r a W-..�... ;i o;. a ♦ oty= ^1 'a ' 'A.,t 6.. x. <« _� :�. .. ..a"; ..•.r. r.. .�i. .. `r, is` ,., a 'at° . ,o;°Y`ae2e d:i'"Si'oa<'v sa.rdt s6 .OL O .. .� `"::+• ♦G�.:. .fit . .s• � s< ..-.:.� .:.. ^ z,: i ,.,.:r.'`�>x� < :.eF ..rc�'�;?cr— �7?::... . ... ......• ...<. a. ...<., y �.3; ,.�aA..; ., .4 .r .#.�. u.# sra rA+: ,y .; sr. � - - .r - a yu�,'•', '.v ` .. .1f o..@vr�iia°i+' tat. 1Y .�ir� .. 1 r 'Iv 'L gas .^ :[::5TH 11ae [ 1'a - t... i ;..r /v1 ro poi i 1 .rW V. ♦pyf[-$.,.'� °Je `S ,w' .* V' t4 3, :. '... r.. C�-y'�',,�y '.Via a `V . ia� O a�j.•o�. '� 'e��:a!o .'*6 2a�bd'�4.Fd' °Y° �O.�e�pRN��, �: ... .. : .. ., t <..:JE2.+Yd««aw�A.a:e'n'�l.�dA�uat°sar.a `ia. . iw� rs'Je �°.e3aae!c�° a ''0°≥°wooaSleL°« °ee�r", S J .:. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 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? 'es If yes, indicate programs and which pollutants: SO2 NOx� CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) J EA` R i_ ■ J Non-Attainment New Source Review (NANSR) J Is this stationary source a major source? No If yes, explain what programs and which pollutants her( SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) N 5 -- Title V Operating Permits (OP) •■ II Non-Attainment New Source Review (NANSR) Separator Venting Emissions Inventory 020 Plant Flare Facility AIRs ID: 12.3 9DF7 020 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Plant flare controls periodic equipment and facility blowdown events. Emission Control Device Description: Open flare. Requested Overall VOC & HAP Control Efficiency %: 95 Limited Process Parameter Natural Gas Vented Gas meter , „i, _ 'JAI be .a 'd . ,.r.:r ft a:. Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Plant Flare Actual Th-oughput = 42.1 MMscf per year Requested Permit Limit Throughput = 42.1 MMscf per year Requested Monthly Throughput = 4 MMscf per month Potential to Emit (PTE) Th-oughput = 42.1 MMscf per year Process Control (Recycling) Equipped with a VRU: No Is VRU process equipment: Secondary Emissions - Combustion Device(s) for Air Pollution Control Vented Gas Heating Value: "12: 2:;• Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Section 04 - Emissions Factors & Methodologies Description Applicant prepared a calculation of the nineteen (19) different gas streams that would be subject to blowdown, accounting for their operating pressure, temperature, density , and molecular weight to arrive at a per- blowdown volume of vapor. This was then multiplied by the anticipated quantity of blowdown events for each equipment type in a year to arrive at an anticipated annual volume of gas sent to the plant flare, This also included the pilot gas requirement of 80 scf/hr. The composition of the gas was assumed by the applicant conservatively using the inlet gas. The total combusted volume is expected to be comprised of 83.5% inlet gas and 15.6% residue gas/methane (with 0.8% propane and 0.05% associated with NGL blowdowns.) MW 19.5 Ib/Ib-mol assuming Ethane Rejection mode as worst-case Weight % n-Hexane 0.5 224-TMP 0.001 Benzene 0.1 Toluene 0.1 Ethylbenzene . ' :'.1 Xylenes 0.02 Methanol 0.03 Hydrogen Sulfide 0.0002 VOC 30.0 Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ib/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 15410.1470 770.5073 c iamt design model and engineering Galatia .. Benzene 51.3672 2.5684 Plant design model and engineering calcuiatbc Toluene 51.3672 2.5684 Plant design model and engineering c alcu₹atk Ethylbenzene 0.5137 0.0257 Plant. design model and engineering calculatic Xylene 10.2734 0.5137 Plans design model and engineering calculation n-Hexane 256.8358 12.8418 Hunt design model and engineering calculation 224 TMP 0.5137 0.0257 Plant design model and engineering calculation Methanol 15.4101 0.7705 . ' ant design model and engineering calculation Hydrogen Sulfide 0.1027 0.0051 c design model and engineering calculation Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 9.090 PM2.5 0.0075 9.090 SOx 0.0002 0.194 Other - Explain NOx 0.1380 168.360 TN RCC Flare Emissions Guidance (NC CO 0.2755 336.110 T NRCC Flare Emissions Guidance (_ .. 2 of 6 K:\PA\2019\19WE0164.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.19 0.19 0.19 0.191 0.191 32 PM2.5 0.19 0.19 0.19 0.191 0.191 32 SOx 0.00 0.00 0.00 0.004 0.004 1 NOx 334 334 3.54 3.54 _ 3.54 602 VOC 324.15 324.15 16.21 324.15 16.21 2753 CO 7.07 7.07 7.07 7.07 7.07 1201 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 2161 2161 108 2161 108 Toluene 2161 2161 108 2161 108 Ethylbenzene 22 22 1 22 1 Xylene 432 432 22 432 22 n-Hexane 10805 10805 540 10805 540 224 TMP 22 22 1 22 1 Methanol 648 648 32 648 32 Hydrogen Sulfide 4 4 0.2 4 0.2 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit. Regulation 7, Section XVII.B, G Not applicable. Regulation 7, Section XVII.B.2.e Not applicable. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Will the operator have a meter installed and operational upon startup of this point? No If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? 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 SOx emission factor is from "Technical Guidance Package for Chemical Sources: Flare Sources", Texas Natural Resource Conservation Commission, New Source Review Division, July 1996, as presented in GRI HAFCalc 3.0. Section 09 - Inventory SCC Coding and Emissions Factors Uncortrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 020 01 3-10-001-60 Flares PM10 9 09 0 Ib/MMSCF PM2.5 9 09 0 lb/MMSCF SOx 019 0 lb/MMSCF NOx 168.36 0 lb/MMSCF VOC 15410.15 95 lb/MMSCF CO 336.11 0 lb/MMSCF Benzene 51.37 95 lb/MMSCF Toluene 51.37 95 lb/MMSCF Ethylbenzene 0.51 95 lb/MMSCF Xylene 10.27 95 lb/MMSCF n-Hexane 256.84 95 lb/MMSCF 224 TMP 0.51 95 Ib/MMSCF Methanol 15.41 95 lb/MMSCF H idrogen Sulfide 0.10 95 lb/MMSCF 3 of 6 K:\PA\2019\19WE0164.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID _ 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS T VOC HAPs VOC HAPs AIRS Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 0.2 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 Previous taken from May 2018 tab Previous Permitted Facility total 0. 0 0.0 0.0 0.0 0. 6 94. 1 0.0 1. 1 0. 7 0.0 0.0 0. 0 0. 0 0. 6 12.9 0.0 1. 1 0. 2 ` 001 1 9WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1O29.X r Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0, 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "i IT/Ry-70,3 J� 1 003 :;aflcel:&d ' 1:7;!_-.' ,..?n e/h d under new facility conf cnir<ciffon 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0. 5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0. 5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" 008 "C-410" Requested combined limit of 8760 - 19WE0152 Caterpillar G3512B, sn: TBD 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 hr/yr between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/yr between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-652" 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 "G-771 " Requested combined limit of 17520 hr/yr between points 013.014,and 014 19WE0157 Caterpillar G3516C, sn: TBD "G-772" 015 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 , Hot oil heater. 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" -i 018 19WE0162 _Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4, 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 , Amine sweetening, 60 MMscfd t 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46, 42.52 6.7 "AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0, 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4 9.8, 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 0.0 , I 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7. 4 7. 4 0. 0 1 . 8 80. 6 755. 9 99. 2 447. 5 219. 0 14 7. 42 0.0 1.8 80. 6 73. 8 9. 8 86.5 23. 6 Excludes units exempt from (A) Change in Permitted Emissions 7. 4 7. 4 0.0 1. 8 80.0 60. 9 9. 8 85.4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 ;A) Change in Total Permitted VOC emissions (point and fugitive 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 • Page 4 of 6 Printed 9/18/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POIN1 PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S Styrene .a TOTAL (tpY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 . 2 002�jf 15V E1} 0t29 .XP Hot z Boil heater, 6 .96 MMBtu/hr 45 46 129 81 108 59 , 173 127 21 0 . 5 C/ 4 R..✓ :.Asnc ieeci Fier V �f /� � / J /Y-3 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 r 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 73 164 16 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar 63608 , sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 5 . 9 011 19WE0154 Caterpillar G3608, sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 140 t 315 32 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 140 315 32 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD 016 19WE0160 Heater for dehy regen , 10 .4 MMB 77 67 68 93 192 120 161 88 259 189 31 0 .7 017 19WE0161 Hot oil heater, 19. 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening , 60 MMscfd 43 .3 30362 14458 145 1446 2892 216872 0. 29 ### 133 . 8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8 . 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 r 3 .4 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 56.8 4.3 2.5 17.4 12. 9 0.7 1 .5 10.6 110.3 0.9 0.7 0.6 0. 2 219 .4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0164. CP1 9/18/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POIERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH N P 224 TMP H2S Styrene ' -"'It TOTAL (tpY) IPreviousFAC1LtTh' TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0. 0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr 51 46 62 129 81 1 (1 0 . 5 cancelled 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 12 50 113 12 1 . 2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 1 59 367 12 50 113 I 12 1 . 2 008 19WE0152 Caterpillar G3512B , sn : TBD 009 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 9 37 82 9 0 .9 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 188 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 83 188 20 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD I : 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 70 158 17 1 . 9 014 19WE0157 Caterpillar G3516O , sn : TBD •015 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 , 514 3 1 t` 70 158 17 1 . 9 016 19WE0160 Heater for dehy regen , 10 .4 MMB 77 67 I 68 93 192 120 161 88 259 v 189 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 a 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 .3 1518 723 7 72 145 10844 0 . 01 72 6 .7 020 19WE0164 Plant Flare 108 108 1 22 540 32 1 0 . 2 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 1 743 1 0 . 5 0 . 0 APEN-Lxempt / Insignificants 0 . 0 0 . 0 0 . 0 0 . 0 TOTAL (tpy) 5.9 2.2 1 .3 1 .4 2.7 0.6 0.5 1 .6 6.3 0.8 0.0 0.6 0.2 24 . 03 6 19WE0164. CP1 9/18/2019 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0164 Issuance: 1 Date issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment'Description Description Plant flare controls vented gas during FL-991 020 periodic equipment and facility Elevated Open Flare blowdown events. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 12 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit atone does not provide final authority for the operation of this source. EMISSION!LIMITATIONS AND RECORDS 6.6. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section I I.A.4) Monthly Limits: AIRS Pounds Per Month Emission Equipment ID Point PM2.5 NO VOC CO Type e FL-991 020 602 2753 1201 Point Note: Monthly limits are based on a 31-day month. The owner or operator must calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant must not exceed 1,359 pounds per month. Facility-wide emissions of total hazardous air pollutants must not exceed 4,006 pounds per month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type FL-991 020 --- 3.5 16.2 16.2 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Page 2 of 12 a COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 23.6 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an.Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 25 tons per year of total hazardous air pollutants (HAP). 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID FL-991 020 Elevated Open Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made Page 3 of 12 a COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit Monthly Limit ID Point (31 days) FL-991 020 Gas venting 42.1 MMscf/yr 3.6 MMscf/month The owner or operator must calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months',,data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented to the open flare using the flow meter. The owner or operator must use monthly throughput records and the calculation methods described in the O€tM Plan to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/9DF7/xxx) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (0&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 12 --ft COLORADO 4414. 1 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) •: Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources (NO.) in ozone nonattainmerlt 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. Page 5 of 12 aN•�M COLORADO Air Pollution Control Division �i Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 19. The exhaust stack(s) for the following emission points) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 10.1 C-653 012 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FE-991 ' 020 38.76 20. The following source groups are restricted to the following maximum annual hoursxf operation and maximum operating scenarios: Maximum Number of Facility Equipment Allowable Combined Hours Engines in Operation IDs' AIRS Points of Operation Per Year at Any Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 21. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 22. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) Page 6 of 12 COLORADO _ Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Emissions - tons per year AIRS Equipment Equipment Pollutant Current IDs Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil,heater VOC 100° , 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604, 007 Cat G3516J VOC 100 3.0 0-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oli heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 Page 7 of 12 isCOLORADO Air Pollution Control Division _ Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Emissions - tons per year AIRS Equipment Equipment Pollutant Current IDs Point Description Threshold Permit Limit HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B C0 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 C-652 011 Cat G3608 CO 100 8.7 C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater ' CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 : 018 Hot oil heater CO 100 4.4 -AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 24. 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. 25. 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 Page 8 of 12 g - :M COLORADO Mr Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. 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. 27. 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. 28. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 29. 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. 30. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 9 of 12 a .4, COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set,forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 2161 108 Toluene 71432 2161 108 Ethylbenzene 108883 22 1 020 Xylenes 100414 432 22 n-Hexane 110543 10806 540 Methanol 67561 648 32 2,2,4- 540841 22 1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 10 of 12 4 : 17. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMscf) (lb/MMscf) NOx 168.36 168.36 TNRCC Flare Emissions CO 336.11 336.11 Guidance VOC 15410.147 770.5073 71432 Benzene 51.3672 2.5684 108883 Toluene 51.3672 2.5684 100414 Ethylbenzene 0.5137 0.0257 Engineering 1330207 Xylene 10.2734 0.5137. calculation(see 110543 n-Hexane 256.8358 12.8418 : below) 67561 Methanol 15.4101 0.7705 540841 2'2'4 0.5137 0.0257 Trimethylpentane Note: NOx and CO emission factors are based on an assumed vented gas heat value of 1220 Btu/scf. VOC and HAP emission factors were calculated based on nineteen (19) different gas streams that would be subject to blowdown, accounting for their operating pressure, temperature, density, and molecular weight to arrive at a per-blowdown volume of vapor. This was then multiplied by the anticipated quantity of blowdown events for each equipment type in a year to arrive at an anticipated annual volume of gas sent to the plant flare, This also accounted for pilot gas requirements of 80 scf/hr. The composition of the gas was conservatively assumed to be equal to the inlet gas. The total combusted volume is expected to be comprised of 83.5% inlet gas and 15.6% residue gas/methane (with 0.8% propane and 0.05%associated with NGL blowdowns. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC Page 11 of 12 COLORADO 4.440 Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ -Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 12 of 12 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date : 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 SW 31 :N Plant AIRS ID: 9DF7 Facility Name: Speer Gas Plant Physical Address/Location: SW quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) . Parccula'e r•+atter (PM ./ Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks 001 Liquid Loading SP300-10 Yes I 19WE0165 Yes Permit Initial Issuance 002 NG Heater HTR-703 No 15WE1029.XP No APEN Required / Permit 004 Natural Gas RICE C-601 Yes 19WE0148 Yes _ 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-6C ` Yes _ 19WE0151 Yes 008 Natural Gas RICE C-410 (es 19WE0152 Yes 009 Natural Gas RICE C-411 Yes 19WE0153 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 Yes 011 Natural Gas RICE C-652 lies 19WE0155 Yes 012 Natural Gas RICE C-653 Yes 19WE0156 Yes Permit Initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0158 Yes 015 Natural Gas RICE G-773 Yes 19WE0159 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 Yes 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New natural gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy; the modeling report was submitted in February 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Yes If yes, for what pollutants? NOx, PM2.5 If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? . . - Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: sC) NOx CO VOC PM25 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) H i Title V Operating Permits (OP) I J I . l ■ J Non-Attainment New Source Review (NANSR) J Is this stationary source a major source? If yes, explain what programs and which pollutants hen SO? NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) ri R ■ Non-Attainment New Source Review (NANSR) Hydrocarbon Loadout Emissions Inventory 001 liquid Loading 123 9DF7 001 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Truck loadout of condensate. Description: Emission Control Device Vapor balance to storage tank, but the tank vapors are not controlled, so no control credit is granted. Description: Is this loadout controlled? Yes Collection Efficiency: 100.0 Control Efficiency: 0 Requested Overall VOC & HAP Control Efficiency %: 0.00 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 75,000 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = Barrels (bbl) per year Requested Permit Limit Throughput = 75,000 Barrels (bbl) per year Requested Monthly Throughput = 6370 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 75,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = Btu/scf Volume of waste gas emitted per year = scf/year Actual heat content of waste gas routed to combustion device = 0 MMBTU per year Requested heat content of waste gas routed to combustion device = 0 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Yes Does the hydrocarbon liquid loading operation utilize submerged fill? Yes The state default emissions factors may be used to estimate emissions. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (Ib/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 2.36E-01 2.36E-01 Condensate Loadout State E.F. Benzene 4.10E-04 4.10E-04 Condensate toas;out State E.F. Toluene Condensate Loadout State E.F. Ethylbenzene Condensate toadout State E.F. Xylene Condensate Loadout State E.F. n-Hexane 3.60E-03 3.60E-03 Condensate Loadout State E.F. 224 IMP Condensate toadout State E.F. Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM 10 PM2.5 SOx NOx CO 2 of 6 K:\PA\2019\19WE0165.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 PM2.5 SOx NOx VOC 8.85 8.85 8.85 8.F.i 8.850 15(,, CO Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 31 31 31 31 31 Toluene Ethylbenzene Xylene n-Hexane 270 270 270 224 TMP Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must be operated with submerged fill 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 The truck vapors are vapor balanced to a 60,000-gallon bullet tank. That tank is not controlled, and vents to atmosphere when tank pressure levels exceed 7 psig. 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Y Caa <rr . < .. < -�'.:. t Yg•kl.ti Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 001 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.000 0 lb/1,000 gallons transferred PM2.5 0.000 0 lb/1,000 gallons transferred SOx 0.0000 0 lb/1,000 gallons transferred NOx 0.000 0 lb/1,000 gallons transferred VOC 5.619 0 lb/1,000 gallons transferred CO 0.000 0 lb/1,000 gallons transferred Benzene 0.010 0 lb/1,000 gallons transferred n-Hexane 0.086 0 lb/1,000 gallons transferred 3 of 6 K:\PA\2019\19WE0165.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group, LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS T VOC HAPs VOC HAPs AIRS Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 , 94.3 0. 1 3.6 0.7 0.2 . 0.2 0.0 2. 1 13.2 0.0 3.6 0.2 Previous taken from May 2018 tab Previous Permitted Facility total 0. 0 0.0 0. 0 0. 0 0. 6 94. 1 _ 0.0 1. 1 0. 7 0.0 0. 0 0. 0 0. 0 0. 6 12. 9 0.0 1. 1 0. 2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.X Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" .;annce/iec. ;-ancelied under new facility configuration? 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601" - 005 19WE0149 Caterpillar G3516J, sn TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" 007 19WE0151 Caterpillar G3516J, sn. TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" "C-410" Requested combined limit of 8760 008 19WE0152 Caterpillar G3512B, sn: TBD 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 hr/yr between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TBD "C-411 " 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-851 " Requested combined limit of 17520 _ hr/yr betweenpoints 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD "C-652" 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 "C-653" 012 19WE0154 Caterpillar G3608, sn: TBD 013 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of _ 17520 hr/yr between points 013.014,and 014 19WE0157 Caterpillar G3516C, sn: TBD "G-772" 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 01 19WE0157 Caterpillar G3516C, sn: TBD _ "G-773" 016 19WE0160 Heater for dehy regen, 10.4 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 I-lot oil heater, 19.33 MMBtu/hr 0.6 0.6 0. 1 , 2. 1 0.5 3.5 1 .3 0.6, 0.6 , 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8, 0.8 0. 1 2.7 0.6 4.4 1 .6_ 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfci , 0.6 0.6 1 .4 5.0 289.2 42.5_ 133.8 0.6 0.6 1 .4 5.0_ 14.46 42.52 6.7_"AMINE" 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 Facility fugitive equipment leaks 99.2 3.4, 9.8 0.5, "LEAKS" APEN-Exempt / Insignificants 0.0 _ 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8 81 .7 74.0 9.8 89.0 24.0 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH, & Total 7777: Syn Minor Permitted Facility Total 7.4 , 14 , 0. 0 . 1. 8 , 80. 6_ 755. 9 99. 2 4415 219.0 7. 4 7. 42 0.0 _ 1. 8 80. 6 73. 8 9. 8 86.5 23. 6 Excludes units exempt from (A) Change in Permitted Emissions 7. 4 7. 4 0.0 1. 8 80. 0 60. 9 9. 8 85.4 Pubcom required. Modeling required for NOx and PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 'A; Change in Total Permitted VOC emissions (point and fugitive', 70. 7 Note 1 lnsignificants tracking required for Total HAPs. Note 2 Page 4 of 6 Printed 9/11/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled ( lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene ' I'd' TOTAL (tpY) IPrevIousFACILITYTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0.2 _ 002 15WE1029.XP Hot oil heater, 6. 96 MMBtu/hr 46 129 81 59 0. 5 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7.0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7. 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 _ 4 25 100 225 23 24 7. 0 008 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 164 16 18 5.6 009 19WE0152 Caterpillar G3512B , sn : TBD 0 . 0 010 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 195 1223 41 i 375 40 5. 9 011 19WE0154 Caterpillar G3608 , sn : TBD 7725 1255 771 1223 375 5. 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 140 315 12.4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 140 315 - 12.4 015 19WE0157 Caterpillar G3516C , sn : TBD ID I 016 19WE0160 Heater for dehy regen , 10.4 MMBt 77 67 68 93 192 120 161 88 259 189 0. 7 017 19WE0161 Hot oil heater, 19. 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 1 .3 018 19WE0162 Hot oil heater, 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43. 3 30362 14458 145 1446 2892 216872 0.29 1446 133.8 I 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 8. 1 021 19WE0166 Facility fugitive equipment leaks 567 580 8 127 5292 143 6 3.4 0. 0 APEN-Exempt / Insignificants 0 . 0 0. 0 0 . 0 _ _ 0. 0 TOTAL (tpy) 56.8 4.3 2.5 17.4 12.9 0.7 1 .5 10.6 110.3 0.9 0.7 0.6 0.2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 5 19WE0165 . CP1 9/11/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls ( lbs per year) _ POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene " ' TOTAL (tPY) IPre\'jousFAClLlTYTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 1 31 270 0 . 2 002 15WE1029 .XP Hot oil heater, 6. 96 MMBtu/hr 46 108 21 0 . 5 003 catwalk , . 'fan 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 I 376 231 59 367 I 50 113 12 1 . 2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 I 231 59 367 50 113 12 1 . 2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 50 113 12 1 . 2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 50 113 12 1 . 2 008 19WE0152 Caterpillar G3512B , sn : TBD 009 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 37 82 9 0. 9 010 19WE0154 Caterpillar G3608 , sn : TBD 772 I 627 386 98 612 188 20 1 .4 011 19WE0154 i Caterpillar G3608 , sn : TBD 012 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 188 20 1 .4 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 70 158 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 015 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 17 70 158 1 r� 1 . 9 016 19WE0160 Heater for dehy regen , 10 .4 MMBt 77 67 68 93 192 120 161 88 259 189 31 0 . 7 017 19WE0161 Hot oil heater, 19 . 33 MMBtu/hr 143 125 127 172 358 224 2.99 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 . 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening , 60 MMscfd 43. 3 1518 723 7 72 145 10844 0. 01 72 6. 7 020 19WE0164 Plant Flare 108 108 1 22 540 32 1 1 0. 2 0 .4 021 19WE0166 Facility fugitive equipment leaks 65 67 1 743 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 0 . 0 0 . 0 0 .0 TOTAL (tpy ) 5.9 2.2 1 .3 1 .4 2.7 0.6 0.5 1 .6 6.3 0.8 0.0 0.6 0.2 24.03 6 19WE0165 . CP1 9/11/2019 jr, .R1. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE01 65 Issuance: 1 Date issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Equipment AIRS Emissions Control lD Point Equipment Description Description Truck loadout of condensate by SP300-10 001 None submerged fill. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 11 -�is ,_.•M COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Monthly Limits: AIRS Pounds per Month Emission Equipment ID Point PM2.5 NOX VOC CO Type SP300-10 001 --- --- 1503 --- Point Note: Monthly limits are based on a 31-daymonth. The owner or operator must calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant must not exceed 1,359 pounds per month. Facility-wide emissions of total hazardous air pollutants must not exceed 4,006 pounds per month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type X SP300-10 001 --- --- 8.9 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 23.6 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 11 �•:�M COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve(12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits.The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission;calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 25 tons per year of total hazardous air pollutants (HAP). PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit Monthly Limit ID Point (31 days) SP300-10 001 Condensate Loaded 75,000 barrels 6,370 barrels The owner or operator must calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. Page 3 of 11 . COLORADO 44.4°---41- Air Pollution Control Division a COPHE Department of Public Health&Enviror rent Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 9. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill. (Regulation Number 3, Part B, III.D.2) 12. All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 13. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, IIi.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, Leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. b.' All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. OPERATING &t MAINTENANCE REQUIREMENTS 14. This source is not required to follow a Division-approved operating and maintenance plan. 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. Page 4 of 11 • COLORADO ..M Air Pollution Control Division 41.7 Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: for any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annualactual 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. 18. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 Page 5 of 11 r�=M COLORADO Ihreilifi Air Pollution Control Division Department of Public Health&Envirorment Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 19. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Maximum Number of Facility Equipment Allowable Combined Hours Engines in Operat on IDs AIRS Points of Operation Per Year at Any Time C-410 and C-411 008,009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 17520 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 20. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 21. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient!air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 22. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B. With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 6 of 11 COLORADO Air Pollution Control Division . ,4i..., Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit SP300-10 001 Loadout VOC 100 8.9 HTR-703 002 Hot oil heater VOC 100 0.2 C-601 004 Cat G3516J VOC 100 3.0 C-602 005 Cat G3516J VOC 100 3.0 C-603 006 Cat G3516J VOC 100 3.0 C-604 007 Cat G3516J VOC 100 3.0 C-410 008 Cat G3512B VOC 100 4.6 C-411 009 Cat G3512B VOC 100 C-651 010 Cat G3608 VOC 100 C-652 011 Cat G3608 VOC 100 5.3 C-653 012 Cat G3608 VOC 100 G-771 013 Cat G3516C VOC 100 G-772 014 Cat G3516C VOC 100 10.9 G-773 015 Cat G3516C VOC 100 H-310 016 Dehy heater VOC 100 0.3 H-290 017 Hot oil heater VOC 100 0.5 H-570 018 Hot oil heater VOC 100 0.6 AMINE 019 Amine unit VOC 100 14.5 FL-991 020 Plant flare VOC 100 16.3 HTR-703 002 Hot oil heater CO 100 2.5 C-601 004 Cat G3516J CO 100 2.5 C-602 005 Cat G3516J CO 100 2.5 C-603 006 Cat G3516J CO 100 2.5 C-604 007 Cat G3516J CO 100 2.5 C-410 008 Cat G3512B CO 100 2.0 C-411 009 Cat G3512B CO 100 C-651 010 Cat G3608 CO 100 8.7 C-652 011 Cat G3608 CO 100 Page 7 of 11 ar.�. . COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit C-653 012 Cat G3608 CO 100 G-771 013 Cat G3516C CO 100 G-772 014 Cat G3516C CO 100 6.5 G-773 015 Cat G3516C CO 100 H-310 016 Dehy heater CO 100 1.9 H-290 017 Hot oil heater CO 100 3.5 H-570 018 Hot oil heater CO 100 4.4, AMINE 019 Amine unit CO 100 42.5 FL-991 020 Plant flare CO 100 7.1 GENERAL TERMS AND CONDITIONS 23. 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. 24. 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. 25. 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. 26. 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. 27. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit Page 8 of 11 COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 28. 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. 29. 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: Andy Gruel, P.E.' Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 9 of 11 r• �y. COLORADO Itagf Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) 'This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing 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 Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 " 31 31 001 n-Hexane 110543 271 271 Note: AU 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: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl VOC 0.236 N/A- Not CDPHE Default for Benzene . 71432 0.00041 Controlled Weld County n-Hexane 110543 0.0036 condensate loadout 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each Page 10 of 11 �� . COLORADO �Y/ Air Pollution Control Division Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO 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: httrt://vvvevv.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A- Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT' 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 393291 Received Date: 2/11/2019 Review Start Date: 3/12/2019 Section 01 - Facility Information Company Name: Aka Energy Group, LLC Quadrant Section Township Range County AIRS ID: 123 : , . ; ; Plant AIRS ID: 91)17 Facility Name: Speer Gas Plant Physical Address/Location : sw quadrant of Section 31, Township 4N, Range 65W County: Weld County Type of Facility: Natural Gas Processing Plant 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) Q Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks Liquid Loading 5P300-10 19WE0165 Permit initial issuance 002 NG Heater HTR-703 No 15WE1029.XP No APEN Required / Permit Exempt. 004 Natural Gas RICE C-601 Yes 19WE0148 _ Ye_ 005 Natural Gas RICE C-602 Yes 19WE0149 Yes 006 Natural Gas RICE C-603 Yes 19WE0150 Yes 007 Natural Gas RICE C-604 Yes - 19WE01S1 Yes 008 Natural Gas RICE C-410 Yes 19WE0152 Yes _ 009 Natural Gas RICE C-411 Yes 19WE0152 Yes 010 Natural Gas RICE C-651 Yes 19WE0154 %es 011 Natural Gas RICE C-652 Yes 19WE0154 Yes 012 Natural Gas RICE C-653 Yes 19WE0154 Yes Permit initial 013 Natural Gas RICE G-771 Yes 19WE0157 Yes Issuance 014 Natural Gas RICE G-772 Yes 19WE0157 Yes 015 Natural Gas RICE G-773 Yes 19WE0157 Yes 016 NG Heater H-310 No 19WE0160 Yes 017 NG Heater H-290 No 19WE0161 Yes 018 NG Heater H-570 No 19WE0162 "res 019 Amine Sweetening Unit AMINE Yes 19WE0163 Yes 020 Process Flare FL-991 Yes _ 19WE0164 Yes 021 Fugitive Component Leaks LEAKS Yes 19WE0166 Yes Section 03 - Description of Project New naturai gas processing plant in the ozone non-attainment area of Weld County. Modeling analysis is required because of NOx requested emissions greater than 40 tpy, and PM2.5 emissions greater than 5 tpy; the most recent modeling report was submitted in July 2019. Point 001 was previously approved to operate under GP07 and is now moved to an individual permit. Point 002 was previously granted a permit exemption, but as a part of this project the applicant has submitted an APEN to revise the emission factors and emission amounts. Point 003 (enclosed flare) was previously issued permit 18WE0486 on 8/16/18. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Yes If yes, for what pollutants? N0x, PM2.5 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: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (DP) J J ■ J Non-Attainment New Source Review (NANSR) J Is this stationary source a major source? N :: If yes, explain what programs and which pollutants here: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) I"' 11 R I ■ Non-Attainment New Source Review (NANSR) Colorado Department of Public Health Environment Air Pollution Control Division Operation (hrs/yr) 8760 Preliminary Analysis - Emissions from Fugitive Components SCC Code: 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Fugitive Component Counts & Emissions - Category "A" VOC Benzene Toluene Ethylbenzene Xylene n-Hexane TOC EF TOC EF - Component lb/hr- kg/hr- Control Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Service Type Count source source (%) (tpy) (tpy) (Ib/yr) Ib/yr) lb/yr: (Ib/yr) (Ib/yr) (lb/yr) ;Ib/yr) (lb/yr) (lb/yr) :lb/yr) Valves 4346 9.92E-03 4.5E-03 U6.; 56.66 2.3 377.8 15. 1 377.8 15. 1 3.8 0.2 75.6 3.0 1888.8 75.6 Pump Seals 0 5.29E-03 2.4E-03 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Gas Others 112 1 .94E-02 8.8E-03 2.86 2.9 19.0 19.0 19.0 19.0 0.2 0.2 3.8 3.8 95.2 95.2 Connectors 8300 4.41E-04 2.0E-04 81 .0% 4.81 0.9 32. 1 6.1 32. 1 6. 1 0.3 0. 1 6.4 1 .2 160.3 30.5 Flanges 0 8.60E-04 3.9E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended lines 33 4.41E-03 2.0E-03 0.19 0.2 1 .3 1 .3 1 .3 1 .3 0.0 0.0 0.3 0.3 6.4 6.4 Valves 130 5.51E-03 2.5E-03 95.0% 3. 14 0.2 62.8 3.1 69. 1 3.5 1 .9 0. 1 18.8 0.9 1443.9 72.2 Pump Seals 24 2.87E-02 1 .3E-02 88.0% 3.01 0.4 60.3 7.2 66.3 8.0 1 .8 0.2 18. 1 2.2 1386. 1 166.3 Light Oil Others 4 1 .65E-02 7.5E-03 0.29 0.3 5.8 5.8 6.4 6.4 0.2 0.2 1 .7 1 .7 133.3 133.3 Connectors 20 4.63E-04 2. 1E-04 81 .0% 0.04 0.0 0.8 0.2 0.9 0.2 0.0 0.0 0.2 0.0 18.7 3.5 Flanges 0 2.43E-04 1 . 1E-04 0.00 0.0 0.0 _ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended lines 0 3.09E-03 1 .4E-03 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 _ 0.0 0.0 0.0 0.0 Valves 594 1 .85E-05 8.4E 0.05 0.0 1 .0 1 .0 1 . 1 1 . 1 0.0 0.0 0.3 0.3 22.2 22.2 Pump Seals Heavy Oil Others 20 7.06E-05 3.2E-05 0.01 0.0 0. 1 0. 1 0. 1 0. 1 0.0 0.0 0.0 0.0 2.8 2.8 Connectors 1518 1 .65E-05 7.5E-06 0.11 0. 1 2.2 2.2 2.4 2.4 0. 1 0. 1 0.7 0.7 50.6 50.6 Flanges 0 8.60E-07 3.9E-07 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended lines 0 3.09E-04 1 .4E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Valves 53 2. 16E-04 9.8E-05 0.05 0. 1 1 .0 1 .0 1 . 1 1 . 1 0.0 0.0 0.3 0.3 23. 1 23. 1 Pump Seals 0 5.29E-05 2.4E-05 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water/Oil Others 0 3.09E-02 1 .4E-02 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 125 2.43E-04 1 . 1E-04 0. 13 0. 1 2.7 2.7 2.9 2.9 _ 0. 1 0. 1 0.8 0.8 61 . 1 61 . 1 Flanges 0 6.39E-06 2.9E-06 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended lines 0 5.51 E-04 2.5E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTALS (tpy) 71.4 7.4 0.28 0.03 0.29 0.03 0.00 0.00 0.06 0.01 2.65 0.37 TOTALS lb/ r 567 65 580 67 8 1 127 15 5292 743 With safety factor: TOTALS (tpy) 71.4 7.4 0.28 0.03 0.29 0.03 0.00 0.00 0.06 0.01 2.65 0.37 TOTALS I b/ r 567 65 580 67 8 1 127 15 5292 743 Emission Factor Source: EPA-453/R-95-017, Table 2-4 Stream VOC Fraction (wt) Stream HAP Components (wt fraction Gas 0.3000 HAP Gas Light Oil Heavy Oil Water/Oil Light Oil 1 .0000 Benzene 0.001 0.01 0.01 0.01 Heavy Oil 1 .0000 Toluene 0.001 0.011 0.011 0.011 Water/Oil 1 .0000 Ethylbenzene 1E-05 0.0003 0.0003 0.0003 Xylene 0.0002 0.003 0.003 0.003 n-Hexane 0.005 0.23 0.23 0.23 Methanol 0.0003 0.001 0.001 0.001 2,2,4-TMP 1E-05 0.0001 0.0001 0.0001 Regulator/ Considerations Is this source located in an ozone non-attainment area or attainment maintenance area? Yes Reg. 3 If yes, is this source subject to leak detection and repair (LDAR) requirements per Regulation 7, Section XVII.F or XII.G or 40 CFR, Part 60, Subparts KKK or OOOO? Yes -- 0000a If you repond "yes" to the first question and "no" to the second, this source is subject to Regulation 3, Part B, Section III. D.2, Reasonably Available Control Technology (RACT) requirements and must implement a leak detection and repair program. The engineer should work with the supervisor to craft an LDAR requirement that mirrors the provisions of Regulation 7, Section XVII.F. Subject to NSPS 0000a Reg. 6 Is this source located in an ozone non-attainment area or attainment maintenance area? Reg. 7 Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.631? If you answer "yes" to both questions above, this source is subject to the provisions of Regulation 7, Section XII.G regardless of the date of construction Is this source at a "natural gas processing plant" as defined in 40 CFR, Part 63.761 ? Yes Reg, 8 Is this facility considered a "major source" of HAP as specifically defined in 40 CFR, Part 63.761 for sites that are not prodcution field facilities? No If you repond "yes" to both questions above, further review if the provisions of 40 CFR, Part 63.769 "Equipment Leak Standards" apply? N/A Printed 9/18/2019 Page 2 of 7 Colorado Department of Public Health Environment Air Pollution Control Division Operation (hrs/yr) Preliminary Analysis - Emissions from Fugitive Components SCC Code: 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Fugitive Component Counts & Emissions - Category " B" ( High-VOC , butane and propane streams) VOC Benzene Toluene Ethylbenzene Xylene n-Hexane TOC EF TOC EF Component lb/hr- kg/hr- Control Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Service Type Count source source (0/0) (tpy) (tpy) (Ib/yr) (Ib/yr) (Ib/yr) (Ib/yr) (Ib/yr) (Ib/yr) (Ib/yr) (Ib/yr) (Ib/yr) (lb/yr) Valves 448 9.92E-03 4.5E-03 96.0% 19.47 0.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 - Pump Seals 4 5.29E-03 2.4E-03 0.09 0. 1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Gas Others 0 1 .94E-02 8.8E-03 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 1413 4.41E-04 2.0E-04 _ 81 .0% 2.73 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Flanges 84 8.60E-04 3.9E-04 0.32 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 I 0.0 0.0 Open-ended lines 0 4.41E-03 2.0E-03 0.00 0.0 0.0 0.0 0.0 0.0 _ 0.0 0.0 0.0 0.0 0.0 0.0 Valves 98 5.51E-03 2.5E-03 95.0% 2.37 0. 1 0.0 _ 0.0 0.0 0.0 0.0 0.0 _ 0.0 0.0 0.0 0.0 Pump Seals 20 2.87E-02 1 .3E-02 88.0% 2.51 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Light Oil Others 4 1 .65E-02 7.5E-03 0.29 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 56 4.63E-04 2. 1E-04 81 .0% 0. 11 0.0 0.0 0.0 _ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Flanges 0 2.43E-04 1 . 1E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended lines 0 3.09E-03 1 .4E-03 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Valves 16 1 .85E-05 8 .4E-06 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Pump Seals Heavy Oil Others 0 7.06E-05 3.2E-05 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 32 1 .65E-05 7.5E-06 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Flanges 0 8.60E-07 3.9E-07 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended lines 0 3.09E-04 1 .4E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Valves 0 2. 16E-04 9.8E-05 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Pump Seals 0 5.29E-05 2.4E-05 s, 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water/Oil Others 0 3.09E-02 1 .4E-02 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 0 2.43E-04 1 . 1E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 _ Flanges 0 6.39E-06 2.9E-06 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 _ Open-ended lines 0 _ 5.51E-04 2.5E-04 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTALS (tpy) 27.9 2.4 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 TOTALS lb/ r 0 0 0 0 0 0 0 0 0 0 With safety factor: 1 TOTALS (tpy) 27.9 2.4 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 TOTALS lb/ r 0 0 0 0 0 0 0 0 0 0 Emission Factor Source: EPA-453/R-95-017, Table 2-4 Stream VOC Fraction (wt) Stream HAP Components wt fraction; Gas 1 .0000 HAP Gas Light Oil Heavy Oil Water/Oil Light Oil 1 .0000 Benzene 0 0 0 0 Heavy Oil 1 .0000 Toluene 0 0 0 0 _ Water/Oil 1 .0000 Ethylbenzene 0 0 0 0 Xylene 0 0 0 0 n-Hexane 0 0 0 0 Methanol 0 0 0 0 2,2,4-TMP 0 0 0 0 Regulatory Considerations Printed 9/18/2019 Page 3 of 7 Colorado Department of Public Health Environment Air Pollution Control Division Summary of Preliminary Analysis - Fugitive Components Source Company Name Aka Energy Group , LLC Facility Name Speer Gas Plant Permit No 19WE0166 AIRS 123/9DF7/021 Permit Engineer Andy Gruel Application Date 2/ 11 /2019 Review Date 3/27/2019 Summary of Emissions VOC Benzene Toluene Ethylbenzne Xylenes n-Hexane Methanol 224-TMP (tpy) (Ib/yr) ( lb/yr) (lb/yr) ( lb/yr) ( Iblyr) ( Ib/yr) (lb/yr) Uncontrolled Requested Emissions 99 .2 567 580 8 127 5 , 292 143 6 Controlled Requested Emissions 9 . 8 65 67 1 15 743 15 1 Reportable? Yes Yes No No Yes No No Total HAP, Uncontrolled (tpy) 3 . 3 Total HAP, Controlled (tpy) 0 .4 Highest HAP, Uncontrolled (tpy) 2 . 6 n-Hexane Emission Factors Emission Factor Source : EPA-453/R-95-017 , Table 2-4 Controls LDAR per NSPS 0000a Category "A" : Stream VOC Fraction : Stream HAP P Components (wt frac) Gas 0 . 3000 HAP Gas Light Oil Heavy Oil Water/Oil Light Oil 1 . 0000 Benzene 0 . 0010 0 . 0100 0. 0100 0 . 0100 Heavy Oil 1 . 0000 Toluene 0 . 0010 0 . 0110 0 . 0110 0 . 0110 Water/Oil _ 1 . 0000 Ethylbenze 0 . 00001 0 . 0003 0 . 0003 0 . 0003 Xylene 0 . 0002 0 . 0030 0 . 0030 0 . 0030 n-Hexane 0. 0050 0 . 2300 i 0. 2300 0 . 2300 Methanol 0 . 0003 0 . 0010 0 . 0010 0. 0010 2 , 2 ,4-TMP 0 . 00001 0 . 0001 0 . 0001 0 . 0001 Category " B" ( High-VOC , no HAP, butane and propane streams) : Stream VOC Fraction : Stream HAP Components (wt frac) Gas 1 . 0000 HAP Gas Light Oil Heavy Oil Water/Oil Light Oil 1 . 0000 Benzene 0 0 0 0 Heavy Oil 1 . 0000 Toluene 0 0 0 0 Water/Oil 1 . 0000 _, _ EthylbenzE 0 0 0 0 Xylene 0 0 0 0 n-Hexane 0 0 0 0 Methanol 0 0 0 0 2 , 2 ,4-TMP 0 0 0 0 Comments/Notes : Applicant used a different VOC and HAP fraction for certain components . Those are split into "Category A" and "Category B" . Category B is assumed to be 100% VOC and 0% HAP (i .e. , butane and propane streams) . For Category A, the gas stream components were estimated by the existing discharge at the existing facility, and the liquid streams were modeled by ProMax simulation . Printed 9/18/2019 Page 4 or 7 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Aka Energy Group1 LLC County AIRS ID 123 History File Edit Date 4/2/2019 Plant AIRS ID 9DF7 - Ozone Status Non-Attainment Facility Name Speer Gas Plant EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 2. 1 94.3 0. 1 3.6 0.7 . 0.2 0.2 . 0.0 2. 1 13.2 0.0 3.6 0.2 revious taken from May 2018 tab Previous Permitted Facilit,v total 0.0 0. 0 0.0 0.0 0. 6 94. 1 0. 0 1. 1 0. 7 0. 0 0. 0 0. 0 0. 0 0. 6 12. 9 0.0 1. 1 0.2 001 19WE0165 Truck loadout of condensate 8.9 0.2 8.90 0.2 "SP300-10" 002 15WE1029.XP Hot oil heater, 6.96 MMBtu/hr 0.2 0.2 0.0 1 . 1 0.2 2.5 0.5 0.2 0.2 0.0 1 . 1 0. 16 2.51 0.5 "HTR-703" ( _ 003 ?..a ncat e�.6 ,...J i 1>'•..- �• % ♦ ti ! •i i •.r �.. 1ji Luc;;}c f7 under new ,� z;it�y t,:),?;ltirt�c,vJ? 004 19WE0148 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-601 " _ 005 19WE0149 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-602" 006 19WE0150 Caterpillar G3516J, sn: TBD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-603" _ 007 19WE0151 Caterpillar G3516J, sn: TAD 0.5 0.5 0.0 6.7 12. 1 35.9 7.0 0.5 0.5 0.0 6.7 3.03 2.51 1 .2 "C-604" 008 19WE0152 Caterpillar G3512B, sn: TBD "C-410" Requested combined limit of 8760 hr/yr. 0.3 0.3 0.0 5.0 18.2 28.0 5.6 0.3 0.3 0.0 5.0 4.55 1 .96 0.9 between points 008 and 009. 009 19WE0152 Caterpillar G3512B, sn: TAD "C-411 " _ 010 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-651 " Requested combined limit of 17520 hr/y; between points 010,011 ,and 012. 011 19WE0154 Caterpillar G3608, sn: TBD 0.8 0.8 0.0 7.2 10.6 62.3 5.9 0.8 0.8 0.0 7.2 2.66 4.36 1 .4 C-652" 012 19WE0154 Caterpillar G3608, sn: TBD "C-653" 013 19WE0157 Caterpillar G3516C, sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0 5.47 3.23 1 .9 G-771 " Requested combined limit of 17520 hr/yr between points 013014,and 015. 014 19WE0157 Caterpillar G3516C, sn: TBD "G-772" 015 19WE0157 Caterpillar G3516O , sn: TBD 0.6 0.6 0.0 10.0 21 .9 46. 1 12.4 0.6 0.6 0.0 10.0_ 5.47 3.23 1 .9 "G-773" Heater for dehy regen, 10.4 011, 19WE0160 Heater 0.3 0.3 0.0 1 . 1 0.3 1 .9 0.7 0.3 0.3 0.0 1 . 1 0.25 1 .87 0.7 "H-310" MMBtu/hr 017 19WE0161 Hot oil heater, 19.33 MMBtu/hr 0.6 0.6 0. 1 2. 1 0.5 3.5 1 .3 0.6 0.6 0. 1 2. 1 0.46 3.47 1 .3 "H-290" 018 19WE0162 Hot oil heater, 24.3 MMBtu/hr 0.8 0.8 0. 1 2.7 0.6 4.4 1 .6 0.8 0.8 0. 1 2.7 0.57 4.36 1 .6 "H-570" 019 19WE0163 Amine sweetening, 60 MMscfd 0.6 0.6 1 .4 5.0 289.2 42.5 133.8 0.6 0.6 1 .4 5.0 14.46 42.52 6.7 "AMINE" _ 020 19WE0164 Plant Flare 0.2 0.2 0.0 3.5 324.9 7. 1 8. 1 0.2_ 0.2 0.0 3.5 16.25 7.08 0.4 "FL-991 " 021 19WE0166 , Facility fugitive equipment leaks 99.2 3.4 _ 9.8 0.5 "LEAKS" APEN-Exempt / Insignificants 0.0 0.0 _ 0.0 0.0 0.0 0.0 FACILITY TOTAL 7.6 7.6 0.0 1 .8 81 .7 756.0 99.2 450.0 219.4 7.6 7.65 0.0 1 .8~ 81.7 74.0 9.8 89.0 24.0 VOC : Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B, T, n-hex, HCHO, McOH. & Total ZZZZ: Syn Minor Permitted Facility Total 7.4 7 4 0. 0 1. 8 80. 6 755. 9 99.2 447. 5 219. 0 7. 4 7. 42 0. 0 1. 8 80. 6 73. 8 9. 8 86. 5 23. 6 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 7. 4 7. 4 0. 0 1. 8 80. 0 60.9 9. 8 85.4 Pubcom required. Modeling required for NOx did PM2.5. Total VOC Facility Emissions (point and fugitive) 83. 8 Facility is eligible for GP02 because < 90 tpy A' Change in Total Permitted VOC emissions (point and fugitive) 70. 7 Note 1 Insignificants tracking required for Total HAPs. Note 2 Page 5 of 7 Printed 9/18/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 4 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0.2 002 15WE1029 .XP Hot oil heater, 6 .96 MMBtu/hr [31 45 46 62 129 81 108 r- { 173 127 21 0 . 5 00:: t {li.,c-hits 004 19WE0148 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 4 24 7 . 0 005 19WE0149 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 25 100 225 23 24 7 . 0 006 19WE0150 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 4 25 100 225 23 24 7. 0 007 19WE0151 Caterpillar G3516J , sn : TBD 11460 753 463 117 734 4 i 25 100 225 23 24 7. 0 008 19WE0152 Caterpillar G3512B , sn : TBD 5 .6 009 19WE0152 Caterpillar G3512B , sn : TBD 9395 550 338 85 536 3 18 73 164 16 18 0 . 0 010 19WE0154 Caterpillar G3608, sn : TBD 7725 + 1255 _ 771 195 1223 6 41 167 375 38 40 5. 9 011 19WE0154 Caterpillar G3608, sn : TBD 7725 1255 771 195 1223 6 41 167 375 38 40 5 . 9 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 140 315 32 34 12 .4 014 19WE0157 Caterpillar G3516C , sn : TBD 21259 1054 648 164 1027 5 34 140 315 32 34 12 .4 015 19WE0157 Caterpillar G3516C , sn : TBD _ 016 19WE0160 Heater for dehy regen , 10.4 MMBtu/hi 77 67 68 93 192 120 161 88 259 31 4 0 . 7 017 19WE0161 Hot oil heater, 19 .33 MMBtu/hr 143 125 127 172 358 224 299 4 163 i 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24 .3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 4 1 .6 019 19WE0163 Amine sweetening , 60 MMscfd 43 . 3 30362 14458 145 1446 2892 216872 0.29 1446 133. 8 020 19WE0164 Plant Flare 2161 2161 22 432 10805 648 22 4 8. 1 021 19WE0166 Facility fugitive equipment leaks _ 567 580 8 127 5292 143 6 3.4 0. 0 APEN-Exempt / Insignificants 0. 0 0 . 0 0 . 0 0. 0 TOTAL (tpy) 56.8 4.3 2.5 17.4 12.9 0.7 1 . 5 10.6 110.3 0.9 0.7 0.6 0.2 219.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 6 19WE0166 . CP1 9/18/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Aka Energy Group, LLC County AIRS ID 123 Plant AIRS ID 9DF7 Facility Name Speer Gas Plant Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S Styrene = J'a TOTAL (tpY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0165 Truck loadout of condensate 31 270 0 .2 002 15WE1029 .XP Hot oil heater, 6 . 96 MMBtu/hr I 45 46 62 129 81 108 59 173 21 0 . 5 003 Jaf,ceiieu - 004 19WE0148 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 005 19WE0149 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 006 19WE0150 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 .2 007 19WE0151 Caterpillar G3516J , sn : TBD 1146 376 231 59 367 2 12 50 113 11 12 1 . 2 008 19WE0152 Caterpillar G3512B , sn : TBD 939 275 169 43 268 1 9 37 82 8 9 0 . 9 009 19WE0152 Caterpillar G3512B , sn : TBD 010 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 19 20 1 .4 011 19WE0154 Caterpillar G3608 , sn : TBD 772 627 386 98 612 3 21 83 188 19 20 1 .4 012 19WE0154 Caterpillar G3608 , sn : TBD 013 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 16 17 1 . 9 014 19WE0157 Caterpillar G3516C , sn : TBD 015 19WE0157 Caterpillar G3516C , sn : TBD 2126 527 324 82 514 3 17 70 158 1 G 17 1 . 9 016 19WE0160 Heater for dehy regen , 10 .4 MMBtu/hi 77 67 68 93 192 120 161 88 259 189 31 0 . 7 017 19WE0161 Hot oil heater, 19. 33 MMBtu/hr 143 125 127 172 358 224 299 163 481 352 58 1 . 3 018 19WE0162 Hot oil heater, 24. 3 MMBtu/hr 180 157 159 216 450 281 376 205 605 443 73 1 . 6 019 19WE0163 Amine sweetening , 60 MMscfd 43. 3 1518 723 7 72 145 10844 0.01 72 6 . 7 020 19WE0164 Plant Flare 108 108 1 22 540 32 1 0 .4 , 021 19WE0166 Facility fugitive equipment leaks 65 67 1 15 743 15 1 0 . 5 0 . 0 APEN-Exempt / Insignificants 0 . 0 _ _ 0 . 0 _ 0 . 0 0 . 0 TOTAL (tpy) 5.9 2. 2 1 .3 1 .4 2.7 0.6 0.5 1 .6 6.3 0.8 0. 0 0.6 0. 2 24 . 03 7 19WE0166 . CP1 9/18/2019 a :Ir,-,. COLORADO - Air Pollution Control Division COPHE Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE01 66 Issuance: 1 Date issued: Issued to: Aka Energy Group, LLC Facility Name: Speer Gas Plant Plant AIRS ID: 123/9DF7 Physical Location: SW Section 31 T4N R65W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this,permit: Equipment AIRS Emissions Control Equipment Description ID Point Description LEAKS 021 Equipment leaks (fugitive VOCs) from LDAR per NSPS 0000a a natural gas processing plant. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/ar/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). Page 1 of 11 COLORADO Air Pollution Control Division CDPHE Department of Public Health t,Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 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 (as calculated in the Division's preliminary analysis).(Reference: ',Regulation No. 3, Part B, Section I I.A.4) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point VOC Emission Type LEAKS 021 1670 Fugitive (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 4,006 lb/month. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. Annual Limits: Facility AIRS Tons per Year Equipment ID Point VOC Emission Type ,LEAKS 021 9.8 Fugitive 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 be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 23.6 tpy. Page 2 of 11 .-.:., COLORADO a ----- � - Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at the facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimus reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve- month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits',any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall be less than: • 25 tons per year of total hazardous air pollutants (HAP). 9. The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas and liquids analyses, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of Page 3 of 11 eye COLORADO a Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 13. This source is subject to Regulation No. 7, Section XII.G.1 (State only enforceable). For fugitive VOC emissions from leaking equipment, the leak detection and repair (LDAR) program as provided at 40 C.F.R. Part 60, Subpart 0000a shall apply. The operator shall comply with all applicable requirements of Section XII. OPERATING Et MAINTENANCE REQUIREMENTS 14. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples and extended natural gas liquids analysis of liquids that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. Representative samples must be collected from each of the two categories of plant service, as described in Note to Permit Holder #5. These extended gas and liquids analyses shall be used in the compliance demonstration as required in the,Emission Limits and Records section'of this permit..; The operator shall submit the results of the gas and liquids analyses and emission calculations to the Division as part of the self-certification process to demonstrate compliance with emissions limits. 16. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service", as well as which of the two categories of plant service apply to each component (see Note to Permit Holder #5). The operator shall submit the results to the Divisiai as part of the self-certification process to ensure compliance with emissions limits. Periodic Testing Requirements 17. On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples and an extended natural gas liquids analysis of liquids that are representative of volatile organic compounds (VCIC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. Representative samples must be collected from each of the two categories of plant service, as described to Note to Permit Holder #5. These extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or Page 4 of 11 -x- COLORADO Air Pollution Control Division il: ,.a "IiIIPP'' Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. 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 10O 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 19. The exhaust stack(s) for the following emission point(s) must vent emissions at a point greater than or equal to the height specified in the table below: Facility AIRS Minimum stack height Equipment ID Point above ground level (m) C-601 004 10.67 C-602 005 10.67 C-603 006 10.67 C-604 007 10.67 C-410 008 9.14 C-411 009 9.14 C-651 010 10.1 C-652 011 10.1 C-653 012 10.1 G-771 013 6.4 G-772 014 6.4 G-773 015 6.4 H-310 016 4.84 H-290 017 7.01 H-570 018 5.5 AMINE 019 13.18 FL-991 020 38.76 Page 5 of 11 aMl�.Y- COLORADO + - Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 20. The following source groups are restricted to the following maximum annual hours of operation and maximum operating scenarios: Allowable Combined Maximum Number of Facility Equipment Hours of Operation Per Engines in Operation at IDs AIRS Points Year Any Time C-410 and C-411 008, 009 8760 1 of 2 C-651, C-652, C-653 010, 011, 012 1752O 2 of 3 G-771, G-772, G-773 013, 014, 015 17520 2 of 3 21. The facility must be constructed and operated with the building and emission source layout depicted in the modeling analysis for the facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section III.B.5.) 22. This facility must be completely enclosed by a fence line and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air NOx and PM2.5 impacts that result from the facility operations. (Regulation Number 3, Part B, Section iIi.B.5.) 23. 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 No. 3 Part D). GENERAL TERMS AND CONDITIONS 24. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 25. 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 No. 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. 26. 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. Page 6 of 11 a 1....... COLORADO Air Pollution Cdhtrol Division Department of Public Health&Ernie um,lent Dedicated to protecting and improving the health and environment of the people of Colorado 27. 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. 28. 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 Cantrol 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. 29. 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. 30. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Aka Energy Group, LLC. Page 7 of 11 DO Air Pollution COLORAControl Di-1%0vision Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The 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/pacificicdphe/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. Uncontrolled Are the Controlled AIRS Emission Rate emissions Emission Rate Point Pollutant CAS# (Ib/yr) reportable? (lb/yr) Benzene 71432 567 Yes 65 Toluene 108883 580 Yes 67 Ethylbenzene 100414 8 No 1 021 Xylenes 1330207 127 No 15 n-Hexane 110543 5292 Yes 743 Methanol 67561 143 No 15 2,2,4-Trimethylpentane 540841 6 No 1 5) The emission levels contained in this permit are based on the following emission factors: The facility components are split into two categories. Category "A" is typical gas plant service, and Category "B" is high-VOC butane and propane streams. Category "A": Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 8300 1518 20 125 Flanges 0 0 0 0 Open-ended Lines 33 0 0 0 Page 8 of 11 COLORADO C L4' Air Pollution Control Division C DPH E Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Pump Seals 0 0 24 0 Valves 4346 594 130 53 Other* 112 20 4 0 VOC Content (wt. fraction) 0.3 1.0 1.0 1.0 Benzene Content (wt. fraction) 0.001 0.01 0.01 0.01 Toluene Content (wt. fraction) 0.001 0.011 0.011 0.011 Ethylbenzene (wt. fraction) 0.00001 0.0003 0.0003 0.0003 Xylenes Content (wt. fraction) 0.0002 0.003 0.003 0.003 n-hexane Content (wt. fraction) 0.005 0.23 0.23 0.23 Methanol Content (wt. fraction) 0.0003 0.001 0.001 0.001 2,2,4-TMP content (wt. fraction) 0.00001 0.0001 0.0001 0.0001 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents Category "B": Component ! Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1413 32 56 0 Flanges 84 0 0 0 Open-ended Lines 0 0 0 0 Pump Seals 4 0 20 0 Valves 448 16 98 0 Other* 0 0 4 0 VOC Content (wt. fraction) 1.0 1.0 1.0 1.0 Benzene Content (wt. fraction) 0 0 0 0 Toluene Content (wt. fraction) 0 0 0 0 Ethylbenzene(wt. fraction) 0 0 0 0 Xylenes Content (wt. fraction) 0 0 0 0 n-hexane Content (wt. fraction) 0 0 0 0 Methanol Content (wt. fraction) 0 0 0 0 2,2,4-TMP content (wt. fraction) 0 0 0 0 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Page 9 of 11 MT�1M COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. 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 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.federalregister.gov/documents/2016/06/03/2016-11971/oil-and- natural-gas-sector-,emission-standards-for-new-reconstructed-and-modified-sources 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAPs (total, and formaldehyde, benzene, toluene, n-hexane, and methanol) PSD Synthetic Minor Source of: CO NANSR Synthetic Minor Source of: VOC NSPS 0000a Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z Page 10 of 11 a - . COLORADO IY_.fl Air Pollution Control Division tigi Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX 10)A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self- certification. Page 11 of 11 CDPH Spark Ignition Engine APEN FEB 1 1 2019 Form APCD 201 A-PC'D CO� a'r tIO,rc&r-v Air Pollutant Emission Notice (APEN) and ,, sue 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 spark ignition (e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g.compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition,the General APEN (Form APCD-200)is available if the specialty APEN options do not meet your reporting.eeds.A list of all available APEN forms canibe found on the Air Pollution Control Division(APCD)website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: L q 114 AIRS ID Number: 123 /9DF7/ 004 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Aka Energy Grow{), LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E-Mail Address 2: ehinkley@redcedargathering.com Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393270 COLORADO Form APCD-201 Spark Ignition Engine APEN - Revision 7/2018 1 I �� ""''e Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source(check one below) O STATIONARY source ❑ PORTABLE source ✓❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) Add point to existing ❑ Change fuel or equipment ❑ Change company name4 ❑ permit ❑ Change permit limit 0 Transfer of ownerships ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Lank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info a Notes: 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. C-601 General description of equipment and purpose: inlet gas compression For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? Yes ❑No (http://www.colorado.gov/cdphe/attaialment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 COLONAOO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I ® ;�: '•.,f•:`;•, Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 4- Engine Information Engine Function: O Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) 0 Compression ❑Pump Jack ❑Water Pump ❑Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpiller Engine Model: G3516J Serial Number7: TBD What is the maximum designed horsepower rating? 1380 hp • What is the maximum manufacturer's site-rating? 1380 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7447 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke p 4-Stroke Combustion: p Lean Burn ❑Rich Burn Aspiration: O Natural O Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ❑✓ Yes O No If yes,what type of AFRC is in use? ❑02 Sensor(mV) ONOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? 0 Yes O No Engine Dates: What is the manufactured date of this engine? after 7/1/2010 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes ✓❑No If yes, provide the make, model, and serial number of the old engine below: Engine.Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. �� p COLORADO Form APCD-201 -Spark Ignition Engine APEN - Revision 7/2018 3 I �0"'',,_"'.1.=, Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unkess APCD has already assigned a permit t/and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,306.28 m El 4,457,190.68 m N Discharge Height, Operator Temp. - Flow Rate - Velocity Above Ground Level (ftFsec) (feet) Stack ID No. r. - (•p) (AMA) • C-601 35 1003 9206 144 Indicate the direction of the Stack outlet (check one) ❑✓ Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ✓❑Circular Interior stack diameter(inches): 14 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑Other(describe): Section 6- Fuel Data and Throughput Information Fuel Use Rate @ 1OO%Load -_ Actual Annual Fuel Use Requested Annual Permit Limit8 (SCF/hour) (MMSCF/year) (MMSCF/year) 10,476 91.8 91.8 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2;300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value(give units): 8 Requested values will become permit Limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I �� - p t' Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit✓;t and AIRS ID] Section 7- Emissions Inventory Ieformation Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. 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): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP (PM) PMio • . PM2,5 SOx - NOx VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Citeria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual-Permit Limit Emission Limits) Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Units (AP-42, Emissions Emissions Emissions Emissions Basis Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 999E-03 Ib/MMBIu AP-42 0 5 0.5 0.5 0.5 PM i o 9 99E-03 IWMMBtu AP-42 0-5 0 5 0 5 0 5 PM2.5 9 99E-03 IbIMMBtu AP-42 0 5 0 5 0.5 9 0 5 SOx 5.88E-04 IbIMMBlu AP-42 0 03 0 03 0 03 0 03 NOx 0.50 g/hp-hr manufacturer 6 7 6.7 6 7 6 7 VOC 0 91 g/hp-hr manufacturer 12 1 3 0 12.1 3.0 CO 2.69 g/hp-hr manufacturer 35 9 2 5 35.9 2 5 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 0 Yes : No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions10 Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 0 43 g/hp-hr manufacturer 11460 1146 Acetaldehyde 75070 836E-03 lb/MMBtu AP-42 753 376 Acrolein 107028 5 14E-03 IblMMBIU AP-42 463 231 Benzene 71432 1 30E-03 IbIMMBtu GRI 117 59 Other: toluene-108883 8 15E-03 lb/MN/Btu GRI 734 367 8 Requested values will become permit limitatbns.,Requested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. i1. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 5 I MI- 4°"'„<<,.r,;.=:a, Permit Number AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit It 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. G� . # 211jict Signature of Legally Authorized Pe (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase,increase production, new equipment, change in fuel type,etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692.3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd COLORADO Form APCD-2O1 -Spark Ignition Engine APEN - Revision 7/2018 6 I E;• "^ 1.0 rr�p>{E Spark Ignition Engine APEN A _►`` Form APCD-201 roCO- C Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application roust 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 spark ignition(e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options do not meet your reporting Needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.Qov/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: 1 Ct AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant • Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 - Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E Mail Address 2: I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 333271 pp COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 1 I Li1� t,•.,,,..,,°,, `„., Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source(check one below) El STATIONARY source ❑ PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) 4 Add point to existing ❑ Change fuel or equipment ❑ Change company name O permit ❑ Change permit limit ❑ Transfer of ownerships O Other(describe below) -OR- ❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info Et Notes: 3 Only one engine may be reported per APEN far GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. C-602 General description of equipment and purpose: inlet gas compression For existing sources, operation began orc For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? Yes ❑No (http://www.colorado.Rov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 COLORADO Form APCD-201 - Spark Ignition Engine APEN • Revision 7/2018 2 I ` Permit Number: AIRS ID Number: 123 i9DF7/ [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 4 - Engine Information Engine Function: ❑Primary and/or Peaking Power D Emergency(max. 500 hrs/year) E Compression O Pump Jack O Water Pump O Other: What is the maximum number of hours this engine will be used for emergency back-up power? hours/year Engine Make: Caterpiller Engine Model: G3516J Serial Number': TBD What is the maximum designed horsepower rating? 1380 hp What is the maximum manufacturer's site-rating? 1380 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7447 BTU/hp-hr Engine Features: Cycle Type: O 2-Stroke 0 4-Stroke Combustion: 0 Lean Burn Rich Burn Aspiration: O Natural ❑Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ✓0 Yes O No If yes,what type of AFRC is in use? O 02 Sensor(mV) ONOx Sensor(ppm) O Other: Is this engine equipped with a Low-NOx design? 0 Yes ❑No Engine Dates: What is the manufactured date of this engine? after 7/1/2010 What date was this engine ordered? after 6/12/2006 What is the date this engine was first lccated to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? O Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 'The serial number must be submitted if coverage under GP02 is requested. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 1 �� a"'.,:'.':,. ;. Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit If and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,306A5 m El 4,457,204.40 m N -Discharge}{eight Operator Temp.; Flow Rate _ Velocity Above Ground Level`- • Stack ID No. _ {'F) (ACFM) - :(ftlsec) (feet) C-602 35 1003 9206 144 Indicate the direction of the Stack outlet: (check one) El Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ✓❑Circular Interior stack diameter(inches): 14 O Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): 'Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load - Actual Annual Fuel Use Requested Annual Permit Limit8 (SCF/hour) (MMSCFIyear) (MMSCF/year). 10,476 91.8 91.8 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) E Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas , Heating Value: BTU/scf ❑Other(describe): Heating Value (give units): 8 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. � COL0RAD0 Form APCD-2O1 -Spark Ignition Engine APED! Revision 7/2018 4 + -'"`;f'•"';'I Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form.The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑No if yes, describe the control equipment MID state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP(PM) PM1D - PM z.s - SOx NOx , VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions10 Emission Limit(s)8 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9 99E-03 lb/MMBtu AP-42 0.5 0 5 0 5 0.5 PM 10 9 99E-03 Ib/MMBtu AP-42 0 5 0 5 0 5 0.5 PM z.5 9 99E-03 lb/MMBtu AP-42 0.5 0 5 0 5 0.5 SOX 5 88E-04 Ib/MMBtu AP-42 0 03 0,03 0 03 0O3 NO x 0 50 g/hp-hr manufacturer 6.7 6.7 6 7 6 7 VOC 0.91 g/hp-hr manufacturer 12 1 3 0 12 1 3 0 CO 2 69 g/hp-hr manufacturer 35 9 2.5 35 9 2.5 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 ❑✓ Yes 0 No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-CriterM Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions10 Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 043 g/hp-hr manufacturer 11460 1146 Acetaldehyde 75070 8.36E-03 Ib/MMBtu AP-42 753 376 Acrolein 107028 5 14E-03 lb/MMBtu AP-42 463 231 Benzene 71432 1.30E-03 Ib/MMBtu GRI 117 59 Other: toluene-108883 8 15E-03 Ib/MMBtu GRI 734 367 8 Requested values will become permit limitations.,Requested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. iv,' COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 5 I m Z"m".`•,.Mp„ Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit k 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. GJ C 2/I il at Signature of Legally Authorized P rse (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3475 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.gov/cdphe/apcd • COLORADO Form APCD-2O1 - Spark Ignition Engine APEN Revision 7/2018 6 I AV „::1g;F"RAD'• FEs 1 1 1019 CDPHE Spark Ignition Engine APEN ht�� c t:,\.10 Form APCD-201 CO ¢� 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 spark ignition le.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine (e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant,crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options do not meet 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: k ck AIRS ID Number: 123 /9DF7/ 00(0 [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 1 -Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E-Mail AddressZ: ehinkley@redcedargathering.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 333272 ply COLORADO Form APCD-2O1 -Spark Ignition Engine APEN - Revision 7/2018 1 I Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2- Requested Action ❑� NEW permit OR newly-reported emission source(check one below) O STATIONARY source ❑ PORTABLE source ❑ Request coverage under a Coastruction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check eoch box below that applies) Add point to existing o Change fuel or equipment ❑, Change company name ❑ permit ❑ Change permit limit ❑ Transfer of ownerships O Other(describe below) -OR • APEN submittal for update only(Wank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement' Additional Info Et Notes: 3 Only one engine may be reported per APEN far GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes -If yes, provide the Company Equipment Identification No. s C-603 General description of equipment and purpose: inlet gas compression For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? Yes O No (http:/1www.colorado.Rov/cdphe/attaiement) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 2 I Aar Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Engine Information Engine Function: O Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) Compression O Pump Jack O Water Pump ❑Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpiller Engine Model: G3516J Serial Number7: TBD What is the maximum designed horsepower rating? 1380 hp What is the maximum manufacturer's site-rating? 1 380 hp kW What is the engine Brake Specific Fuel Co.sumption at 100%Load? 7447 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke ❑✓ 4-Stroke Combustion: ❑✓ Lean Burn O Rich Burn Aspiration: O Natural ❑Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes O No If yes,what type of AFRC is in use? ❑02 Sensor(mV) ❑NOx Sensor(ppm) O Other: Is this engine equipped with a Low-NOx design? ❑✓ Yes O No Engine Dates: What is the manufactured date of this engine? after 7/1/2010 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes D No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 'The serial number must be submitted if coverage under GP02 is requested. ppCOLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 3 I Lam® CO Permit Number: AIRS ID Number: 123 /9DF71 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,306.62 m El 4,457,218.11 m N Discharge Height Operator - - Temp. Flow Rate� Velocity Above Ground Level (ft/sec) Stack ID No. Co - - (ACFM) (f ) (feet) C-603 35 1003 9206 144 Indicate the direction of the Stack outlet (check one) ✓�Upward ❑Downward ❑Upward with obstructing raincap El Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) �✓ Circular Interior stack diameter(inches): 14 Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): El Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use - .. Requested Annual Permit Limits (SCF/hour) (MMSCFI year) (MMSCF/year) 10,476 91.8 91.8 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ▪ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ✓Q Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 Bi U/scf) • Landfill Gas Heating Value: BTU/scf Other(describe): Heating Value (give units): 8 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO Form APCD-201 Spark Ignition Engine APEN - Revision 7/2018 4 I �"FJ C L A Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form.The APCD website has a . Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0 Yes O No If yes,describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP(PM) PM 10 . PM2.5 SOx NOx VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Emission Factor . Actual Annual Emissions" Permit Pollutant Emission Limit(s)8 Source Uncontrolled Controlled , Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions Basis Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP (PM) 9 99E-03 Ib/MMBtu AP-42 0 5 0 5 0 5 0.5 PM 10 9 99E-03 IbIMMBtu AP-42 0 5 0 5 0 5 0.5 PM2.5 9.99E-03 Ib/MMBlu AP-42 0,5 0,5 05 0.5 SOx 5.88E-04 lb/MMBtu AP-42 0 03 0 03 0 03 0 03 NOx 050 g/hp-hr manufacturer 67 6.7 6.7 6.7 VOC 0 91 glhp-hr manufacturer 12 1 3 0 121 3 0 CO 2 69 g/hp-hr manufacturer 35 9 2 5 35 9 2 5 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 ✓l Yes ❑No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory . Chemical Emission Factor Actual Annual Emissions10 Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 043 gfhp-hr manufacturer 11460 1146 Acetaldehyde 75070 8 36E-03 Ib/MMBtu AP-42 753 376 Acrolein 107028 514E-03 Ib/MMBtu AP-42 463 231 Benzene 71432 1 30E-03 IbIMMBIu GRI 117 59 Other: toluene-108883 8 15E-03 Ib/MMBtu GRI 734 367 8 Requested values will become permit limitations.,Requested limit(s)shoulc consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 5 I ® ..7,v,"70'.'"' Permit Number: AIRS ID Number: 123 i9DF7/ [Leave blank unless APCD has already assigned a permit II 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. . 1/ " 2/I )!? Signature of Legally Authorized Pe o (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 6 I AV °`w:°^`F;°f'°:°° RECEIVED FEB 1 1 2019 ®� � Spark Ignition Engine APEN APCD Stational'' °7 Ariffr- Form APCD-201 CO V7 �' 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 spark ignition(e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g.compression ignition engine, mining operations, asphalt plant,crusher, screen, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options do not meet your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase,increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: \o m ej t 51 AIRS ID Number: 123 /9DF7/ O [Leave blank unless APCD has already assigned a permit x and AIRS ID] Section 1 - Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source s Home Base: E-Mail Address 2: ehinkley@redcedargathering_com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393273 op COLORADO IS., Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 1 I Permit Number: AIRS ID Number: 123 /9DF7/ - [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 2 - Requested Action ❑� NEW permit OR newly-reported emission source(check one below) ✓❑ STATIONARY source O PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) Add point to existing El Change fuel or equipment O Change company name ❑ permit o Change permit limit ❑ Transfer of ownerships ❑ Other(describe below) -OR • APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement& Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. s For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3,etc.)? yes If yes, provide the Company Equipment Identification No. C-604 General description of equipment and purpose: inlet gas compression For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? Yes ❑No (http://www.colorado.gov/cdphe/attainment) ❑J Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 A COLORADO Form APCD-2O1 • Spark Ignition Engine APEN - Revision 7/2018 2 I M "^t:F,.•.,,,,, ..., Permit Number: AIRS ID Number: 123 i9DF7 [Leave blank unless APCD has already assigned a permit q and AIRS ID) Section 4 - Engine Information Engine Function: ❑Primary and/or Peaking Power O Emergency(max. 500 hrs/year) 0 Compression ❑Pump Jack ❑Water Pump O Other: What is the maximum number of hours this engine wilt be used for emergency back-up power? 0 hours/year Engine Make: Caterpiller Engine Model: G3516J Serial Number7: TBD What is the maximum designed horsepower rating? 1380 hp What is the maximum manufacturer's site-rating? 1380 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7447 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke ❑✓ 4-Stroke Combustion: ❑✓ Lean Burn ❑Rich Burn Aspiration: ❑Natural ❑Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes ❑No If yes, what type of AFRC is in use? O OZ Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? ❑✓ Yes O No Engine Dates: What is the manufactured date of this engine? after 7/1/2010 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: The serial number must be submitted if coverage under GP02 is requested. COLORADO Form APCD-2O1 - Spark Ignition Engine APB' - Revision 7/2018 3 I �� Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit/I and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,306.78 m El 4,457,231.83 m N Discharge Height Operator Temp. Flow_Rate velocity Above Ground Level Stack ID No. co , (ACFM) (ft/sec) (feet) - C-604 35 1003 9206 144 Indicate the direction of the Stack outlet (check one) ❑Upward ❑Downward El Upward with obstructing raincap ❑Horizontal El Other(describe): Indicate the stack opening and size: (check one) Q Circular Interior stack diameter(inches): 14 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use • Requested Annual Permit Limit6 (SCF/hour) (MMSCF/year) (MMSCFI year) 10,476 91.8 91.8 From what year is the actual annual amount? 2020 Indicate the type of,fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value(give units): a Requested values will become permit limitations. Requested limit(s)should consider future process growth, 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. ADO Form APCD•2O1 - Spark Ignition Engine APEN - Revision 7/2018 4 I AY COLORADO f�:t LOR `= Permit Number: AIRS ID Number: 123 i9DF7i [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ✓❑Yes ❑No If yes, describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP(PM) PM10 . PM 2.5 - SOX NOx VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory 10 Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)8 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9 99E-03 IbIMMBIu AP-42 0 5 0 5 0 5 0 5 PMio o 9 99E-03 Ib/MMBIu AP-42 0 5 0 5 0.5 0 5 PM 2,5 9-99E-03 Ib/MMBIu AP-42 0.5 05 0-5 05 SOX 5-88E-04 Ib/MMBIu AP-42 0.03 0.03 003 0.03 NOX 0.50 g/hp-hr manufacturer 6 7 6 7 6.7 6 7 VOC 0 91 glhp-hr manufacturer 12 1 3 0 12 1 3 0 CO 2 69 g/hp-hr manufacturer 35 9 2 5 35.9 2.5 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 ❑✓ Yes ❑No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions10 Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 043 g/hp-hr manufacturer 11460 1146 Acetaldehyde 75070 8 36E-03 Ib/MMBIu AP-42 753 376 Acrolein 107028 5.14E-03 Ib/MMBtu AP-42 463 231 Benzene 71432 1 30E-03 Ib/MMBIu GRI 117 59 Other: toluene-108883 815E-03 Ib/MMBIu GRI 734 367 8 Requested values will become permit limitations.requested limit(s)should consider future process growth. 1°Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. Vy COLORADO Farm APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 5 I �V =',7,,':,=, Permit Number: AIRS ID Number: 123 i9DF7/ [Leave blank unless APCD has already assigned a permit M 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GPOZ. . # zh l Signature of Legally Authorized ersdn (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase,increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$1,875,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246.1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.calorado.Rov/cdphe/apcd COLORADO Form APCD-2O1 Spark Ignition Engine APEN - Revision 7/2018 6 I A� TF.:.°'"'"';,. RECEIVED FEB 1 1 2019 10 ,E Spark Ignition .Engine APEN i'`) tationaru t; - Form APCD-201 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 spark ignition(e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options do not meet 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: IQ) t AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 1 - Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W county: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E-Mail AddressZ: ehinkley@redcedargathering.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. • 393274 COLORADO Form APCD-2O1 - Spark Ignition Engine APEN Revision 7/2018 1 I AV Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit if and AIRS ID) Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source(check one below) ❑✓ STATIONARY source ❑ PORTABLE source ✓❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) 4 Add point to existing ❑ Change fuel or equipment El Change company name ❑ permit O Change permit limit O Transfer of ownerships ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement& Additional Info Et Notes: two (2) identical units to be installed with one as backup; operation limited to 8,760 hr/yr between the units (4,380 hr/yr each on average) 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for A0S permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. C-410 General description of equipment and purpose: propane compression For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? El Yes No (http://www.cotorado.gov/cdphe/attainment) ❑ Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I A� '��F.,=' Permit Number: AIRS ID Number: 1 23 i9DF7/ [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 4 - Engine Information Engine Function: O Primary and/or Peaking Power O Emergency(max. 500 hrs/year) ❑✓ Compression ❑Pump Jack ❑Water Pump ❑Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpiller Engine Model: G3512B Serial Number7: TBD What is the maximum designed horsepower rating? 1O35 hp What is the maximum manufacturer's site-rating? 1O35 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7254 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke D 4-Stroke Combustion: Lean Burn ❑Rich Burn Aspiration: ❑Natural El Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ✓❑Yes ❑No If yes,what type of AFRC is in use? ❑02 Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NO=design? Q Yes ❑No Engine Dates: What is the manufactured date of this engine? after 1/1/2OO8 What date was this engine ordered? — May 2011 What is the date this engine was first located to Colorado? after 7/1/2O1O What is the date this engine was first placed in service/operation? —Jan 2O12 What is the date this engine commenced construction? — May 2011 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes ✓❑No • If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP0Z is requested. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 I � 1=7,=��'�.„ Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,366.29 El 4,457,236.89 N Discharge Height Operator - _ -Temp. Flow Rate Velocity Above Ground Level Stack ID No. (�F) • S (ACFM) • (ft/sec) (feet) C-410 30 983 6,654 51 Indicate the direction of the Stack outlet (check one) 0 Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 20 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit Limits (SCF/hour) (MMSCF/year) (MMSCF/year) 7,653 67.0 67.0 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) 0 Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value= BTU/scf ❑Other(describe): Heating Value (give units): Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO Form APCD-201 - Spark Ignition Engine APEN -Revision 7/2018 4 I Permit Number: AIRS ID Number: 123 /9DF7/ , [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? OYes ❑No If yes, describe the control equipment AID state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP(PM) PM10 PM2.5 SOx NOx . VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions70 Emission Limit(s)8 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9 99E-03 Ib/MMBtu AP-42 0 3 0 3 0 3 0 3 PM 10 9 99E-03 Ib/MMBtu AP-42 0 3 0.3 • 0 3 0 3 PM2,5 9 99E-03 Ib/MMBtu AP-42 0.3 0.3 0,3 03 SOx 5 88E-04 Ib/MM8tu AP-42 0 02 0 02 0 02 002 NOx 0 50 - g/hp-hr manufacturer 5 0 5 0 5 0 5 0 VOC 1 82 g/hp-hr manufacturer 18 2 4 6 18.2 4 6 CO 2 80 g/hp-hr manufacturer 28.0 2 0 28 0 2.0 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 El Yes ❑No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions10 Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) UncontrolledUnits (AP-42, Emissions Emissions Number Basis Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 047 g/hp-hr manufacturer 9,395 939 Acetaldehyde 75070 8 36E-03 Ib/MMBtu AP-42 550 275 Acrolein 107028 5 14E-03 Ib/MMBtu AP-42 338 168 Benzene 71432 1 30E-03 Ib/MMBtu GRI 86 43 Other: toluene-108883 8 15E-03 IbIMMBtu GRI 536 268 8 Requested values will become permit limitations.)tequested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual=ohtrolled emissions reported.If source has not yet started operating,leave blank. ' COLORADO Form APCD-201 -Spark Ignition Engine APEN - Revision 7/2018 5 1 A „4,," :..°"" Permit Number: AIRS ID Number: 1 23 /9DF7/ • [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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. zJI Al Signature of Legally Authorized Per a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result I.an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and tie General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303) 692-3175 or(303)692-3148 Air Pollution Control Division APCD-5S-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/apcd COLORADO Form APCD-201 Spark Ignition Engine APEN - Revision 7/2018 6 I �� > ;4 !mss Spark Ignition Engine APEN � � ► Form APCD-201 '' 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 spark ignition (e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine (e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific AI?£N for your source(e.g.compression ignition engine, mining operations, asphalt plant,crusher, screen, etc.). In addition,the General APEN (Form APCD-200)is available if the specialty APEN options do not meet your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at:www.00lorado.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.)i. See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: q C,t 2 AIRS ID Number: 123 /9DF7/ Ck [Leave blank unless APCD has already assigned a permit 11 and AIRS ID] Section 1 -Administrative Information Company Name': Aka Energy Group, LLC site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31,T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 813O1 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source E-Mail Address2 Home Base: ehinkiey@redcedargathering,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 wilt be issued by the APCD via e-mail to the address provided. 393275 COLORADO Form APCD-2O1 - Spark Ignition Engine APEW - Revision 7/2018 1 I �� Permit Number: AIRS ID Number: 123 i9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly-reported emission source(check one below) O STATIONARY source ❑ PORTABLE source O Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) Add point to existing ❑ Change fuel or equipment ❑ Change company name4 O permit O Change permit limit O Transfer of ownerships O Other(describe below) -OR- ❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info a Notes: two (2) identical units to be installed with one as backup; operation limited to 8,760 hr/yr between the units (4,380 hr/yr each on average) 3 Only one engine may be reported per APEN far GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for A0S permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1,Engine 3, etc.)? yes If yes, provide the Company Equipment identification No. C-411 General description of equipment and purpose: propane compression For existing sources,operation began ort For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? El Yes ❑No (http://www.colorado.eov/cdphe/attaisiment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 Q� COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I AV �` Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Engine Information Engine Function: 0 Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) ❑✓ Compression ❑Pump Jack ❑Water Pump ❑Other: What is the maximum number of hours this engine wilt be used for emergency back-up power? 0 hours/year • Engine Make: Caterpiller Engine Model: G3512B Serial Number7: TBD What is the maximum designed horsepower rating? 1035 hp What is the maximum manufacturer's site-rating? 1035 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7254 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke ❑✓ 4-Stroke Combustion: ❑✓ Lean Burn ❑Rich Burn Aspiration: ❑Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ❑✓ Yes ❑No If yes,what type of AFRC is in use? ❑02 Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? ❑✓ Yes 0 No Engine Dates: What is the manufactured date of this engine? after 1/1/2008 What date was this engine ordered? — May 2011 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? —Jan 2012 What is the date this engine commenced construction? — May 2011 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: The serial number must be submitted if coverage under GP02 is requested. • COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 3 1 AV k: Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit u and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,366.40 E/ 4,457,246.03 N Discharge Height Operator Temp ? Flow Rate' Velocity Above GrourI Level Stack ID 140- (F) .: (ACFM) - -(ft/sec) C-411 30 983 6,654 51 Indicate the direction of the Stack outlet (check one) ✓❑Upward ❑Downward ❑Upward with obstructing raincap ' ❑Horizontal ❑Other(describe): Indicate the stack opening and-size: (check one) E]Circular Interior stack diameter(inches): 2O ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load - Actual Annual Fuel Use Requested Annual Permit Limite (SCF/hour)- (MMSCF/year) (MMSCF/year) • 7,653 67.0 67.0 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value (give units): 8 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. QQ COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I m ':`:_:'';.:,.::i. Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank unless APCD has already assigned a permit t/and AIRS ID) Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? []✓ Yes 0 No If yes, describe the control equipment AID state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP(PM)' PMto . PM 2.5 SOx NOx - VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%. Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions10 Requested Annual Permit • Pollutant Emission Limit(s)8_ Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9.99E-03 Ib/MMBIu AP-42 0,3 03 0.3 03 PM 10 9 99E-03 Ib/MMBtu AP-42 03 0 3 0.3 0 3 PM 2.5 9 99E-03 IbIMMBtu AP-42 0.3 0.3 0 3 0 3 SOX 5.88E-04 Ib/MMBtu AP-42 0.02 0,02 0O2 0.02 NOx 0.50 glhp-hr manufacturer 50 50 50 5O • VOC 182 g/hp-hr manufacturer 18.2 - 4.6 18.2 4.6 CO 2 80 g/hp-hr manufacturer 28.0 2 0 28 0 2 0 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 0 Yes 0 No . lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions10 • Chemical Name Abstract Source Uncontrolled Controlled (CAS) Units (AP-42 Service Uncontrolled , Basis Emissions Emissions Number Mfg.etc) (pounds/year) , (pounds/year) Formaldehyde 50000 047 a/hp-hr manufacturer 9,395 939 Acetaldehyde 75070 8.36E-03 Ib/MMBtu AP-42 550 275 Acrolein 107028 5,14E-03 lb/MMBIu AP-42 338 16B Benzene 71432 1.30E-03 Ib/MMBtu GRI 86 43 Other: toluene-108883 8 15E-03 IbIMMBtu GRI 536 268 8 Requested values will become permit limitations.1Requested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 5 I eV ":w7:7:.!..',I,I'::., Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank unless APCD has already assigned a permit f/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 GP02, I further certify that this source is and wilt be operated in full compliance with each condition of General Permit GP02. G✓. ft,L8 Signature of Legally Authorized P rson ( of a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: ❑/ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.$ov/cdphe/apcd COLORADO Form APCD-2O1 -Spark Ignition Engine APEN - Revision 7/2018 6 A� ,*, ''.42=. 1.0 Spark Ignition Engine APEN es osks cDfHE N.NcGSo Co Form APCD-201 i 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 spark ignition (e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made (significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 1 SW C 0 AIRS ID Number: 123 /9DF7/ O k [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name1: Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E-Mail Address 2: ehinkley@redcedargathering.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393276 [� COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 1 I AV H',',F.=,, Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action • NEW permit OR newly-reported emission source(check one below) ❑✓ STATIONARY source ❑ PORTABLE source ✓❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested,the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) Add point to existing O Change fuel or equipment 0 Change company name 0 permit ❑ Change permit limit 0 Transfer of ownerships ❑ Other(describe below) -OR • APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info a Notes: (3)identical units to be installed with one(1)operating as a backup unit only; the(3) units are limited to 17,520 hr/yr total operation (5,840 hr/yr each on average) 3 Only one engine may be reported per APEN far GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. C-651 General description of equipment and purpose: residue gas compression For existing sources, operation began orc TBD For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? ID Yes ❑No (http://www.colorado.4ov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 GOLORA DO Form APCD-201 -Spark Ignition Engine APEN • Revision 7/2018 2 I m Permit Number: AIRS ID Number: 123 i9DF7 [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 4 - Engine Information Engine Function: O Primary and/or Peaking Power O Emergency(max. 500 hrs/year) 0 Compression O Pump Jack ❑Water Pump O Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpillar Engine Model: G3608 Serial Number7: TBD What is the maximum designed horsepower rating? 2,500 hp What is the maximum manufacturer's site-rating? 2,500 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 6,853 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke 0 4-Stroke Combustion: 0 Lean Burn ❑Rich Burn Aspiration: ❑Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? El Yes ❑No If yes,what type of AFRC is in use? ❑Oz Sensor(mV) ❑NOx Sensor(ppm) O Other: Is this engine equipped with a Low-NOx design? 0 Yes ❑No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? O Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 I M� ,,=F„,°,= • Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,365.95 E/ 4,457,209.46 N Discharge Height Operator-Temp: - Flow Rate' Velocity __ Above Ground Level F ACFM) (fr(sec) . Stack ID No. (° ) •.. _ - (feet] . C-651 33.13 826 12000 92 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ✓❑Circular Interior stack diameter(inches): 20 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information -Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit Limite (SCF/hour) - (MMSCF/year) (MMSCF/year);. 17,464 102.0 153.0 From what year is the actual annual amount? , 2020 Indicate the type of fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value(give units): 8 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. • COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I AtiiVi Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑No , If yes,describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) • - TSP(PM) • - PMio • PM2.5 SOx . NOx - VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions" Emission Limit(s)8 Pollutant - Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/}rear) (tons/year) (tons/year) TSP(PM) 9.99E-03 lb/MMBtu AP-42 0.5 0.5 0 8 0 8 PM10 999E-03 lb/MMBtu AP-42 05 05 08 08 PM2,5 999E-03 lb/MMBtu AP-42 05 05 08 08 SOX 5.86E-04 lb/MMBtu AP-42 0 03 0 03 0.04 0 04 NOx 0 30 g/hp-hr manufacturer 4 8 4 8 7 2 7.2 VOC 044 g/hp-hr manufacturer 71 18 10.6 2.7 CO 2 58 g/hp-hr manufacturer 41 5 2 9 62.3 4-4 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 0 Yes O No • lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissionst° Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 0.16 g/hp-hr manufacturer 7,725 773 Acetaldehyde 75070 8.36E-03 Ib/MMBIu AP-42 1,254 627 Acrolein 107028 5.14E-03 lb/MMBtu AP-42 771 386 Benzene 71432 1.30E-03 lb/MMBtu GRI 195 98 Other: toluene-106883 8 15E-03 lb/MMBtu GRI 1,223 611 8 Requested values will become permit limitations.,tequested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. COLORADO Form APCD 201 Spark Ignition Engine APENRevision 7/2018 5 AV •l• ;F;:Z:.F',„`"„ Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit N 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 fro coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. . ,,r 4'0 2 f I f i' Signature of Legally Authorized P�r�(not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance []Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc. .See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program ' Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303) 692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd pp COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 6 I m� NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: .gW16 `ej' AIRS ID Number: 123/9DF7/ O i Company Name: Aka Energy Group, LLC Plant Location: SW/4 Section 31, T4N, R65W County: Weld Zip Code: Person to Contact: Ethan Hinkley Phone Number: (970) 764-6495 E-mail Address: ehinkley@redcedargathering.com Fax Number: Chemical Abstract Control Equipment Emission Factor Emission Factor Uncontrolled Controlled Actual Service (CAS) Chemical Name / Reduction (%) (Include Units) Source Actual Emissions Emissions Number (lbs/year) (lbs/year) 67-56-1 methanol oxidation catalyst/50% 2.50E-03 lb/MMBtu AP-42 375 188 Calendar Year for which Actual Data Applies: / -- lJ - � Z��flf Signature of Person Leggy'Authorized to Supply Data Date Ethan Hinkley Air Quality Compliance Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14. 2014 OCV- tie$ CDPHE A Spark Ignition Engine APEN ��cv Form APCD-201 CO 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 spark ignition(e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options do not meet 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: l g y 0 1 'f' AIRS ID Number: 123 /9DF7// 0 [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 1 -Administrative Information Company Namet: Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: ehinkley@redcedargathering.com Mail Address ehinkley@redcedargathering.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 3932'7 COLORADO Form APCD-201 -Spark Ignition Engine APEN • Revision 7/2018 1 I c eri Permit Number: MRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit q and AIRS ID] Section 2- Requested Action El NEW permit OR newly-reported emission source(check one below) El STATIONARY source ❑ PORTABLE source ✓❑ Request coverage under a Construction Permit ❑ .Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit rcheck each box below that applies) Add point to existing O Change fuel or equipment 0 Change company name 0 permit D Change permit limit 0 Transfer of ownerships ❑ Other(describe below) -OR- ❑ APEN submittal for update only(plank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacements Additional Info Et Notes: (3) identical units to be installed with one(1)operating as a backup unit only; the(3) units are limited to 17,520 hr/yr total operation (5,840 hr/yr each on average) 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No, (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. C-652 General description of equipment and purpose: residue gas compression For existing sources, operation began on: TBD For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? Yes O No (http://www.cotorado.gov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I �►� Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Engine Information Engine Function: ❑Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) Q Compression ['Pump Jack O Water Pump ❑Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpillar Engine Model: G3608 Serial Number: TBD What is the maximum designed horsepower rating? 2,500 hp What is the maximum manufacturer's site-rating? 2,500 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 6,853 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke 0 4-Stroke Combustion: 0 Lean Burn O Rich Burn Aspiration: ❑Natural Q Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes ❑No If yes, what type of AFRC is in use? ❑Oz Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? ❑✓ Yes ❑No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes ✓❑No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. AIM COLORADO Form APCD-2O1 -Spark Ignition Engine APEN - Revision 7/2018 3 I Lam® "' F"•:,.,',' Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit//and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,366.06 El 4,457,218.60 N Discharge Height. Operator' - Temp.- Flow Rate; Velocity Above Ground Level: _ Stack ID No. - _ - (F) _,.- _ - • e (ACFM) ;` -r _(ft/tea) .. - C-652 33.13 826 12000 92 Indicate the direction of the Stack outlet (check one) 0 Upward El Downward El Upward with obstructing raincap ❑Horizontal Other(describe): Indicate the stack opening and size: (check one) O Circular Interior stack diameter(inches): 20 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): Ei Other(describe): Section 6 -Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit-Limits SCFlhour (MMSCF/ ear (NLMSCF/year) 17,464 102.0 153.0 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ['Field Natural Gas Heating value: 981 BTU/scf Propane (assumed fuel heating value of 2,300 BTU/scf) El Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value(give units): a Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I ail,V Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit q and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form.The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. 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): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP (PM) PM10 . PM2.5 . SOx . NOx . VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor • Actual Annual Emissions10 Emission Limit(s)8 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions • Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9 99E-03 IbIMMBtu AP-42 0 5 0 5 0.8 0 8 PM 10 9,99E-03 lb/MMBtu AP-42 0.5 05 0 8 0.8 PM 2.5 9.99E-03 Ib/MMBtu AP-42 0 5 0 5 0.8 0 9 SOx 5 88E-04 lb/MMBtu AP-42 0.D3 0.03 004 0.04 NOx coo g/hp-hr manufacturer 4.8 4 8 7.2 7.2 VOC 0.44 g/hp-hr manufacturer 7 1 1 8 10.6 2 7 CO 2 58 g/hp.hr manufacturer 41-5 2 9 62.3 4 4 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 ❑✓ Yes ❑No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions1° Chemical Name Abstract . Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 016 g/hp-hr manufacturer 7,725 773 Acetaldehyde 75070 8.36E-03 lb/MMBtu AP-42 1,254 627 Acrolein 107028 5 14E-03 Ib/MMBIu AP-42 771 386 Benzene 71432 1 30E-03 Ib/MMBIu GRI 195 98 • Other: toluene-108883 8.15E-03 Ib/MMBtu GRI 1,223 611 B Requested values will become permit limitations.requested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. AN., Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 5 I Y ZrZ,. Permit Number: AIRS ID Number: 123 /9DF7I [Leave blank unless APCD has already assigned a permit ft 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 GP02, I further certify that this source is and wilt be operated in full compliance with each condition of General Permit GP02. 2 )/iq Signature of Legally Authorize er n(not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result i■an increased fee and/or processing time) . This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. • Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303) 692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/apcd COLORADO Form APCD-201 Spark Ignition Engine AI'EN - Revision 7/2018 6 I • NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: ccLAJE4 l c. - AIRS ID Number: 123/9DF7/ O 1. 1 Company Name: Aka Energy Group, LLC Plant Location: SW/4 Section 31, T4N, R65W County: Weld Zip Code: Person to Contact: Ethan Hinkley Phone Number: (970) 764-6495 E-mail Address: ehinkley@redcedargathering.com Fax Number: Chemical Abstract Control Equipment Emission Factor Emission Factor Uncontrolled Controlled Actual Service (CAS) Chemical Name / Reduction (%) Actual Emissions Emissions Number (Include Units) Source (lbs/year) (lbs/year) 67-56-1 methanol oxidation catalyst/50% 2.50E-03 Ib/MMBtu AP-42 375 188 Calendar Year for which Actual Data Applies: 19' 2/Iiiq Signature of Person Legally orized to Supply Data Date Ethan Hinkley Air Quality Compliance Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14, 2014 0.0% PHE Spark Ignition Engine APEN etc a _ Form APCD-201 Sces C© ✓� 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 spark ignition (e.g. gas-fired)reciprocating internal combustion engines (RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g.compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options do not meet your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.nov/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: 190 1C9 AIRS ID Number: 123 /9DF7/ 7 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information • Company Namei: Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or sic Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E-Mail AddressZ: ehinkley@redcedargathering.com 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393273 ,[[��q COLORADO Form APCD-2O1 -Spark Ignition Engine APEN - Revision 7/2018 1 I L3�Xi' Permit Number: AIRS ID Number: 1 23 i9DF7/ [Leave blank uriess APCD has already assigned a permit N and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source(check one below) • STATIONARY source ❑ PORTABLE source ❑✓ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested,the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- O MODIFICATION to existing permit(check each box below that applies) Add point to existing ❑ Change fuel or equipment O Change company name4 D permit ❑ Change permit limit ❑ Transfer of ownerships O Other(describe below) -OR- ❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ID APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacements Additional Info li Notes: (3) identical units to be installed with one(1)operating as a backup unit only; the (3) units are limited to 17,520 hr/yr total operation (5,840 hr/yr each on average) 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 -General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. C-653 General description of equipment and purpose: residue gas compression For existing sources, operation began on: TBD For new or reconstructed sources,the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? Yes ❑No (http://www.colorado.eov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 - - COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I � Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit//and AIRS ID] Section 4 - Engine Information Engine Function: 0 Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) ❑✓ Compression O Pump Jack 0 Water Pump ❑Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpillar Engine Model: G3608 Serial Number7: TBD What is the maximum designed horsepower rating? 2,500 hp What is the maximum manufacturer's site-rating? 2,500 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 6,853 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke 0 4-Stroke Combustion: ❑✓ Lean Burn ❑Rich Burn Aspiration: ❑Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ✓❑Yes ❑No If yes,what type of AFRC is in use? ❑O2 Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? 0 Yes ❑No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? O Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP©2 is requested. co►oRAoo Form APCD-201 -Spark Ignition Engine APEN - Revision 7/2018 3 I „` - ".a Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit 11 and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude(Longitude or UTM) 524,366.18 El 4,457,227.75 N Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level Stack ID No. �. ('F1 (ACFM) h(ft/sec) (feet) C-653 33.13 826 12000 92 Indicate the direction of the Stack outlet: (check one) ✓❑Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) 0✓ Circular Interior stack diameter(inches); 20 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate 100%Load Actual Annual Fuel Use - Requested Annual Permit Limite (SCF/hour) (MMSCF/year) (MMSCF/year) 17,464 102.0 153.0 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ✓❑Field Natural Gas Heating value_ 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value(give units): 8 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO Form APCD-201 Spark Ignition Engine APEN - Revision 7/2018 4 I AV • Permit Number: AIRS ID Number: 123 i9DF71 [Leave blank unless APCD has already assigned a permit Jt and AIRS ID] Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? OYes ❑No If yes,describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (Y reduction in emissions) TSP(PM) PM 10 - PM 2,5 SOx NOx VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions10 Emission Limit(s)e Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9 99E-03 lb/MMBtu AP-42 0 5 0 5 0.8 0.8 PM10 9.99E-03 Ib/MMBtu AP-42 05 0.5 0.8 08 PM2.5 9 99E-03 lb/MMBtu AP-42 0.5 0 5 0 8 0 8 SOX 5.88E-04 lb/MMBtu AP-42 0.03 0.03 004 004 NOx 0.30 g/hp-hr manufacturer 4 8 4 8 7 2 7 2 VOC 0 44 g/hp-hr manufacturer 7-1 1 8 10.6 2,7 CO 2 58 glhp-hr manufacturer 41 5 2.9 62 3 4.4 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 p Yes El No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory • Chemical Emission Factor Actual Annual Emissions1° Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Basis. Units (AP-42, Emissions Emissions Number Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 016 g/hp-hr manufacturer 7,725 773 Acetaldehyde 75070 8.36E-03 Ib1MMBtu AP-12 1,254 627 Acrolein 107028 5.14E-03 IbIMMBtu AP-42 771 386 Benzene 71432 130E-03 lb/MMBtu GRI 195 98 Other: toluene-108883 815E-03 Ib/MMBtu GRI 1,223 611 8 Requested values will become permit limitations.requested limit(s)should consider future process growth. la Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. COLORADO Form APCD-20'I - Spark Ignition Engine APEN - Revision 7/2018 5 I A Zs,n''F.`.;,L.`., Permit Number: AIRS ID Number: 123 i9DF7/ [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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. �--k 21;1)9 Signature of Legally Authoriz a son (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303) 692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colarado.gov/cdphe/avcd COLORADO Form APCD-201 Spark Ignition Engine APEN - Revision 7/2018 6 I H.AI tr E.vi..gym.•_ NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: Is kA) 15 L.1 AIRS ID Number: 123/9DF7/ 0 i7 --- Company Name: Aka Energy Group, LLC Plant Location: SW/4 Section 31, T4N, R65W County: Weld Zip Code: Person to Contact: Ethan Hinkley Phone Number: (970) 764-6495 E-mail Address: ehinkley@redcedargathering.com Fax Number: Chemical Abstract Control Equipment Emission Factor Emission Factor Uncontrolled Controlled Actual Service (CAS) Chemical Name / Reduction (%) Actual Emissions Emissions Number (Include Units) Source (Ibs/year) (lbs/year) 67-56-1 methanol oxidation catalyst/50% 2.50E-03 Ib/MMBtu AP-42 375 188 Calendar Year for which Actual Data Applies: —G✓. . 2/t /17 Signature of Person Legg1Authorized to Supply Data Date Ethan Hinkley Air Quality Compliance Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14,2014 RECEIVED FEB 1 1 2019 APCD Spark Ignition Engine APEN t;teo t CDPiHE' - ►7 Form APCD-201 CO 'itsr 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 spark ignition(e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g.compression ignition engine, mining operations, asphalt plant,crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options do not meet 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: ki,j3k5V AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 • Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E-Mail AddressZ: ehinkley@redcedargathering.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 wilt require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393273 ANY COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 1 I A� 11:r.117g..°=,. Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly-reported emission source(check one below) ❑r STATIONARY source ❑ PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the ADEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) Add point to existing ElChange fuel or equipment ElChange company name El permit ❑ Change permit limit O Transfer of ownerships ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement& Additional Info Et Notes: (3)identicaltemporary units to be installed with one(1)operating as a backup unk only; the(3)units are limited to 17,520 hr/yr total operation(5,840 hr/yr each on average) 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. G-771 General description of equipment and purpose: driver for generator set For existing sources,operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? ❑Yes ❑No (http://www.colorado.nov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: Z5 Sept-Nov: 25 COLON A DO Form APCD-201 - Spark Ignition Engine AREN - Revision 7/2018 2 I my 7.=F"'?=, Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit p and AIRS ID] Section 4 - Engine Information Engine Function: ❑✓ Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) ❑Compression ❑Pump Jack ❑Water Pump ❑Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpiller Engine Model: G3516C Serial Number7: TBD What is the maximum designed horsepower rating? 2,175 hp What is the maximum manufacturer's site-rating? 2,077 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 6,929 BTU/hp-hr Engine Features: Cycle Type: O 2-Stroke D 4-Stroke Combustion: 0 Lean Burn O Rich Burn Aspiration: ❑Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes ❑No If yes,what type of AFRC is in use? O O2 Sensor(mV) ❑NOx Sensor(ppm) El Other: Is this engine equipped with a Low-NOx design? 0 Yes ❑No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? D Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. • COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 3 I �0 :.v:t. :,, Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit ti and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,269.07 E/ 4,457,163.40 N Discharge.•Height Operator Temp.f Flow Rate -Velocity Above Ground Level p atFM) . (ftsec) =Stack ID No. ( }._ . G-771 21 854 12,366 148 Indicate the direction of the Stack outlet: (check one) 0 Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter(inches): 16 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑Other(describe): Section 6- Fuel Data and Throughput Information Fuel Use Rate @ 100%Load. Actual Annual Fuel Use _ _ ; Requested Annual Permit Limite, (SCF/hour) (MMSCF/year)• (MMSCF/year) 14,670 85.7 128.5 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ['Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value (give units): B Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO ANIF Form APCD-201 Spark Ignition Engine APEN - Revision 7/2018 4 I l • _ Permit Number: AIRS ID Number: 123 /9DF7i [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form.The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? p✓ Yes D No If yes, describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP (PM) PM10 PM2.5 SOx - NOx VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 ' Criteria Pollutant Emissions Inventory 1 Emission Factor Actual Annual Emissions— Requested EmissionPermit Limit(s)8 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions Basis Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9 99E-03 Ib/MMBtu AP-42 -0 4 0 4 0.6 0.6 PM10 9 99E-03 Ib/MMBtu AP-42 04 04 0.6 06 PM 2.5 9 99E-03 Ib/MMBtu AP-42 0 4 0 4 0 6 0 6 SOX 5.88E-04 Ib/MMBtu AP-42 0.02 0 02 0 04 0 04. NOx 050 g/hp-hr manufacturer 67 6-7 10.0 100 VOC 1 09 g/hp-hr manufacturer 14 6 3 6 21 9 5 5 CO 2.30 g/hp-hr manufacturer 30 8 2 2 46.1 3 2 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 J Yes D No lbs/year? If yes, please use the following table to report the non-criteria pollutant,(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions" Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.etc/ (pounds/year) (pounds/year) • Formaldehyde 50000 0 53 g/hp-hr manufacturer 21.259 2,126 Acetaldehyde 75070 836E-03 Ib/MMBtu AP-42 1,054 527 Acrolein 107028 5 14E-03 Ib/MMBtu AP-42 648 324 Benzene 71432 1 30E-03 Ib/Mt14Btu GRI 164 82 Other: toluene-108683 8.15E-03 Ib/MMBtu GRI 1,027 514 8 Requested values will become permit limitations.requested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. �y COLORADO Form APCD-201 Spark Ignition Engine APEN Revision 7/2018 5 I L3Z® =:,-`;""":: Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit n 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. tt) - �9�� 21/ 111 Signature of Legally Authorized R&sen (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.eov/cdphe/aped A� a COLORADO Form APCD 201 Spark Ignition Engine APEN Revision 7/2018 6 I NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: t'UUg- O S 1 AIRS ID Number: 123/9DF7/ 0 l-, Company Name: Aka Energy Group, LLC Plant Location: SW/4 Section 31, T4N, R65W County: Weld Zip Code: Person to Contact: Ethan Hinkley Phone Number: (970) 764-6495 E-mail Address: ehinkley@redcedargathering.com Fax Number: Chemical Abstract Control Equipment Emission Factor Emission Factor Uncontrolled Controlled Actual Service(CAS) Chemical Name (%) Actual Emissions Emissions Number /Reduction (Include Units) Source (lbs/yea!) (lbs/year) 67-56-1 methanol oxidation catalyst/50% 2.50E-03 lb/MMBtu AP-42 315 158 Calendar Year for which Actual Data Applies: Signature of Person Lega thorized to Supply Data Date Ethan Hinkley Air Quality Compliance Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14. 2014 RECENED FEB 1 1 2019 Ap CD Spark Ignition Engine APEN stationary, ACDPF)E" Sources AtICV Form APCD-201 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 spark ignition (e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-2OO)is available if the specialty APEN options do not meet your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at: www.colorado.eov/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, rtiew equipment,change in fuel type,etc.).. See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: t AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source Home Base: E-Mail Addressz: ehinkley@redcedargathering.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393280 COLORADO Form APCD-2O1 - Spark Ignition Engine APEN . Revision 7/2018 1 I Avg, � Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit t/and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source(check one below) ✓❑ STATIONARY source O PORTABLE source ✓❑ Request coverage under a Construction Permit O Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) Add point to existing ❑ Change fuel or equipment O Change company name ❑ permit ❑ Change permit limit ❑ Transfer of ownerships ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info&Notes: (3) identical temporary units to be installed with one(1)operating as a backup unit only; the(3)units are limited to 17,520 hr/yr total operation(5,840 hr/yr each on average) 3 Only bne engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. s For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does not apply to General Permit GPO?,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yeS If yes, provide the Company Equipment Identification No. G-772 General description of equipment and purpose: driver for generator set For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.gov/cdphe/attainment) ❑✓ Yes El No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 AV' COLORADO Form APCD 201 Spark Ignition Engine APEN Revision 7/2018 2 I t��i ° lvrg,," `N..�n 4Fnv�+ni YIOI Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Engine Information Engine Function: Q Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) Compression El Pump Jack ❑Water Pump 0 Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpiller Engine Model: G3516C Serial Number7: TBD What is the maximum designed horsepower rating? 2,175 hp What is the maximum manufacturer's site-rating? 2,077 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 6,929 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke El 4-Stroke Combustion: Lean Burn O Rich Burn Aspiration: ❑Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ✓E Yes ❑No If yes,what type of AFRC is in use? D 02 Sensor(mV) ❑N05 Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? Yes ❑No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes ❑✓ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 'The serial number must be submitted if coverage under GP02 is requested. COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 3 I Aii xtF„" Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,274.25 El 4,457,163.33 N Discharge Height Operator = - Temp., Flow Rate.;; Velocity Above Ground Level -'Stack ID No. 1 F) �.(ACFM) (ft%rec) (feet) .::: � _ . _ . .: . G-772 21 854 12,366 148 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑Downward D Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ▪Circular Interior stack diameter(inches): 16 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑Other(describe):. Section 6- Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use - --Requested Annual Permit Limit1 _ (SCF/hour) (MMSCF/year)- (MMSCFI year) 14,670 85.7 128.5 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: 981 BTU/scf ❑Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value(give units): I Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO Form APCD-201 - Spark Ignition Engine APEN Revision 7/2018 4 I AI" Permit Number: AIRS ID Number: 123 i9DF7i [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0 Yes 0 No If yes, describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP(PM) - PM1D • • PM 2.6 SOX . NOx VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions10 Emission Limit(s)8 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 9 99E-03 IbIMMBtu AP-42 0.4 0 4 0 6 0.6 PM 10 9.99E-03 Ib/MMBtu AP-42 0 4 0 4 0 6 0 6 PMz.s 9 99E-03 IbIMMBtu AP-42 04 0.4 06 06 SOx 5.88E-04 lb/MMBtu AP-42 0.02 002 0.04 004 - NOx 050 g/hp-hr manufacturer 67 67 100 10.0 VOC 1 09 g/hp-hr manufacturer 14 6 36 21-9 5 5 CO 2 30 g/hp-hr manufacturer 30 8 2 2 46 1 3 2 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 0 Yes O No Ibs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions10 Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Basis Units (AP-42, Emissions Emissions Number Mfg.etc) (pounds/year) (pounds/year) Formaldehyde 50000 0.53 g/hp-hr manufacturer 21,259 2,126 Acetaldehyde 75070 836E-03 Ib/MMBtu AP-42 1,054 527 Acrolein 107028 5.14E-03 Ib/MMBIu AP-42 648 324 Benzene 71432 1 30E-03 Ib/MMBIu GRI 164 82 Other: toluene•108883 815E-03 Ib/MMBIu GRI 1,027 514 B Requested values will become permit Limitations.Jtequested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. AV COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 5 I m® '1'F'`''" ` Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank unless APCD has already assigned a permit p 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. - GtJ . 2/I/11 Signature of Legally Authorized P rss (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance 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) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-81 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.Qov/cdphe/apcd COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 6 I �� Y' NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: \. O\ + AIRS ID Number: 123/9DF7/ C5 ( Company Name: Aka Energy Group, LLC Plant Location: SW/4 Section 31, T4N, R65W County: Weld Zip Code: Person to Contact: Ethan Hinkley Phone Number: (970) 764-6495 E-mail Address: ehinkley@redcedargathering.com Fax Number: Chemical Abstract Control Equipment Emission Factor Emission Factor Uncontrolled Controlled Actual Service (CAS) Chemical Name (%) Actual Emissions Emissions Number / Reduction (Include Units) Source (lbs/year) (lbs/year) 67-56-1 methanol oxidation catalyst/50% 2.50E-03 lb/MMBtu AP-42 315 158 Calendar Year for which Actual Data Applies: tAJ 2f1 i14 Signature of Person L Authorized to Supply Data Date Ethan Hinkley Air Quality Compliance Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14,2014 RECEIVED FEB l 1 2019 APCD Stationary �� Spark Ignition Engine APEN Form APCD-201 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 spark ignition(e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant,crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options do not meet your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.Qov/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: V ilk! t — AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location: Site Location SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 Portable Source E-Mail Address2 Home Base: ehinkley@redcedargathering.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393281 w COLORADO Form APCD-2O1 Spark Ignition Engine APEN - Revision 7/2018 • Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2- Requested Action (] NEW permit OR newly-reported emission source(check one below) 0 STATIONARY source ❑ PORTABLE source ✓❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) 4 Add point to existing ❑ Change fuel or equipment ❑ Change company name 0 permit ❑ Change permit limit 0 Transfer of ownerships ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info Et Notes: (3)identical temporary units to be installed with one(1)operating as a backup unit only; the(3)units are limited to 17,520 hr/yr total operation(5,840 hr/yr each on average) 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GPOZ is voluntary. 4 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. s For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. 6 This does pot apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? yes If yes, provide the Company Equipment Identification No. G-773 General description of equipment and purpose: driver for generator set For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 Will this equipment be operated in any NAAQS nonattainment area? Yes ❑No (http://www.colorado.Qov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I ® ,"`tF Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Engine Information Engine Function: 0 Primary and/or Peaking Power ❑Emergency(max. 500 hrs/year) ❑Compression O Pump Jack ❑Water Pump ❑Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Caterpiller Engine Model: G3516C Serial Number7: TBD What is the maximum designed horsepower rating? 2,175 hp What is the maximum manufacturer's site-rating? 2,077 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 6,929 BTU/hp-hr Engine Features: Cycle Type: ❑2-Stroke ❑✓ 4-Stroke Combustion: ✓❑Lean Burn O Rich Burn. Aspiration: ❑Natural ✓❑Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ❑✓ Yes ❑No If yes,what type of AFRC is in use? O 02 Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? ❑✓ Yes El No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? pending What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. COLORADO A Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 I P°,T,74P;.,,,`;n, Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit I/and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Lotitude/Longitude.or UTM) 524,279.43 E/ 4,457,163.27 N Discharge Height°� Operator Above—Ground Le Temp. Flow.hate. Velocity vel Stack ID Ho. = (!rp _ 446419 tiksed tfee0 G-773 21 854 12,366 148 Indicate the direction of the Stack outlet: (check one) 0 Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ✓❑Circular Interior stack diameter(inches): 16 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate® 100%Load - Actual Annual Fuel Use = Requested Annual Permit Llmitl (SCF/hour) (MMSCFfyear) (MMSCF/year) 14,670 85.7 128.5 From what year is the actual annual amount? 2020 Indicate the type of fuel used9: O Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) Field Natural Gas Heating value: 981 BTU/scf o Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf ❑Other(describe): Heating Value(give units): s Requested values will become permit limitations.Requested limit(s)should consider future process growth. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. pp COLORADO Form APCD-201 - Spark Ignition Engine APEN- Revision 7/2018 4 I m� Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑No If yes, describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP(PM) PM10 PM2.s SOx NOx - VOC oxidation catalyst 75% CO oxidation catalyst 93% Other: oxidation catalyst formaldehyde 90%,other HAP 50%, Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissionst0 Pollutant Emission Limit(s)8 Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (tons/year) (tons/year) , (tons/year) (tons/year) _ . TSP(PM) 9.99E-03 Ib/MMBtu AP-42 0 4 0.4 0 6 0 6 PMi0 9 99E-03 Ib/MMBtu AP-42 0.4 0,4 06 0.6 PM2.5 9 99E-03 lb/MMBtu AP-42 0 4 0.4 0 6 0 6 SOx 5 88E-04 lb/MMBtu AP-42 0 02 0,02 0.04 0.04 NOx 0 50 glhp-hr nanutacturer 6 7 6 7 10 0 10 0 VOC 1 09 glhp-hr rarufacturer 14 6 3.6 21.9 5.5 CO 2 30 glhp-hr marutacturer 30 8 2 2 46.1 3 2 Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 0 Yes ❑No lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP)emissions from source: W Non-Criteria Reportable Pollutant Emissions Inventory - Chemical Emission Factor Actual Annual Emissions10 Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Basis Units (AP-42, Emissions Emissions Number Mfg.etc) (pounds/year) - _ ,(pounds/year) Formaldehyde 50000 0.53 glhp-hr manufacturer 21,259 2,126 Acetaldehyde 75070 836E-03 lb/MMBtu AP-42 1,054 527 Acrolein 107028 5 14E-03 lb/MMBtu AP-42 648 324 Benzene 71432 1 30E-03 lb/MMBtu GRI 164 82 Other: toluene-108883 9 15E-03 lb/MMBtu GRI 1,027 514 8 Requested values will become permit limitations.,Requested limit(s)should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. . COLORADO Form APCD-2O1 - Spark Ignition Engine APEN - Revision 7/2018 5 I A „'t'�:;�",.'= Permit Number: AIRS ID Number: 123 /9DF7/ [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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GPO2. A),4 211117 Signature of Legally Authorized re on(not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303) 692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/apcd COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 6 I A� h ,1;,', =,, NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: ' l l0 6 Q 14 AIRS ID Number: 123/9DF7/ o 1 S Company Name: Aka Energy Group, LLC Plant Location: SW/4 Section 31, T4N, R65W County: Weld Zip Code: Person to Contact: Ethan Hinkley Phone Number: (970) 764-6495 E-mail Address: ehinkley@redcedargathering.com Fax Number: Chemical Abstract Control Equipment Emission Factor Emission Factor Uncontrolled Controlled Actual Service(CAS) Chemical Name / Reduction (%) Actual Emissions Emissions Number (Include Units) Source (lbs/year) (lbs/year) 67-56-1 methanol oxidation catalyst/50% 2.50E-03 lb/MMBtu AP-42 315 158 Calendar Year for which Actual Data Applies: 2_11 /19 Signature of Person Leg Authorized to Supply Data Date Ethan Hinkley Air Quality Compliance Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14.2014 Fee 4t L) f�a O � t�fr 4 '�°p�l�- Boiler APEN - Form APCD-220 c�� CO1717 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 boilers, hot oil heaters, process heaters,and similar equipment. If your emission unit does not fall into one of these categories, there may be a more specific APEN for your source(e.g. print shop, mining operations, engines, etc.). In addition, the General APEN (Form APCD-2OO)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at: www.colorado.gov/cdphe/aped. Do not complete this form for the following source categories: - Heaters or boilers with a design capacity less than or equal to 5 MMBtu/hour that are fueled solely by natural gas or liquid petroleum gas(LPG). • - Heaters or boilers with a design capacity less than or equal to 10 MMBtu/hour used solely for heating buildings for personal comfort that are fueled solely by natural gas or liquid petroleum gas(LPG). More information can be found in the APEN exempt/permit exempt checklist: https://www.colorado.Qov/pacific/cdphe/apen-or-air-permit-exemptions. 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: 19 to EOl(Q® AIRS ID 123 /9DF7/ O 1 Number: [Leave blank unless APCD has already assigned a permit t/and AIRS ID] Section 1 - Administrative Information Company Namei: Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 7.64-6495 E-Mail Address2: ehinkley@redcedargathering.com 1 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 the APCD via e-mail to the address provid J 3289 . COLORADO Form APCD-220- Boiler APEN - Revision 7/2018 1 1 AV t.g,eti`'::,;:=, Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] • Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) • -ADDITIONAL PERMIT ACTIONS- ✓❑ Limit Hazardous Air Pollutants(RAPS)with a federally-enforceable limit on Potential To Emit(PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info& Notes: low-NOx burners 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: regeneration gas heater (dehydration unit) Manufacturer: TBD Model No.: TBD Serial No.: TBD Company equipment Identification No. H-31 (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 1/1/2020 • Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Seasonal use Dec- Mar- June- Sept- percentage: Feb: May: Aug: Nov: Are you reporting multiple identical boilers on this APEN? ❑Yes No If yes, please describe how the fuel usage will be measured for each boiler(i.e., one meter for all boilers or separate meters for each unit): wAir COLORADO Form APCD-220 - Boiler APEN - Revision 7/2018 2 I m tr,,.4,-•,,.,,,,,,„ Permit Number: AIRS ID Number: 123 I 9DF7/ [Leave blank unless APCD has already assigned a permit/I and AIRS ID] Section 4 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,321.80 m E/4,457,337.72 m N Discharge Height Temp - : Flow Rate Ve6ocity Above Ground Level Stack ID No._ `- ' ('F) (ACFM) (ftfsec) . H-310 15.9 756 25.0 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑Downward O Upward with obstructing raincap ❑ Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 30 ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): o Other(describe): Section 5 - Fuel Consumption Information Requested Annual Permit Design Input Rate Actual Annual Fuel Uses (MMBTU/hr) (Specify Units) Limit6 (Specify Units) 10.4 92.9 MMscf/yr 92.9 MMscf/yr From what year is the actual annual fuel use data? Fuel consumption values entered above are for: 0 Each Boiler O All Boilers O N/A Indicate the type(s)of fuel used: o Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) 0 Field Natural Gas Heating value: 981 BTU/SCF ❑Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) o Coal Heating value: BTU/Lb Ash content: Sulfur Content: ❑Other(describe): Heating value (give units): 5 If you are reporting multiple identical boilers on one APEN,be sure to clarify if the values in this section are on an individual boiler basis,or if the values represent total fuel usage for multiple boilers. 6 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 7 If fuel heating value is different than the listed assumed value,please provide this information in the"Other"field. COLORADO Form APCD-220- Boiler APEN - Revision 7/2018 3 I AV Permit Number: AIRS ID Number: 123 /9DF7 I [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Q✓ Yes O No If yes, please describe the control equipment AND state the overall control efficiency(%reduction): Overall Control Pollutant Control Equipment Description Efficiency (%reduction in emissions) TSP(PM) PMio PM2.5 - SOx " NOx low NOx burners n/a CO VOC I From what year is the following reported actual annual emissions data? 2020 Use the following tables to report the criteria pollutant emissions from source: (Use the data reported in Section 5 to calculate these emissions.) . Primary Fuel Uncontrolled Emission Requested Annual Permit Factor Actual Annual Emissions Emission Limit(s)6 Type Pollutant Emission Source (natural gas,#Z Factor (AP-42, Uncontrolled Controlled° Uncontrolled Controlled diesel,etc.) (Specify Units) Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 7.6Ib/MMscf AP42 0.2 0.2 0.4 0.4 ' field gas PMio 7.6 Ib/MMscf AP42 0.2 0.2 0.4 0.4 PM2.5 7.6Ib/MMscf AP42 0.2 0.2 0.4 D.4 SOx 0.6Ib/MMscf AP42 0.01 0.01 0.03 0.03 NOx 0.025 Ib/MMBtu manufacturer 0.6 0 6 1.1 1.1 CO 0.041 Ib/MMBtu manufacturer 0.9 0.9 1.9 1.9 VOC 5.5Ib/MMscf AP42 01 0.1 0.3 0-3 p✓ Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 7. if multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the total criteria pollutant emissions table below: Uncontrolled Emission Requested Annual Permit, Secondary Factor • Actual Annual Emissions6 Fuel Type Emission _ Emission Limit(s) (#2 diesel, Pollutant Factor Source (AP-42, Uncontrolled Controlled8 Uncontrolled Controlled waste oil,etc.) (specify Units) Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) J TSP(PM) ,. PMio PMz.s SOx NOx CO , VOC 6 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APCD-22.0- Boiler APEN - Revision 7/2018 4 I �® sa;;.:':;....,�:,;' Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] if multiple fuels were fired during this reporting period,use the following table to report the TOTAL criteria pollutant emissions from the source. Values listed below should be the sum of the reported emissions from the primary and secondary fuels'emissions tables in this Section 6: Requested Annual Permit Actual Annual Emissions Emission Lim_it(s)6 Pollutant �_� . ,_ Uncontrolled e Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) TSP (PM) PM1D PM2.5 SOX NO. CO VOC 6 Requested values will become permit limitations.Requested limit(s)should consider future process growth. a Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. Section 7- Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria 0 Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Primary Fuel Type(natural gas,#2 diesel,etc.) Uncontrolled Uncontrolled Controlled Overall Emission Factor kmission Actual Actual CAS Number Chemical Name Control Factor Source Emissions Emissionse Efficiency s eci units) (AP-42,Mfg.,etc.) (lbs/ eor) ibs/ ear (specify y { y ) 540-84-1 224-trimethylpentane 2.84E-03Ib/MMBtu GRI-HAPCAIc 259 259 El Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 8. if multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the total non-criteria pollutant(HAP)emissions table below: Secondary Fuel Type(#2 diesel,waste oil,etc.) Uncontrolled Uncontrolled Controlled Overall Emission Emission Factor Actual Actual CAS Number Chemical Name Control Source 8 Factor Emissions Emissions Efficiency (specify units) CAP 42,Mfg.,etc.) (lbs/year) (lbs/year) 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APCD-22O- Boiler APEN - Revision 7/2018 5 I ® ••• Permit Number: AIRS ID Number: 123 I 9DF7/ [Leave blank unless APCD has already assigned a permit/I and AIRS ID] If multiple fuels were fired during this reporting period, use the following table to report the TOTAL non-criteria pollutant(HAP)emissions from the source. Values listed below should be the sum of the reported emissions from the primary and secondary fuels'emissions tables in this Section 7: Actual Annual Emissions CAS Number Chemical Name Uncontrolled Controlled$ (tons/year) _ (tons/year) 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. �,f L 7:4- H • 2/l tlf Ci Signature of Legally Authorized P (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box if you want: ❑✓ Draft permit prior to public notice ❑r Draft of the permit prior to issuance (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase,increase production, new equipment, change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.sov/cdphe/aped COLORA00 Form APCD-220 - Boiler APEN - Revision 7/2018 6 I `d • Fop E \ \ Boiler APEN - Form APCD-220 \->15° -> Air Pollutant Emission Notice (APEN) and Sarin -- 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 boilers, hot oil heaters, process heaters, and similar equipment. If your emission unit does not fall into one of these categories, there may be a more specific APEN for your source(e.g. print shop, mining operations, engines, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at: www.colorado.eov/cdphe/apcd. Do not complete this form for the following source categories: - Heaters or boilers with a design capacity less than or equal to 5 MMBtu/hour that are fueled solely by natural gas or liquid petroleum gas(LPG). - Heaters or boilers with a design capacity less than or equal to 10 MMBtu/hour used solely for heating buildings for personal comfort that are fueled solely by natural gas or liquid petroleum gas (LPG). More information can be found in the APEN exempt/permit exempt checklist: https://www.colorado.eov/pacific/cdphe/apen-or-air-permit-exemptions. 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: r t OHOI AIRS ID 123 /9DF7 / 8 Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W county: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 813+01 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 E-Mail Address2: ehinkley@redcedargathering.com I 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 the APCD via e-mail to the address provided. 393283 COLORADO Form APCD-22O - Boiler APEN - Revision 7/2018 1 I IAD W Permit Number: AIRS ID Number: 123 /9DF7 [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2 - Requested Action NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership4 O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: low-NOx burners 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: hot oil heater (amine unit) Manufacturer: TBD Model No.: TBD Serial No.: TBD Company equipment Identification No. 1-1-290 (optional): For existing sources,operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 1/1/2020 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Seasonal use Dec- Mar- June- Sept- percentage: Feb: May: Aug: Nov: Are you reporting multiple identical boilers on this APEN? ❑Yes ❑✓ No If yes, please describe how the fuel usage will be measured for each boiler(i.e., one meter for all boilers or separate meters for each unit): COLORADO Form APCD-220- Boiler APEN -Revision 7/2018 2 I �� w8'F= Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit p and AIRS ID] Section 4 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,314,66 m E/4,457,340.25 m N Discharge Height Operator = Temp Flow Rata Velocity _' Above Ground Level Stack ID,No H-290 23 764 29.0 Indicate the direction of the stack outlet: (check one) ❑� Upward ❑Downward ❑Upward with obstructing raincap ❑ Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ✓❑Circular Interior stack diameter(inches): 30 ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑Other(describe): Section 5 - Fuel Consumption Information Requested Design Input Rate Actual Annual Fuel Uses Annual Permit (MMBTU/hr) (Specify Units) L1mit (Specify Units) 19.33 172.6 MMscf/yr 172.6 MMscf/yr From what year is the actual annual fuel use data? Fuel consumption values entered above are for: ✓❑Each Boiler ❑All Boilers ❑N/A Indicate the type(s)of fuel used: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑✓ Field Natural Gas Heating value: 981 BTU/SCF ❑Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑Coal Heating value: BTU/lb Ash content: Sulfur Content: ❑ Other(describe): Heating value (give units): 5 If you are reporting multiple identical boilers on one APEN,be sure to clarify if the values in this section are on an individual boiler basis,or if the values represent total fuel usage for multiple boilers. 6 Requested values will become permit limitations. Requested iimit(s)should consider future process growth. 7 If fuel heating value is different than the listed assumed value,please provide this information in the"Other"field. [��r COLORADO Form APCD-220 - Boiler APEN - Revision 7/2018 3 m`G `:'c; Permit Number: AIRS ID Number: 1 23 /9DF7 / [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 6 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes 0 No If yes, please describe the control equipment AND state the overall control efficiency(%reduction): Overall Control Pollutant Control Equipment Description Efficiency (%reduction in emissions) TSP (PM) PM1a PMzs SOx NOx low NOx burners n/a CO VOC From what year is the following reported actual annual emissions data? 2020 Use the following tables to report the criteria pollutant emissions from source: (Use the data reported in Section 5 to calculate these emissions.) Emission Requested Annual Permit Primary Fuel Uncontrolled Actual Annual Emissions q 6 Emission Factor Emission Limits) Type Pollutant Source - _ ` - (natural gas,#2 Factor (AP-42' Uncontrolled Controlled° Uncontrolled Controlled diesel,etc.) (Specify Units) Mfg etc.) (tons/year) (tons/year) (tons/year) •(tons/year) TSP(PM) 7.6 lb/MMscf AP42 0.7 03 0.7 D.7 field gas PMto 7.6Ib/MMscf AP42 0.7 0.7 0-7 0.7 PM2.s 7.6 Ib/MMscr AP42 0.7 0.7 0.7 0 7 SOx 0.6Ib/MMscf AP42 0.05 0.05 0.05 0.05 NOx 0.025Ib/MM6tu manufacturer 2.1 2.1 2.1 2.1 CO 0.041 Ib/MMBtu manufacturer 3.5 3.5 3 5 3.5 VOC 5.5Ib/MMscf AP42 0.5 D5 0.5 0.5 • 0 Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 7. if multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the total criteria pollutant emissions table below: Uncontrolled Emission Requested Annual Permit Secondary Factor Actual Annual Emissions a e Fuel Type Emission Emission Limit(s) Pollutant Source (#2 diesel, Factor (AP-42 Uncontrolled Controlled° Uncontrolled Controlled waste oil,etc.) (Specify Units) Mfa.,etc.) (tons/year) (tons!year) (tons/year) (tons/year) TSP(PM) PM10 PM2.5 SOx NOS CO VOC 6 Requested values will become permit limitations.Requested limits)should consider future process growth. °Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. COLORADO Form APCD-220 - Boiler APEN - Revision 7/2018 4 I WV 1.",t''F;;:`,.,Y,R`.°I° Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] if multiple fuels were fired during this reporting period,use the following table to report the TOTAL criteria pollutant emissions from the source. Values listed below should be the sum of the reported emissions from the primary and secondary fuels'emissions tables in this Section 6: Requeited Annual Permit Actual Annual Emissions Emission ft-0),---a4;11 Pollutant Uncontrolled Controlled$ Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) PMio PM2s SOX NOx CO VOC 6 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. Section 7- Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria ❑✓ Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Primary Fuel Type(natural gas,#2 diesel,etc.) Uncontrolled Uncontrolled ` Controlled Overall Emission Emission Factor Actual Actual CAS Number Chemical Name Control Source Emissions Emissions6 Factor Efficiency (specify units) (AP 42,Mfg.,etc.) (lbs/year) (lbs/year) 540-84-1 2,2,4-trimethylpentane 0% 2.84E-03Ib/MMBtu GRI-HAPCalc 481 481 100-41-4 ethylbenzene 0% 2.11E-03Ib/MMBtu GRI-HAPCalc 358 358 110.54.3 n-hexane 0% 1,76E-03 Ib/MMBtu AP42 299 299 100-42-5 styrene 0% 2,08E-031b/MMBtu GRI-HAPCaIc 352 352 0✓ Check this box if multiple fuels were NOT firedduring this reporting period and skip to Section 8. If multiple fuels were fired during this reporting period,complete this secondary fuel emissions table and the total non-criteria pollutant(HAP) emissions table below: Secondary Fuel Type(#2 diesel,waste oil,etc.) Uncontrolled Uncontrolled Controlled Overall Emission Emission Factor Actual Actual CAS Number Chemical Name - Control Source Factor Emissions Emissions8 Efficiency (AP-42,Mfg.,etc.) (specify units) (lbs/year) (lbs/year) a Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. COLORADO Form APCD-22O- Boiler APEN - Revision 7/2018 5 J �]� :........ ......, Permit Number: AIRS ID Number: 1 23 I 9DF7 / [Leave blank unless APCD has already assigned a permit If and AIRS ID] If multiple fuels were fired during this reporting period, use the following table to report the TOTAL non-criteria pollutant(HAP) emissions from the source. Values listed below should be the sum of the reported emissions from the primary and secondary fuels'emissions tables in this Section 7: Actual'Annual Emissions _ CAS Number Chemical Name Uncontrolled Controlled' (tons/year) (tons/year) s Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 2)1liR Signature of Legally Authorized on (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box if you want: ID Draft permit prior to public notice Draft of the permit prior to issuance (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements: Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303) 692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aped COLORADO Form APCD-220 - Boiler APEN Revision 7/2018 6 I laig f:,"° • A CDPHE Boiler APEN - Form APCD-220 'T` 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 boilers, hot oil heaters, process heaters, and similar equipment. If your emission unit does not fall into one of these categories, there may be a more specific APEN for your source (e.g. print shop, mining operations, engines, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options wilt 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.Qov/cdphe/apcd. Do not complete this form for the following source categories: - Heaters or boilers with a design capacity less than or equal to 5 MMBtu/hour that are fueled solely by natural gas or liquid petroleum gas(LPG). - Heaters or boilers with a design capacity less than or equal to 10 MMBtu/hour used solely for heating buildings for personal comfort that are fueled solely by natural gas or liquid petroleum gas(LPG). More information can be found in the APEN exempt/permit exempt checklist: https://www.colorado.Qov/pacific/cdphe/aoen-or-air-permit-exemptions. 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: AIRS ID 123 /9DF7/ O( I to eot tool, Number: [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 1 - Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 E-Mail Address2: ehinkley@redcedargathering.com I 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 the APCD via e-mail to the address provided. 393284 A� COlON4D0 Form APCD-220- Boiler APEN - Revision 7/2018 1 � ,T,,..,,,,.`"":: Permit Number: AIRS ID Number: 1 23 /9DF7 / [Leave blank unless APCD has already assigned a permit it and AIRS ID) Section 2 - Requested Action El NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) O Change fuel or equipment O Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: low-NOx burners 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: hot oil heater (cryo unit) Manufacturer: TBD Model No.: TBD Serial No.: TBD Company equipment Identification No. H-570 (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 1/1/2020 ❑Check this box if operating hours are 8,760 hours per year;if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Seasonal use Dec- Mar- June- Sept- percentage: Feb: May: Aug: Nov: Are you reporting multiple identical boilers on this APEN? O Yes El No If yes,please describe how the fuel usage will be measured for each boiler(i.e., one meter for all boilers or separate meters for each unit): Form APCD-22O- Boiler APEN - Revision 7/2018 2 I A® COLORADO,°;" Permit Number: AIRS ID Number: 123 /9DF7/ (Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,305.08 m E/4,457,341.89 m N " ' Discharge,: Height OperatorTemp Flow Bate Velocity Above Ground Level . . . `.-Staekl�No: _ {'F) (AtFiNj.. "(ftisec)- (Feet) H-570 18.1 665 23.0 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑Downward O Upward with obstructing raincap o Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 30 ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑Other(describe): Section 5 - Fuel Consumption Information Requested Annual Design Input Rate Actual Annual Fuel Use Permit (MMBTU/hr) (Specify Units) Limit 6 (Specify Units) 24.3 217.0 MMscf/yr 217.0 MMscf/yr From what year is the actual annual fuel use data? Fuel consumption values entered above are for: 0 Each Boiler O All Boilers ❑N/A Indicate the type(s) of fuel used: ❑Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) 0 Field Natural Gas Heating value: 981 BTU/SCF ❑Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑Coal Heating value: BTU/lb Ash content: Sulfur Content: ❑ Other(describe): Heating value(give units): 5 If you are reporting multiple identical boilers on one APEN,be sure to clarify if the values in this section are on an individual boiler basis,or if the values represent total fuel usage for multiple boilers. 6 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 7 If fuel heating value is different than the listed assumed value,please provide this information in the"Other"field. COLORADO Form APCD-22O- Boiler APEN - Revision 7/2018 3 I AY .. • •••• Permit Number: AIRS ID Number: 1 23 I 9DF7 I [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 6 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes O No If yes, please describe the control equipment AND state the overall control efficiency(%reduction): Overall Control Pollutant Control Equipment Description Efficiency 1%reduction in emissions) TSP (PM) PM10 PM2.5 - SOx NOS low NOx burners n/a CO VOC From what year is the following reported actual annual emissions data? 2020 Use the following tables to report the criteria pollutant emissions from source: (Use the data reported in Section 5 to calculate these emissions.) Emission Requested Annual Permit Primary Fuel Uncontrolled Actual Annual Emissions - q 6 Factor Emission Limit Limit(s) Type Pollutant Emission Source (natural gas,#2 Factor (AP-42, Uncontrolled Controlled8 Uncontrolled Controlled diesel,etc.) (Specify Units) Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) TSP (PM) 7.6 Ib/MMscf AP42 0.8 0.8 0 8 0.8 field gas PMio 7.6 lb/MMscf AP42 0.8 0.8 08 0.8 PM2.5 7.5Ib/MMscf AP42 0.8 0.8 0.8 0.8 SOx 0.6Ib/MMscf AP42 0.07 0.07 0.07 0.07 NOx 0.025Ib/MMBtu manufacturer 2.7 2.7 2.7 2.7 CO 0.041Ib/MMBIu manufacturer 4.4 4.4 4.4 4.4 VOC 5.51blMMscf AP42 0.6 0.6 0.6 0.6 0 Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 7. If multiple fuels were fired during this reporting period, complete this secondary fuel emissions table and the total criteria pollutant emissions table below: Seconda Uncontrolled Emission Requested Annual Permit ry Emission Factor Act•ual Annual Emissions Emission Limit(s)6 Fuel Type Pollutant Source - (#2 diesel, Factor (AP-42, Uncontrolled Controlled8 Uncontrolled Controlled waste oil,etc.) (Specify Units) Mfs.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) TSP (PM) PMio _ PM2.5 SOS NOx CO VOC 6 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APCD-220 - Boiler APEN - Revision 7/2O18 4 I A® =',:!:;v::;,':.;:"..-r;, Permit Number: AIRS ID Number: 1 23 I 9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID) if multiple fuels were fired during this reporting period, use the following table to report the TOTAL criteria pollutant emissions from the source. Values listed below should be the sum of the reported emissions from the primary and secondary fuels'emissions tables in this Section 6: Requested Annual Rermlt Actual Annual Emissions Emi;sion Limit(s)6 Pollutant = . Uncontrolled Controllede Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) PMto PM2.s SOx NOx CO VOC 6 Requested values will become permit limitations.Requested limit(s)should consider future process growth. s Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating, leave blank. Section 7- Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria ✓❑Yes ❑No pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes,.use the following table to report the non-criteria pollutant(HAP)emissions from source: Primary Fuel Type(natural gas,#2 diesel,etc.) Uncontrolled Uncontrolled Controlled Overall Emission Factor Emission Actual Actual CAS Number Chemical Name Control Source Emissions Emissionsa Factor Efficiency (specify units) ('P"42,Mfg.,etc.) (!bs/)tear) (Ibs/year) 540-84-1 2,2,4-trimethylpentane 0% 2.84E-03 Ib/MMBtu GRI-HAPCalc 605 605 100-41-4 ethylbenzene 0% 2.11E-03 lb/MMBtu GRI-HAPCaIc 450 450 110-54-3 n-hexane 0% 1.76E-03 lb/MMBtu AP42 376 376 100-42-5 styrene 0% 2.08E-03 lb/MMBtu GRI-HAPCalc 443 443 1330.20-7 xylenes 0% 1.32E-03 lb/MMBtu GRI-HAPCalc 281 281 El Check this box if multiple fuels were NOT fired during this reporting period and skip to Section 8. If multiple fuels were fired during this reporting period,complete this secondary fuel emissions table and the total non-criteria pollutant(HAP)emissions table below: Secondary Fuel Type(#2 diesel,waste oil,etc.) Uncontrolled Uncontrolled Controlled Overall Emission Emission Factor Actual Actual CAS Number Chemical Name Control Factor Source Emissions Emissions' Efficiency (AP-42,Mfg.,etc) (specify units) (lbs/year) (lbs/year) Annual emissions fees wilt be based on actual controlled emissions reported.If source has not yet started operating, leave blank. COLORADO Form APCD-220 - Boiler APEN - Revision 7/1018 5 I �� Permit Number: AIRS ID Number: 123 I 9DF7/ [Leave blank unless APCD has already assigned a permit ti and AIRS ID] If multiple fuels were fired during this reporting period,use the following table to report the TOTAL non-criteria pollutant(HAP)emissions from the source. Values listed below should be the sum of the reported emissions from the primary and secondary fuels'emissions tables in this Section 7: Actual-Annual Emissions CAS Number Chemical Name - - Uncontrolled Controlled$ (tons/year) (torts/year) 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating, leave blank. Section 8 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 2111/7 Signature of Legally AuthoriaePerson (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box if you want: El Draft permit prior to public notice El Draft of the permit prior to issuance (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303) 692-3175 or(303)692-3148 APCD-SS-B1 43O0 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado,nov/cdphe/aped COLORADO Form APCD-220- Boiler APEN - Revision 7/2018 6 I �� °".:° CDPHE Amine Sweetening Unit - Form APCD-206 Co 01 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 amine sweetening units only. If your emission unit does not fall into this category,. there may be a more specific APEN available for your source (e.g. glycol dehydration unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN(Form APCD-200)is available if the Specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/aped. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I (4 RAJ () ' AIRS ID Number: 123 / 9DF7 / [Leave blank unless APCD has already assigned a permit is and AIRS ID] Section 1 -Administrative Information Company Name: Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 E-Mail Address2: ehinkley@redcedargathering.com I 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 the APCD via e-mail to the address provided. 333286 • COLORADO �� Form APCD-206-Amine Sweetening Unit APEN - Revision 7/2018 1 I Permit Number: AIRS ID Number: 123 /9DF7 [Leave blank unless APCD has already assigned a permit//and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 O Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- - 0 Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: amine unit emissions controlled by enclosed flare 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 -General Information General description of equipment and purpose: amine unit used to sweeten gas Company equipment Identification No. (optional): AMINE For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 • Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS 0 Yes ❑ No nonattainment area? Does this facility have a design capacity less than 2 long ❑ Yes ❑ No tons/day of H2S in the acid gas? OLORADO C Form APCD-206-Amine Sweetening Unit APEN -Revision 7/2018 2 I ® -1i17z Permit Number: AIRS ID Number: 123 /9DF7 [Leave blank unless APCD has already assigned a permit t/and AIRS ID] Section 4- Amine Unit Equipment Information Manufacturer: TBD Model No.: TBD Serial Number: TBD Absorber Column Stages: TBD stages Amine Type: ❑ MEA ❑ DEA O TEA ❑✓ MDEA ❑ DGA Pump Make and Model: TBD backup) of pumps: 2 (1 Design Capacity: 60 MMSCF/day Sour Gas Throughput: 2,-(10° 6 Requested 5: ZigpaMMSCF/year Actual MMSCF/year `{(i&Ij Sour Gas: Pressure: 973 psig Temperature: 73 'F Pressure: 968 psia Temperature: 115 °F Lean Amine Flowrate: 209 gal/min Wt. %amine: 41.3 Stream: Mole loading H2S: 0.01 maximum Mole Loading 0.01 maximum CO2: Pressure: psia Temperature: 'F NGL Input: Flowrate: Gal/min Flash Tank: Pressure: 58 psia Temperature: 1 32 °F O No Flash Tank Additional Required Information: ❑✓ Attach a'Process Flow Diagram 0 Attach the simulation model inputs ft emissions report ❑� Attach composition reports for the rich amine feed, sour gas feed, NGL feed, &outlet stream(emissions) Attach the extended gas analysis(including BTEX Et n-Hexane, H2S, CO2, temperature, and pressure) 5 Requested values will become permit limitations. Requested timit(s)should consider future process growth. Air COLORADO Form APCD-206- Amine Sweetening Unit APEN - Revision 7/2018 3 I Air ;t �:'.°;..,m:. • Permit Number: AIRS ID Number: 123 /9DF7/ (Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,373.50 m E/4,457,328.25 m N Discharge gHeight- Operator , . Temp. Flow Rate Velocity Above Ground Level F (ACFM)ID No. = ( ) ( ) (ft/sec) (feet) FL-992 40 Indicate the direction of the stack outlet: (check one) O Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 72 ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Used for control of: ❑ Size: Make/Model: VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: Used for control of: VOC/HAP/H2S Rating: 18 MMBtu/hr Type: ECD Make/Model:Zeeco EGF-6-40 40 Combustion Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: "F Waste Gas Heat Content: 209 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.08 MMBtu/hr Supplemental Fuel Flow: MMscf/year Supplemental Fuel Heat Content: 981 Btu/scf Closed Used for control of: ❑ Loop Description: System: System Downtime: Used for control of: Q Other: Description: Requested Control Efficiency: - -- per vVtNKrt tI Form APCD-206 - Amine Sweetening Unit APEN • Revision 7/2018 4 A I y`•'�',F7.7,`�U Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit H and AIRS ID] Section 7- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): • Overall Requested Pollutant Description of Control Method(s) Control Efficiency lt (%reduction in emissions) PM - SOx HZS enclosed flare 95% NO. CO _ VOC enclosed flare 95% HAPs enclosed flare 95% ----— - ----- Other: From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory • Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP-42, Emissions Emissions' Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) . PM 7.6 Ib/MMscf AP-42 0 2.8 0 2.8 SOx 1.76E-02 lb/MMBtu calculated 1,4 1.4 1.4 1.4 H75 9.34E-03 lb/MMBtu calculated 0.7 0.04 0.7 0.04 NO. 0.0641 lb/MMBtu TNRCC RG-109 0 5.0 0 5.0 CO 0.5496 Ib/MMBtu TNRCC RG-109 0 42.5 0 42.5 VOC 3.74 lb/MMBtu calculated 289.2 14.5 289.2 14.5 Non-Criteria Reportable Pollutant Emissions Inventory_ Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions' Number Basis Mfg.,etc.) (pounds/year) -(pounds/year) Benzene 71432 1.96E-01 lb/MMBtu calculated 30,362 1,518 Toluene 108883 9.34E-02 Ib/MMBtu calculated 14,458 723 Ethylbenzene 100414 9.34E-04 Ib/MMBtu calculated 145 7 Xylene 1330207 9.34E-03 lb/MMBtu calculated 1,446 72 n-Hexane 110543 1.87E-02 lb/MMBtu calculated 2,892 145 2,2,4- 540841 1.87E-06 lb/MMBtu calculated 0 0 Trimethylpentane Other: methanol 1.4 lb/MMBtu calculated 216,872 10,844 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. AT COLORADO Form APCD-206- Amine Sweetening Unit APEN - Revision 7/2018 5 1 L33T te:w':�:,.�,,,,,�n„ Permit Number: AIRS ID Number: 1 23 /9DF7 [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. X11 Signature of Legally Authorized Perot a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(print) Title • Check the appropriate box to request a copy of the: El Draft permit prior to issuance ❑� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.4ov/cdphe/apcd COLORADO Form APCD-206 -Amine Sweetening Unit APEN - Revision 7/2018 6 I 10 \ Y Gas Venting APEN - Form APCD-211 • Air Pollutant Emission Notice (APEN)and CO • 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 gas venting only. Gas venting includes emissions from gas/liquid separators,well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: )ctwt.oRD AIRS ID Number: 123 /9DF7 / 6 [Leave blank unless A CD has already assigned a permit Ji and AIRS ID] Section 1 - Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W Weld County: NAICS or SIC Code: 1321 Mailing Address: 125 Mercado Street, Suite 201 (Include Zip Code) Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 E-Mail Address: Ehinkley@redcedargathering.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393287 �® COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action O NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 O Add point to existing permit ❑ Change permit limit O Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- Q Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: plant flare Company equipment Identification No. (optional): FL-991 For existing sources, operation began on: For new, modified,or reconstructed sources, the projected start-up date is: 1/1/2020 Cheek this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS ❑ Yes © No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes 0 No considered a Major Source of(HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, ❑ Yes / No Section XVII.G? COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I AMOY .;'3=7,.",,"'„`. Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4- Process Equipment Information ❑ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: It of Pistons: Leak Rate: Scf/hr/pist Blowdown Events It of Events/year: Varies Volume per event: Varies MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator,you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes ❑ No Vent Gas ,�220 gTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: 42,1 MMSCF/year Actual: 42,1 MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5: • Molecular Weight: 19.5 VOC (Weight%) 30.0 Benzene(Weight%) 0,1 Vented Gas Toluene(Weight%) 0,1 Properties: Ethylbenzene(Weight%) 0.001 Xylene(Weight%) 0,02 n-Hexane (Weight%) 0.5 2,2,4-Trimethylpentane (Weight%) 0.001 Additional Required Information: ▪ Attach a representative gas analysis(including BTEX B n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX a n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I �� Permit Number: AIRS ID Number: 123 I 9DF7 I [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524,411.65 m El 4,457,332.36 m N Discharge Neighs Operator Temp. Flow Rate Velocity Above Ground Level F (ACFM) {ftlsec) (Feet) Stack ID No. CF) FL-991 125 1832 65.6 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑Downward ❑Upward with obstructing raincap O Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ✓❑Circular Interior stack diameter(inches): ❑Other(describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC/HAP/H2S Rating: 5,9 MMBtu/hr Type: open flare Make/Model: TBD ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 1 220 Btu/scf Constant Pilot Light: Q Yes O No Pilot burner Rating: 0.08 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: c OIORADD Form APCD-211 Gas Venting APEN - Revision 7/2018 4 1 Ea ``= Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit 1/and AIRS ID] Section 7- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): _ Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SO. NO. CO VOC plant flare 95% HAPs plant flare 95% Other: • H2S-plant flare 95% From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Units (AP-42, Emissions Emissions& Emissions Emissions Basis Mfg.,etc.) (tons/year) (tonsly_ear) (torts/year) (tortstyear) PM 7.6 lb/MMscf AP-42 0 0.2 0 0.2 SOx 1,35E-04 lb/MMBtu calculated 0 0.004 0 0.004 NO. 0.138 lb/MMBtu TNRCC RG-109 0 3.5 0 3.5 CO 0.2755 lb/MMBtu TNRCC RG-109 0 7.1 0 7.1 VOC 12.63 Ib/MMBtu calculated 324,2 16.2 324.2 16.2 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissfons Emissions& Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 4.21E-02 lb/MMBtu calculated 2,161 108 Toluene 108883 4.21E-02 lb/MMBtu calculated 2,161 108 Ethylbenzene 100414 4.21E-04 lb/MMBtu calculated 22 1 Xylene 1330207 8.42E-03 lb/MMBtu calculated 432 22 n-Hexane 110543 2.11E-01 Ib/MMBtu calculated 10,806 540 2,2,4- Trimethylpentane 540841 4.21E-04 lb/MMBtu calculated 22 1 Other:methanol 67561 1.26E-02 lb/MMBtu calculated - 648 32 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. COLORADO Form APCD-211 Gas Venting APEN - Revision 7/2018 5 I A� zxr,f n"a�.. Permit Number: AIRS ID Number: 123 I 9DF7/ [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. 4,J . 2,1-/11 Signature of Legally Authorized Per rt.( ot a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(please print) Title Check the appropriate box to request a copy of the: ®Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase,increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/apcd VIV COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I Av., t°aF?:,.,: ^^." RECEIVED FEB 1 1 201g' APCD ta;.;ofary c:,,t ces DPHE Hydrocarbon Liquid Loading APEN Form APCD-208 CO Ize 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 (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at:www.colorado.eov/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: 19 a t AIRS ID Number: 123 / 9DF7/ 001 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Aka Energy Group, LLC Site Name: Speer Gas Plant Site Location Site Location: SW/4 Section 31, T4N, R65W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 E-Mail Address2: Ehinkley@redcedargathering.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on ail documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393288 ��yy COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 i mV tw"'hF °:wt', Permit Number: MRS ID Number: 123 /9DF7/001 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action O NEW permit OR newly-reported emission source ❑r Request coverage under constnxtion permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 O Change permit limit ❑ Transfer of ownership's 0 Other(describe below) -OR- - ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑✓ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: increase throughput,request coverage under construction permit,and cancel GP07 upon issuance 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: truck load out of condensate Company equipment Identification No. (optional): SP300-10 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 (modification start up) Will this equipment be operated in any NAAQS nonattainment area? p Yes O No Is this equipment located at a stationary source that\is considered a Major Source of(HAP) ❑ Yes ❑✓ No emissions? Does this source load gasoline into transport vehicles? O Yes Q No Is this source located at an oil and gas exploration and production site? ❑ Yes El No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes ❑ No average? Does this source splash fill less than 6750 bbl of condensate per year? O Yes O No Does this source submerge fill less than 16308 bbl of condensate per year? ❑ Yes O No -- - COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN -Revision 7/2018 2 I A� F='F;;;;. t•, Permit Number: AIRS ID Number: 123 /9DF7/001 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 75 000 bbl/year Actual Volume Loaded: 75 000 bbl/year r � This product is loaded from tanks at this facility into: tank trucks (e.g. "rail tank cars"or"tank trucks") — If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of F bulk liquid loading: True Vapor Pressure: Psia @ 60 "F Molecular weight of lb/lb-mot displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft'/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit Limitations. Requested limit(s)should consider future process growth. • • COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I '`d' =7:.;;;,t, Permit Number: AIRS ID Number: 123 /9DF7/001 [Leave blank unless APCD has already assigned a permit/I and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 524216.00 m El 4457286.00 m N Discharge Height Above pperator Temp Flow Rate Velocity Stack ID No, b, Ground Lerel, en _ -plum) ` (ft/sec) (feed SP300-10 Indicate the direction of the stack outlet: (check one) ❑Upward ❑ Downward O Upward with obstructing raincap ❑ Horizontal p Other(describe): vapor balance return line to load out tank Indicate the stack opening and size: (check one) ❑Circular Interior stack diameter(inches): ❑Other(describe): Section 6 - Control Device Information eck this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. C . iNfo )Loading occurs using a vapor balance system: Requested Control Efficiency: 88 very i Used for control of: - Rating: MMBtu/hr Ai Type: Make/Model:tvo Combustion ❑ Device: Requested Control Efficiency: % 1(15V' Manufacturer Guaranteed Control Efficiency: % Minimum Temperature: °F Waste Gas Heat Content: Btu/scf ja Constant Pilot Light: El Yes El No Pilot Burner Rating: MMBtu/hr a k3c1 Pollutants Controlled: VIA ,l El Other: Description: Requested Control Efficiency: COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I �ff :4'1'C^:.�: D.°:, Permit Number: AIRS ID Number: 123 /9DF7/001 [Leave blank unless APCD has already assigned a permit lt and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SOX NOx CO / f VOC v balance /8B% HAPs vappytegice p< O Other: AC6 I-1251A E✓ Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ID Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL aIEL Ickt ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2020 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s) Pollutant • 5 Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NOx CO �. VOC 0.236 lb/bbl PS Memo 14-02 8.9 a ,� 8.9- - �1• , Non-Criteria Reportable Pollutant Emissions Inventory Chemical _ Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Basis Mfg.,etc.) (pounds/year) (pounds/year) .. Benzene 71432 4.16E-04 lb/bbl PS Memo 14-02 31 ,? Toluene 108883 Ethylbenzene 100414 Xylene- 1330207 n-Hexane 110543 3,61E-03 lb/bbl PS Memo 14-02 271 2s74 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. • 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. OLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN- Revision 7/2018 5 I ;C...,,..=.. Permit Number: AIRS ID Number: 123 /9DF7/001 [Leave blank unless APCD has already assigned a permit ft 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 General Permit GP07. mow. e4. 2/1/jef Signature of Legally Authoriz P son(not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name(print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) • This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692.3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530, Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aped g COLORADO Form APCD-208—Hydrocarbon Liquid Loading APEN- Revision 7/2018 6 I A! • STATE OF Gruel -CDPHE,Andrew<andrew.gruel@state.co.us> COLORADO Jy7e` Aka Energy -- Speer Gas Plant -- Loadout control request Joe Miller<jmiller@mtn-air.com> Mon, Jul 22, 2019 at 1:51 PM To:Andy Gruel-CDPHE<andrew.gruel@state.co.us> Andy- Please proceed with redlining the loadout APEN to remove the requested control credit and set the requested permit limit to 8.9 tpy VOC. Please let me know if you have any questions or need anything else. Thanks! Joe Joe Miller Principal Air Quality Specialist Mountain Air Consulting,LLC 730 17th Street, Suite 315 Denver, CO 80202 (303)-524-9686 phone From:Andy Gruel -CDPHE [mailto:andrew.gruel@state.co.us] Sent: Friday,April 26, 2019 4:22 PM To:Joe Miller<jmiller@mtn-air.com> Subject:Aka Energy--Speer Gas Plant-- Loadout control request Hi Joe, As we discussed on the phone, I cannot grant control credit at the truck loadout point at Aka Energy's proposed Speer Gas Plant (19WE0165, 123/9DF7/001). Please respond to this email with approval to redline the APEN to remove the requested control credit, and to set the requested permit limit to 8.9 tpy VOC. Thank You, Andy Gruel, P.E. Oil and Gas.Permit Engineer Stationary Sources Program RECEivED FEB 1 1 2019 APCD Stagunary c ��aE Fugitive Component Leak Emissions APEN suura�` Form APCD-203 CO _ "* 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 fugitive component leak emissions only. If your emission source does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid loading,condensate storage tanks,etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of alt available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: Ict1JjOJ(Q AIRSiDNumber: 123 /9DF7/ 02( [Leave blank unless APCD has already assigned a permit/1 and AIRS ID] Section 1 - Administrative Information Company Name': Aka Energy Group, LLC. Site Name: Speer Gas Plant SW/4 Section 31, T4N, R65W Site Location Weld Site Location: County: NAICS or SIC Code: 1321 Mailing Address: 125 Mercado Street, Suite 201 (Include Zip Code) Durango, CO 81301 Contact Person: Ethan Hinkley Phone Number: (970) 764-6495 E-Mail Address2: Ehinkley@redcedargarhering.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 393289 COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN- Revision 7/2018 1 I �� ,=';,FF =4,:., Permit Number: AIRS ID Number: 1 23 I 9DF7/ [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source(check one below) -OR- ❑ MODIFICATION to existing permit(check each box below that applies) O Change process or equipment ❑ Change company name3 O Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 O 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&Notes: fugitive VOC emissions from equipment leaks(OOOOa);stream constituents in Section 5 apply to first equipment count provided in Section 8; 1O0%VOC and 0%HAP apply to second equipment count provided in Section 8 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information Company equipment Identification No. (optional): LEAKS For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 1/1/2020 p Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Facility Type: ❑Well Production Facilitys ❑Natural Gas Compressor Stations ❑✓ Natural Gas Processing Plants ❑Other(describe): 5 When selecting the facility type,refer to definitions in Colorado Regulation No.7,Section XVII. Form APCD-2O3 - Fugitive Component Leak Emissions APEN -Revision 7/2018 2 I AV COLOR ADO� ,Permit Number: AIRS ID Number: 123 /9DF7/ [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? pending (after 9/18/2015) Will this equipment be operated in any NAAQS nonattainment area? Yes O No Will this equipment be located at a stationary source that is considered a ❑Yes /No Major Source of Hazardous Air Pollutant(HAP)emissions? Are there wet seal centrifugal compressors or reciprocating compressors Q Yes ❑No located at this facility?Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑Yes No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? ❑Yes El No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? El Yes O No Is this equipment subject to 40 CFR Part 63, Subpart HH? O Yes 0 No Is this equipment subject to Colorado Regulation No.7, Section XII.G? 0 Yes O No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? O Yes Q No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? O Yes ❑✓ No Section 5 - Stream Constituents ✓❑The required representative gas and liquid extended analysis(including BTEX)to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight%content of each applicable stream. VOC Benzene Toluene Ethylbenzene Xylene n-Hexane 2,2,4 Stream (wt%) (wt%) (wt%) (wt%) (wt%) (wt%) Trimethyfpentane (wt%) Gas 30% 0.1% 0.1% 0.001% 0.02% 0.5% 0.001% Heavy Oil(or Heavy Liquid) 100% 1.0% 1.1% 0.03% 0.3% 23.0% 0.01% Light Oil (or Light Liquid) 100% 1 .0% 1.1% 0.03% 0.3% 23.0% 0.01% Water/Oil Section 6- Geographical Information Geographical Coordinates (LatitudelLongitude or MA) 524280.98 m E/ 4457274.01 m N Attach a topographic site map showing location COLORADO Form APCD-2O3 - Fugitive Component Leak Emissions APEN - Revision 7/2018 3 I A Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank uriess APCD has already assigned a permit ft and AIRS ID] Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: O LDAR per 40 CFR Part 60, Subpart KKK O Monthly Monitoring-Control: 88%gas valve, 76%light liquid valve,68%tight liquid pump ❑Quarterly Monitoring- Control: 70%gas valve, 61%light liquid valve, 45%light liquid pump ❑✓ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa 0 Monthly Monitoring-Control: 96%gas valve, 95%light liquid valve,88%light liquid pump, 81% connectors ❑LDAR per Colorado Regulation No,7, Section XVILF ❑Other6: ❑No LDAR Program 6 Attach other supplemental plan to APEN form if needed. COLOADO Form APCD-203- Fugitive Component Leak Emissions APEN - Revision 7/2018 4 I MI c: '' R:'a Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ✓❑Table 2-4 was used to estimate emissions7. ❑Table 2-8 (‹ 10,000ppmv)was used to estimate emissions7. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑� Estimated Component Count ❑Actual Component Count conducted on the following date: Equipment Type Service Open-Ended y Connectors Flanges Lines Pump Seals Valves Other Gas Count8 8,300+ 1,413 0 + 84 33 + 0 0 + 4 4,346 + 448 112 +0 Emission Factor Units Heavy Oil(or Heavy Liquid) Counts 1,518 + 32 0 +0 0 +0 0 + 0 594 + 16 20 +0 Emission Factor Units Light Oil(or Light Liquid) Count8 20+ 56 0 +0 0+ 0 24 + 20 130 + 98 4 + 4 Emission Factor Units n 6 Water/Oil • 3/Z 7-1 Cy counts !25 432 53 4Ib Emission Factor Units ket 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates(Document EPA-4531R- 95.017). R The count shall be the actual or estimated number of components in each type of service that is used to calculate the"Actual Calendar Year Emissions"below. 9 The"Other"equipment type should be applied for any equipment other than connectors,flanges,open-ended lines,pump seals,or valves. C�OLORAOO Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 7/2018 5 I ANF .,• mv.•- � Permit Number: AIRS ID Number: 1 23 I 90F7 I [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 9 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? 2020 Use the following table to report the criteria pollutant emissions and non-criteria pollutant(HAP)emissions from source: (Use the data reported in Section 8 to calculate these emissions.) Requested Annual Permit Emission Actual Annual Emissions CAS Limit(s) tt Chemical Name Number Uncontrolled Controlled10 Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) vOC 99.2 9.8 99.2 9.8 Does the emissions source have any actual emissions of non-criteria pollutants 0✓ Yes ❑No (e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Actual Annual Emissions Requested Annual Permit Emission CAS Limit(s)11 Chemical Name Number Uncontrolled Controlled7° Uncontrolled Controlled (lbs/year) _ (lbs/year) (lbs/year) (lbs/year) Benzene 71432 567 65 567 65 Toluene 108883 580 67 580 67 Ethylbenzene 100414 8 1 8 1 Xylene 1330207 127 15 127 15 n-Hexane 110543 5,292 743 5,292 743 2,2,4 540841 6 1 6 1 Trimethylpentane Other: 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations.Requested limit(s)should consider future process growth,component count variability,and gas composition variability. COLORADO Form APCD-203-Fugitive Component Leak Emissions APEN - Revision 7/2018 6 I f= ;= Permit Number: AIRS ID Number: 1 23 /9DF7/ [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 10-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 2/1/I5 Signature of Legally Authoriz d-P rson (not a vendor or consultant) Date g g Y/ Ethan Hinkley Air Quality Compliance Manager Name(print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance D Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. • Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692.3175 or(303)692.3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment httos://www.colorado.eov/cdphe/apcd Ay COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 7 I Ay ,,z.'"�w;,, Hello