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HomeMy WebLinkAbout20192223.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 June 3r, 2019 Dear Sir or Madam: RECEIVED JUN 1 0 2 wV �.✓ WELD COUNTY COMMISSIONERS On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for SRC Energy, Inc. - Leffler 8-21, Donn 1-21 Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor M th`C- C_2 /l-1 Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Pt -41 aR IMP► !C_w ) C,.o Il► I l 9 2019-2223 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: SRC Energy, Inc. - Leffler 8-21, Donn 1-21 Pad - Weld County Notice Period Begins: June 6, 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: SRC Energy, Inc. Facility: Leffler 8-21, Donn 1-21 Pad Exploration and Production Well Pad NENE and SENE Sec. 21 T6N R66W Weld County The proposed project or activity is as follows: This project is a new well pad production facility that began operation 1/10/2018 and is located in the ozone non -attainment area to permit 8-400 bbl condensate storage tanks and hydrocarbon liquid loadout. In addition to these individual permit requests, this facility has 2-400 bbl produced water tanks that have been permitted under the GP08 program and 5 natural gas engines which have been permitted under GP02 for this project. The facility is a synthetic minor facility for NOx, VOC and HAPs (n -hexane and total HAPs). The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0602 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 <OIORADO Twncrev.iac head, £ 6FxrioawmnM th & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0602 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: SRC Energy, Inc. Leffler 8-21, Donn 1-21 Pad 123/9FC9 NENE and SENE SEC 21 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TNK 1-8 001 Eight (8) 400 barrel fixed roof storage vessels used to store condensate Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, y submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 COLORADO Air Pollution Control Division Department al Public Health & Environment Page 1 of 10 It in •cati i f the •ermit. A self certification form and guidance on ertifpli. c:` as r:f'uired by this permit may be obtained online at of a.go_ /cdf , e/. -permi ;>elf -certification. (Regulation Number 3, Part B, 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO TNK 1-8 001 --- 4.6 49.3 21.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division Department of Public Health & Env&onment Page 2 of 10 • c Pollutants E. i • t I o9 Control Device rS. Controlled TNK 1-8 001 ombustion Device (Four (4) IES 96" Enclosed Combustors) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TNK 1-8 001 Condensate throughput 2,541,714 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply COLORADO Air Pollution Control Division Department U Public Health 6 Environment Page 3 of 10 sed; have no visible emissions during normal on Number 7, XVII.A.16; and be designed so that servation from the outside of the enclosed flare convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O8M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) 17. A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. 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 COLORADO Mr Pollution Control Division Department el Pubic Health & Duironment Page 4 of 10 days prior to testing. No compliance test shall rom the Division. (Regulation Number 3, Part B., 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). COLORADO Air Pollution Control Division Department of Public Health & 6nvvonment Page 5 of 10 21. t be retained and made available for inspection y be re sued to a new owner by the APCD as provided in ,rt B,on II.B. B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. CDPHE a - COLORADO Air Pollution Control Division Department of Publie Health Er Environment Page 6 of 10 Permit History Issuance Date Description Issuance 1 This Issuance Issued to SRC Energy, Inc. COLORADO Air Pollution Control Division Department of PutAic Health & En4irurtrnent Page 7 of 10 Notes • Pe :>_ it'kf. -rat tim- � his p w mit issuance: 1) Th p. fee or the processing time for this permit. An invoice fo er the -rmit is issued. The permit holder shall pay the i ��•' -�wi ' 3 ` •: �' o` :° of t voice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: / /www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 11,006 220 Toluene 108883 10,701 214 Ethylbenzene 100414 658 13 Xylenes 1330207 5,287 106 n -Hexane 110543 83,877 1,678 2,2,4- Trimethylpentane 540841 844 17 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. COLORADO Air Pollution Control Division Department of Public Health 6 Envvonvnent. Page 8 of 10 it are based on the following emission factors: CAS # Pollutant Un rolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.64E-03 3.64E-03 AP -42, Chapter 13.5 CO 1.66E-02 1.66E-02 VOC 1.939 3.878E-02 ProMax simulation of flash and working/breathing emissions based on a pressurized liquid sample taken 1/29/2018 71432 Benzene 4.33E-03 8.66E-05 108883 Toluene 4.21 E-03 8.42E-05 100414 Ethylbenzene 2.59E-04 5.18E-06 1330207 Xylene 2.08E-03 4.16E-05 110543 n -Hexane 3.30E-02 6.60E-04 540841 2 2 4- Trimethylpentane 3.32E-04 6.64E-06 Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 98%. The combustion emissions were calculated using a waste gas heat content of 2,471 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 shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https: / /www.federalregister.gov/documents/2016/06/03/2016-11971 /oi l -and - natural -gas -sector -emission -standards-for-new- reconstructed -and - modified -sources 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, CO, n -Hexane, Total HAPs NANSR Synthetic Minor Source of: NOx, VOC PSD Synthetic Minor Source of: VOC COLORADO Air Pollution Control Division Department of Pubfie i fealch b En ,onment Page 9 of 10 10) F of � P - +n of can be found at the website listed below: http://www.ecfr.gov/ ronment Electronic Code of Federal Regulations Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Mr Pollution Control Division Department 4t Public Health & Envimnrnent. Page 10 of 10 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0603 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: SRC Energy, Inc. Leffler 8-21, Donn 1-21 Pad 123/9FC9 NENE and SENE SEC 21 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LDG-1 002 Truck loadout of condensate by submerged fill Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, ty submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 COLORADO Mr Pollution Control Division Department of Public health & Environment Page 1 of 9 days may result in revoca rm an guidance on how to self -certify compl nc _ reper be obtai -d online at www.colorado.gov/cdphe air -permit -se -certification. ('egu ation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO LDG-1 002 --- --- 0.8 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for criteria pollutants OR for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division Department nl Pubhc ifealth & FAvvonment Page 2 of 9 Facility"' Equipment ID AIRS Point _ Co rol vi v ollutants ontrolled LDG-1 002 Enclosed Combustion Device VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LDG-1 002 Condensate Loaded 127,086 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.D.2) 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): COLORADO Air Pollution Control Division Department of Public H?alth& 'crwroonrnent Page 3 of 9 a. The owner or opeipent t ensure that hoses, couplings, d $ = es am tai ed to rev t drippin leaking, or other liquid or vapor oss during owing and un oading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 13. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&tM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. COLORADO Air Pollution Control Division Department of Public Keach 5 Envvonment Page 4 of 9 Periodic Testing Require 16. This source is not require =`suerwise -`z' ted by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOt) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; 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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). COLORADO Air Pollution Control Division Deparinten; of Public Health b Llibivournent Page 5 of 9 GENERAL TERMS AND CONDITIO 19. This permit and any atto£ m - rr ,> wr an ailabl inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued 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. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. COLORADO Air Pollution Control Division Department of Public Heald t Environment Page 6 of 9 By: Lauraleigh Lakoc Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to SRC Energy, Inc. COLORADO Air Pollution Control Division Department of Public Health & Environment Page 7 of 9 Notes to Permit Holder at the ti 1) The permit holder is require ees he sinhis peAn invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: / /www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 52 3 n -Hexane 110543 458 23 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC -- 0.236 1.18E-02 State Emission Factor Benzene 71432 4.16E-04 2.08E-05 n -Hexane 110543 3.61E-03 1.805E-04 Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five - COLORADO Air Pollution Control Division Department of Public Health 5 Environment Page 8 of 9 year term expires. Please ref APEN expiration date for eac questions regarding a specific expiration .ate ca t e 7) This facility is classified as follows: o det: ine the ermit. F any 3) -692 - Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, CO, n -Hexane, Total HAPs NANSR Synthetic Minor Source of: NOx, VOC PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: https://ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Department of Public Meath & EEnvironment. Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Lauraleigh Lakocy Package If: 378530 Received Date: 4/10/2018 Review Start Date: 12/7/2018 Section 01 - Facility Information Company Name: SRC Energy, Inc. County AIRS ID: 123 Quadrant Section Township Range NENE & SENE 21 6N 66 Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: 9FC9 Leffler 8-21, Donn 1-21 Pad NENE & SENE quadrant of Section 21. Township 6N, Range 66W Weld County Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point tt Emissions Source Type Equipment Name Emissions Control? Permit $4 Issuance # Self Cert Required? Action Engineering Remarks Condensate Tank TNK 1-8 I - , 18WE0602 Permit Initial Issuance Liquid Loading LOG -1 18WE0603 Permit Initial Issuance Section 03 - Description of Project This project is for a new well pad production facility that began operation 1/10/2018 and is located in the ozone non -attainment area to permit 8-400 bbl condensate storage tanks and hydrocarbon liquid loadout. In addition to these individual permit requests, this facility has 2-400 bbl produced water tanks that have been permitted under the GP08 program and 5 natural gas engines which have been permitted under GP02 for this project. The facility is a synthetic minor facility for NOx, VOC and HAPs (n -hexane Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Yes Was a quantitative modeling analysis required? arc- If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants her€ SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx J CO “DC PM2.5 PM10 TSP HAPs I4 NOx CO \'OC PM2.5 PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 County 9FC9 Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Eight (8) - 400 bbl fixed roof storage vessels used to store condensate liquid Four (4) IES 96" Enclosed Combustors 98 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 2,118,092 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 2,118,092 Barrels (bbl) per year Requested Permit Limit Throughput = 2,541,714 Barrels (bbl) per year Requested Monthly Throughput = 215872 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = 2,541,714 Barrels (bbl) per year 2471 21.7035811 Btu/scf scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? 113,592 MMBTU per year 136,311 MMBTU per year 136,311 MMBTU per year Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 1.94 0.04 Site Speiiiic E.I. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 0.004 0.000 Toluene 0.004 0.000 Ethylbenzene 0.000 0.000 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes ffas) Xylene 0.002 0.000 n -Hexane 0.033 0.001 224 IMP 0.000 0.000 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 0.0004 AP -42 Table 1.4-2 (PM1,O/PM.2.5'r AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Chapter 13.5 industrial Flares (NOx) AP -42 Chapter 13.5 industrial Flares (CO) PM2.5 0.0075 0.0004 NOx 0.0680 0.0036 CO 0.3100 0.0166 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrclled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 2464.2 7053.5 41.1 2464.2 49.3 8372 0.5 0.4 0.4 0.5 0.5 86 PM2.5 0.5 0.4 0.4 0.5 0.5 86 NOx 4.6 3.9 3.9 4.6 4.6 787 CO 21.1 17.6 17.6 21.1 21.1 3589 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 11006 9171 183 11006 220 Toluene 10701 8917 173 10701 214 Ethylbenzene 658 549 11 658 13 Xylene 5287 4406 88 5287 106 n -Hexane 83877 69897 1398 83877 1678 224 TMP 844 703 14 844 17 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section Xli.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2of10 K:\PA\2018\18WE0602.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? No If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? fo If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally mean; site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. Yes If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specifi: emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Volume of waste gas was calculated using the results from the ProMax simulation for standard vapor volumetric flowfor flash gas and working losses per (user -defined) standard condensate volumetric flow. This source is a well affected facility and a storage vessel affected facility based on the permitted emissions of 49.3 tpy per 8 storage vessels > 6tpy per vessel and is therefore subject to NSPS OOOOa. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # SCC Code 01 4M4-003-11 Fixed Roof Tank, Condensate, working+bbreathing+#lashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 Ib/1,000 gallons condensate throughput PM2.5 0.01 0 lb/1,000 gallons condensate throughput NOx 0.09 0 lb/1,000 gallons condensate throughput VOC 46.2 98 lb/1,000 gallons condensate throughput CO 0.40 0 lb/1,000 gallons condensate throughput Benzene 0.10 98 lb/1,000 gallons condensate throughput Toluene 0.10 98 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 98 lb/1,000 gallons condensate throughput Xylene 0.05 98 lb/1,000 gallons condensate throughput n -Hexane 0.79 98 lb/1,000 gallons condensate throughput 224 TMP 0.01 98 lb/1,000 gallons condensate throughput 3 of 10 K:\PA\2018\18NE0602.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 WY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0501 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Fegulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emission: greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a pertnrt Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section XII.C-F Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C2 — Emission Estimation Procedures Section XII.D — Emissions Control Requirements Section XII.E — Monitoring Section XII.F — Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section XII,G Section XII.G.2 - Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C2 — Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station3 or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7. Section XVII. B, CA & C3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C3 - Recordkeeping Requirements S. Does the condensate storage tank contain only "stabilized" liquids? (Storage tank is subject to Regulation 7, Section XVII C .2 Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipmen• 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (`472 BBLs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBLJ used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.11lb? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.; ) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.111 b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa x29.7 psr1 and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 ['950 BBL) and stores a liquid with a maximum true vapor pressure' less than 35 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' (^'472 B3L1 but less than 151 m3 [%950 BBL and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? Yes No Yes No Yes Yes Yes No No Source Req Go to next Source Req Continue • ' Continue • ' Source is st Continue -' Storage Tar Source is st Continue -' Go to then Go to the n Source is st Source is st Storage Tat Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.1166 - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HI -I? Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures 460.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user3 (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.7E1? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subject to MACT HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774-Recordkeeping §63.775 Reporting Yes No RACT Review RACT review is required if Regulation 7 does not apply AND If the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applcability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation. and the analysis it contains may not apply to a particular s tuation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable 'n the event of any conflict between the language of this document and the language of the Clean Air Act., its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may.' "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Continue Storage Tar Continue -' Storage Tar Hydrocarbon Loadout Emissions Inventory 002 Liquid Loading Facility AIRs ID: 123 County 9FC9 Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Contingency (5%) truck load out of condensate from storage tanks teed 30" Enclosed Combustor Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Yes 100.0 95 95.00 105.905 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 105,905 Barrels (bbl) per year Requested Permit Limit Throughput = 127,086 Barrels (bbl) per year Requested Monthly Throughput = 10794 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 127,086 Barrels (bbl) per year 2502.47 Btu/scf 174878 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? 365 MMBTU per year 438 MMBTU per year 438 MMBTU per year Yes Yes The state default emissions factors may be used to estimate emissions. w.. .r ,. ,.. . . tt T� t 4 /. 1'iit:Ct f :a rn . rs+.4t . f i.c-mporitt r lt,' Toluene ris/ /471 Ethylbenzene Xyferte nrilexan 22:4 IN MasS frActivn 4 Fmissiur f3t-to �Si1t ; } t.;.i ,»r,:. «,..... «-.. t-1.•,. • • ->.. ...; :./i ,_/i.../... c.� /,ir../;., r ,�„s wv«' �ir'li..f :.f4�•4.41d�iXff 6.r/..e �: L7+L124LCG/li�iAti.i-.H.`,t w:i ir; . ..NN.hv�ii/.....n.d:l%✓/6H.G-i:�.j//�^..dGYi`3 / .� eL �lmsvvi„' Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 2.36E-01 1.18E-02 Condensate LoadoutState E.F. Benzene 4.10E-04 2.05E-05 Condensate Loadout State E.F. Toluene 0.00E+00 0.00E+00 Condensate Loadout State E.F. Ethylbenzene 0.00E+00 0.00E+00 Condensate Loadout State E.F. Xylene 0.00E+00 0.00E+40 Condensate Loadout State E.F. n -Hexane 3.60E-03 1.80E-04 Condensate LoadoutState E.F. Condensate LoadoutState F 224 TMP 0.00E+00 0.00E+00 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 2.57E-05 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 2.57E-05 AP -42 Table 1.4-2 (50x) M'-42 Chapter 133 Industrial Hares (NOx) AP -42 Chapter 133 Industrial Flares (CO) SOx 0.0006 2.03E-06 NOx 0.0680 2.34E-04 CO 0.3100 1.07E-03 5 of 10 K:\PA\2018\18 NE0602.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.01 0.01 0.01 0.01 0.01 3 15.00 12.50 0.62 15.00 0.75 127 0.07 0.06 0.06 0.07 0.07 12 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/yearP (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) 0.0261 0.0000 0.0000 0.0000 0.2288 0.0000 Benzene Toluene Ethylbenzene 52 43 2 52 3 0 0 0 0 0 0 0 0 0 0 Xylene 0 0 0 0 0 n -Hexane 458 381 19 488 23 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis 0.0013 0.0000 0.0000 0.0000 0.0114 0.0000 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 Enclosed combustor has a manufacturer guaranteed control efficiency of 98%; however, source has requested a 95% control efficiency. On APEN, source responded yes to 2 of the questions in section 3, which suggest permit exemation; however, they are not applicable to the determination of whether this source requires a permit. This source does not submerge fill fess than 16308 BBL of condensate per year and thus requires a permit. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # 01 SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.6 95 lb/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.00 95 Ib/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.09 95 Ib/1,000 gallons transferred 224 TMP 0.00 95 Ib/1,000 gallons transferred 6 of 10 K:\PA\2018\18VVt E0602.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude of per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non•Attainment Area • NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Ye. No No No Yet Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? No The loadout must be operated with submerged fill to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it conta.ns may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can." is intended to describe APCD interpretations and recommendations. Mandatory terminology such as must" and required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document coes not establish legally binding requirements in and of itself Go to next Go to the n Go to next Go to next Go to next The loadou The loadou COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FC9 Facility Name Leffler 8-21, Donn 1-21 Pad History File Edit Date 3/26/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons aer year POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE0602 Condensate Tanks (8)- 400 bbl 4.6 2,463.9 21.1 56.2 4.6 49.3 21.1 1.1 New emission point, modelled EF 002 18WE0603 Hydrocarbon Liquid Loadout 15.0 0.3 0.8 0.0 003 GP08 Produced Water Tanks (2)-400 1.4 99.7 6.4 9.2 1.4 5.9 6.4 0.5 New GP08 Request, State EF 004 GP02 Doosan 14.6L 390 HP 4SRB 0.2 0.1 0.1 33.0 2.6 55.6 0.5 0.2 0.1 0.1 0.3 2.6 0.2 0.5 005 GP02 Caterpillar 203 HP 4SRB RICE 0.2 0.1 0.1 32.5 1.4 32.5 0.6 0.2 0.1 0.1 2.0 1.4 3.9 0.6 006 GP02 Caterpillar 1150 HP 4SLB RICE 0.4 0.0 0.0 5.6 7.9 27.5 2.6 0.4 0.0 0.0 5.6 2.2 5.6 1.3 007 GP02 Caterpillar 1150 HP 4SLB RICE 0.4 0.0 0.0 5.6 7.9 27.5 2.6 0.4 0.0 0.0 5.6 2.2 5.6 1.3 008 GP02 Caterpillar 145 HP 4SRB RICE 0.1 0.0 0.0 18.8 1.0 18.8 0.4 0.1 0.0 0.0 0.7 1.0 2.8 0.4 0.0 0.0 0.0 0.0 /;PEN Exempt/Insignificant Sources 0.0 0.0 Heaters (25) 0.4 0.4 5.6 0.30 4.7 0.0 0.4 0.4 5.6 0.3 4.7 0.0 From Form APCD-102 Fugitive Emissions 0.5 72.3 0.5 5.6 From Form APCD-102 FACILITY TOTAL 1.7 0.6 0.2 0.0 107.1 2,599.7 0.5 194.1 144.6 1.7 0.6 0.2 0.0 25.8 65.7 0.5 50.3 11.2 VOC: Syn Minor NOx: True Minor CO: Syn Minor (OP), HAPS: Syn Minor (NANSR (PSD, n NANSR and and OP) True Minor (PSD) -Hexane and OP) Total Permitted Facility Total 1.3 0.2 0.2 0.0 101.5 2,599.4 0.0 189.4 72.3 1.31 0.2 0.2 0.0 20.2 65.41 0.0 45.61 5.6 Excludes units exempt from (A) Change in Permitted Emissions 1.3 0.2 0.2 0.0 20.2 65.4 0.0 45.6 Pubcom synthetic total required required because on new minor limit (point 001) and project emissions (001, 002). Modeling not based on Division guidance. Note 1 Total VOC Faci _4) Change in Total Permitted VOC ity Emissions (point and fugitive emissions (point and fugitive 66.2 Facility Project is eligible for emissions not GP02 because < 90 less than 25 tpy 65.4 Note 2 Page 8 of 10 Printed 4/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FC9 Facility Name Leffler 8-21, Donn 1-21 Pad Emissions - uncontrolled (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE0602 Condensate Tanks (8)- 400 bbl 11006 10701 658 5287 83877 844 56.2 002 18WE0603 Hydrocarbon Liquid Loadout 458 0.3 003 GP08 Produced Water Tanks (2)-400 bbl 4441 I 13956 9.2 004 GP02 Doosan 14.6L 390 HI-) 4SRB RICE 612 79 47 91 0.5 005 GP02 Caterpillar 203 HP 4SRB RICE 979 42 25 49 0.6 006 GP02 Caterpillar 1150 HP 4SLB RICE 3772 720 443 38 215 2.6 007 GP02 Caterpillar 1150 HP 4SLB RICE 3772 720 443 38 215 2.6 008 GP02 Caterpillar 145 HP 4SRB RICE 756 17 34 0.4 0.0 0.0 APEN 0.0 Heaters (25) 0.0 TOTAL (tpy) 4.9 0.8 0.5 7.8 5.4 0.3 2.6 49.1 0.3 0.4 0.0 0.0 72.3 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acroleln Benzene Toluene Ethylbenzene Xylenes n -Hexane TOTAL (tpY) McOH 224 TMP H2S Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0.0 0 0 0 001 18WE0602 Condensate Tanks (8)- 400 bbl 220 214 13 106 1678 1.1 17 002 18WE0603 Hydrocarbon Liquid Loadout 23 0.0 003 GP08 Produced Water Tanks (2)-400 bbl 222 698 0.5 004 GP02 Doosan 14.6L 390 HP 4SRB RICE! 612 0.5 9 18WE0602.CP1 4/4/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9FC9 Facility Name Leffler 8-21, Donn 1-21 Pad 005 GP02 Caterpillar 203 HP 4SRB RICE 979 42 25 0.6 49 006 GP02 Caterpillar 1150 HP 4SLB RICE 1109 720 443 38 1.3 215 007 GP02 Caterpillar 1150 HP 4SLB RICE 1109 720 443 38 1.3 215 008 GP02 Caterpillar 145 HP 4SRB RICE 756 29 17 0.4 34 0.0 0.0 APEN 0.0 Heaters (25) 0.0 TOTAL (tpy) 2.3 0.8 0.5 0.3 0.1 5.6 0.0 0.1 1.2 0.3 0.0 0.0 0.0 10 18WE0602.CP1 4/4/2019 :'LivLD r;PR102018 Condensate Storage Tank(s) APEN - Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: is we 0 Ce 0 2 AIRS ID Number: 123 /q FCa /00 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: Leffler 8-21, Donn 1-21 Pad Site Location: NENE and SENE Sec. 21 T6N R66W Mailing Address: (Include Zip Code) 5400 VV. 11th Street, Suite C Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211 111 Permit Contact: Brad Rogers Phone Number: (970) 475-5242 E -Mail Address2: brogers@srcenergy.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017 3-1c52c1 ,iAV COLORADO Dewnvsn[ of Put,c Nun ...torment Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit 0 GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name ❑ Change permit limit ❑ Transfer of ownership3 0 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 £t Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: Storage of condensate from production wells For new or reconstructed sources, the projected start-up date is: 1/10/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration a Production (EitP) site 0 Midstream or Downstream (non EftP) site Will this equipment be operated in any NAAQS nonattainment area? Yes No p • Are Flash Emissions anticipated from these storage tanks? Yes No FA • Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No FA • If "yes", identify the stock tank gas -to -oil ratio: 0.00387 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualSI emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 Permit Number: AIRS ID Number: ❑ Upward ❑ Horizontal [Leave blank unless APCD has already assigned a permit ` and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl/year) Condensate Throughput: 2,118,091.6 2,541,714.0 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 47.5 degrees O Internal floating roof Tank design: Fixed roof RVP of sates oil: 10 psi D External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TNK 1-8 8 3200 01/2018 01/2018 Wells Serviced by this Storage Tank or Tank Battery5 (EELP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 44823 Leffler 8N -23B -L 151 05 - 123 - 44824 Leffler 8C -23-L l7 05 - 123 - 44825 Leffler 8N -23C -L F4 05 -- 123 - 44826 Leffler 40C -23-L - F4 05 - 123 - 44827 Leffler 26C -23-L Fl 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.47686/-104.77436 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 COLORADO 3 j� d�h,�m.n, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit u and AIRS ID] 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. Pollutants Controlled: Vapor ❑ Recovery , Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 282.1 MMBtu/hr Make/Model: (4) I ES - 96" Type: (4) Enclosed Combustors Requested Control Efficiency: 98 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 1,076 F Waste Gas Heat Content: 2,471 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 0.12 MMBtu/hr O Closed Loop System Description of the closed loop system: El Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (EitP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 21 psig Describe the separation process between the well and the storage tanks: (25) 36" Worthington 3 -phase horizontal separators, (5) 36" 2 -phase vertical separators, and (1) 60" gas buster Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 ,COLORADO Neel1T b FJIVI/O11m0N Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) V0C ECD 98 NOx CO HAPs ECD ,98 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions? (Tons/year) Uncontrolled "Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 1.939 V Ibs/bbl ProMax 2,053.25 41.06 2,463.90 49.28 NOx 0.068 Ib/MMBtu AP -42 N/A 3.86 N/A 4.63 CO 0.310 Ib/MMBtu AP -42 N/A 17.60 N/A 21.13 Non -Criteria Reportable Pollutant Emissions Inventory_:_ Chemical Name Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) g Uncontrolled Emissions Pounds/ ear (Pounds/year) ) Controlled Emissions7 (Pounds/year) Benzene 71432 4.33E-03 '/Ibs/bbl ProMax 9,171.34 183.43 Toluene 108883 4.21E-03 °Ibs/bbl ProMax 8,917.17 178.34 Ethylbenzene 100414 2.59E-04 ✓Ibs/bbl ProMax 548.59 10.97 Xylene 1330207 2.08E-03 q- Ibs/bbl ProMax 4,405.63 88.11 n -Hexane 110543 3.30E-02 .dlbs/bbl ProMax 69,665.72 1,393.31 2,2,4- Trimethylpentane 540841 3.32E-04\efbsIbbl ProMax 703.21 14.06 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN —Revision 07/2017 ®V COLORADO 5 I em wr,su� 'whim a c,..�.oan,.N Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek ()rive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 COLORADO 6 I p.pvement W P Wr H.ath 6 4v.�vrwen. Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: iswEa(P03 AIRS ID Number: 123 /Q1Fq /00 2, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: LDG-1 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: SRC Energy, Inc. Leffler 8-21, Donn 1-21 Pad Site Location: NENE and SENE Sec. 21 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Greeley, CO 80634 E -Mail Address' brogers@srcenergy.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brad Rogers Phone Number: (970) 475-5242 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 3-1%. 3 O ®® COLORADO 1 tleparlxneMolkala. Health 6 Enunommurnf Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action El NEW permit OR newly -reported emission source ❑✓ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 0 Other (describe below) OR - APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Requesting 5% load out as contingency 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Contingency truck load out of condensate from storage tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 1/ 10 /2018 Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 Yes Yes Yes Yes 0 Yes Yes 0 Yes 0 ❑✓ No No No No ❑ No ❑ No El No ®V COLORADO = 2 I xo,rYm�mm eveu� Hu�1+Yi S £nunvnmun+ Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate El Crude Oil El Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth 127,085.6 Bbl/yr Actual Volume Loaded: 105,904.6 Bbl/yr This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") tank trucks If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: °F True Vapor Pressure Psia @ 60 °F Molecular weight of displaced vapors Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: Bbl/yr Actual Volume Loaded: 4 Requested values will become permit limitations. Requested limit s) should consider future process growth Bbl/yr Product Density: Load Line Volume: Lb/ft3 ft3/truckload Vapor Recovery Line Volume ft3 /truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 3 IAV Ha:a�n 6 £no�ronmen� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.47686/-104.77436 Operator ! Stack ID No: Discharge Height Above Ground Level, , (Feet) Temp ('F) Flow Rate. (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal D Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ' ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system: Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 14.88 MMBtu/hr Type: Enclosed Combustor Make/Model: Leed 30" L30-0011 Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 95 98 1076 Waste Gas Heat Content 2502.47 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0.051 MMBtu/hr Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 A COLORADO 4 I Acnt. Hwhh 6 Fsvnenm•n Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ✓❑ Yes O No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control' Efficiency (% reduction in emissions) PM SOX NO), CO VOC Leed 30" enclosed combustor 95% HAPs Leed 30" enclosed combustor 95% Other: ❑✓ Using State Emission Factors (Required for GP07) VOC 0 Condensate 0.236 Lbs/BBL ❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL. From what year is the following reported actual annual emissions data? 2018 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions - � ; ..: : Requested Annual Permit Emission Limit s) s . , Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) . Controlled (Tons/year). PM SOX NO. VOC 0.236 lbs/bbl State EF 12.50 0.62 15.00 0.75 CO Benzene 4.16E-04 lbs/bbl State EF 2.20E-02 1.10E-03 2.64E-02 1.32E-03 Toluene Ethylbenzene Xylenes n -Hexane 3.61 E-03 lbs/bbl State EF 1.91 E-01 9.56E-03 2.29E-01 1.15E-02 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 ®Y COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and MRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 4/9/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (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 $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 6 I Ig7 Dcpp ncntm vMc s.�rn 6 &:mnmmu COLORADO Hello