HomeMy WebLinkAbout20180633.tiffCOLORADO
Department of Public
Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
February 22, 2018
Dear Sir or Madam:
On March 1, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for SRC
Energy, Inc. - Orr State 40-36 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
ptax. Re_
03-05— 18'
Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
CC: PLC MNAITP), H L CST),
pbcJ C ere" 4 I SPA( CO
02-2l.-1 8'
2018-0633
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: SRC Energy, Inc. - Orr State 40-36 Pad - Weld County
Notice Period Begins: March 1, 2018
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: Orr State 40-36 Pad
Well production facility
NESE Section 36 T6N R67W
Weld County
The proposed project or activity is as follows: Well production facility; individual permits are for
condensate tanks and loadout to trucks; other equipment associated with this project are three (3) GP02
registrations for engines, one (1) GP08 registration for produced water storage tanks, and one (1) GP06
registration for a diesel generator engine. APEN-exempt equipment associated with this project are heaters
and fugitive emissions.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permits 17WE1141 and
17WE1142 have been filed with the Weld County Clerk's office. A copy of the draft permits 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 abilitfr
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. Any such comment must be submitted in writing to the following addressee:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: AndyOruel
Package #: 37LYS23
Received Date:
Review Start Date:
1112,7/2017
;vs/2018'
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
9F60'.;..
Facility Name: 'Orr Stake 4t35
Physical Address/Locatia NESE quadrant of Section 36, Township 6N, Range 67W, in Weld County, Colorado
Type of Facility: ExPlaratian & Pj'tsc('uigtt 4(I Pad
What industry segment? y i tura[ a3.Elnci Yhtioz &Process's
Is this facility located in a NAAQS non -attainment area? O.
If yes, for what pollutant? Bon Monoxide (CO)
Weld
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
13�3�3
j3
alb"^,/
Condensate tar€tc �/`
'' ''
TNK 1 8
: s "°
S7W€2141"
.8f3'Tiit ddf
008
RV
on iqurdto3d€ng
LO 1
)
No. .;;=-17WE1142
GP1 1..
r .,
Yes
Permit irriti
issciancei
Section 03 - Description of Project
�l 11131tf11
Newsynthet€cmin ro&t iY2m iazonenon -attainment area.
li� -.�...
Project ylsq includes three:(3) GPD2 registrations
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?Requesting
Section 05 - Ambient Air Impact Analysis Requirement!
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration IPSO)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
J
Is this stationary source a major source? w ?I
If yes, explain what programs and which pollutants here SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
NOx
CO
J
PM2.5
VOC
PM10 TSP
❑ ❑✓
HAPs
❑ ❑
Condensate Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
Facility AIRs ID:
.6123.
County
9F6D
Plant
0
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Eight (8) 400 -bbl fixed roof atmospheric condensate storage vessels.
Description:
Emission Control Device our (4) enclosed combustors DES 96").. Combustors
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Condensate Throughpu
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced = 55.49 scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
1,136,526. Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating =
2,363,959. Barrels (bbl) per year
95S! Barrels (bbl) per year
Btu/scf from ProMax output
from ProMax output — includes flash and working/breathing vapors
42,308 MMBTU per year
88,001 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 88,001 MMBTU per year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
30143dJ.13'i'.
0.0260
0.0001
0.0001
Benzene
Toluene
670:00276f≥≥?
0.00266 _.
0,00015
0.00126
0.02134
Ethylbenzene
0.000003
0.00003
0.0004
Xylene
n -Hexane
224 TMP
....0,00018......:':
0.000004
Pollutant
Control Device
Uncontrolled Uncontrolled
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
..,0:.0075
(Condensate
Throughput)
PM10
PM2.5
0.0003
0.0003
0.0025
0.0115
0.0075-:-
0.0630
0.3100
NOx
CO
Section OS - Emissions Inventory
Emission Factor Source
Emission Factor Source
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)
VOC
PM10
PM2.5
NOx
CO
1538.27
739.6
14.8
1538.27
30.77
0.33
0.2
0.2
0.33
0.33
0.33
0.2
0.2
0.33
0.33
2.99
1.4
1.4
2.99
2.99
13.64
6.6
6.6
13.64
13.64
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
fibs/year) fibs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
6532
3141
63
6532
131
6284
3021
60
6284
126
353
170
3
353
7
2983
1434
29
2983
60
50680
24365
487
50680
1014
419
201
4
419
8
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XII.C, D, E, F
Regulation 7, Section 111.5, C
Regulation 7, Section XVII.B, C.1, C.3
Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Regulation 6, Part A, NSPS Subpart 0000a
Regulation 8, Part E, MACT Subpart HH
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Storage tank is subject to Regulation 7, Section XII.C-F
Storage Tank is not subject to Regulation 7, Section XII.G
Storage tank is subject to Regulation 7, Section XVII, B, Cl & C3
Storage tank is subject to Regulation 7, Section XVII.C.2
Storage Tank is not subject to NSPS Kb
Storage Tank is not subject to NSPS 0000a
Storage Tank is not subject to MACE HO
2 of 3 K:\PA\2017\17WE1141.CP1.xlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of tie application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analvsb Notes
Applicant based theACILAL EMISSIONS values on a sample collected early on in the prodoctiortcycle. In October 2017the site was la
concentrations. The ACTUAL EMISSIO Ns values were calculated by using the results of theorigiial sample multiplied by the throughp
of the resample multiplied by the throughput from the re le date through the end of tbe-year.
The VOC and HAP emission-Mctors reflectth t re piing event and ace usedf r permit development and emusionlimit determination. EFs were doter
site -specific liquid analysis based one condensatethrougl�tltof 23@3961 bb)/yr
••••
Section 09 - Inventory 5CC Coding end Emissions Factors
AIRS Point #
007
Process # SCC Code
01
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 0.01 0 lb/1,000 gallons condensate throughput
PM2.5 0.01 0 lb/1,000 gallons condensate throughput
NOx 0.06 0 lb/1,000 gallons condensate throughput
VOC 31.0 98 lb/1,000 gallons condensate throughput
CO 0.27 0 lb/1,000 gallons condensate throughput
Benzene 0.07 98 lb/1,000 gallons condensate throughput
Toluene 0.06 98 lb/1,000 gallons condensate throughput
Ethylbenzene 0.004 98 lb/1,000 gallons condensate throughput
Xylene 0.03 98 lb/1,000 gallons condensate throughput
n -Hexane .. 0.51 98 Ib/1,000 gallons condensate throughput
224 TMP 0.004 98 lb/1,000 gallons condensate throughput
3 of 3 K:\PA\2017\17W E1141.CP1.xlsm
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
SRC Energy, Inc.
123
9F6D
Orr State 40-36 Pad
History File Edit Date
Ozone Status
1/10/2018
Non -Attainment
EMISSIONS - Uncontrol ed (tons per year)
EMISSIONS With Controls (tons per year)
POINT
AIRS
ID
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
GP02
Waukesha FIBGSI, sn: C-12669/1
0.3
0.3
54.1
7.7
54.1
0.4
0.3
0.3
3.9
2.7
7.7
0.4
new GP02
002
GP02
Waukesha F18GSI, sn: C-10550/1
0.3
0.3
54.1
7.7
54.1
0.4
0.3
0.3
3.9
2.7
7.7
0.4
new GP02
003
GP02
Doosan D146L. sn: EEZOG300622
0.3
0.3
30.4
0.5
56.5
0.5
0.3
0.3
0.3
0.2
0.3
0.5
new GP02
004
t:P02.0%
Caterpillar 034067A, so: 4FO04 ITS
cancelled Jan 2018
005
GP06
Cummins QSM11-G4 NR3, sn: 35269881
0.5
0.5
3.4
10.9
3.8
9.5
0.2
0.5
0.5
3.4
10.9
3.8
9.5
0.2
new GP06
006
GP0B
Prod water storage (800 bbl)
6.0
0.5
6.0
0.0
new GP08
007
17WE1141
Condensate storage (3200 bbl)
0.3
0.3
3.0
1,538.3
13.6
33.6
0.3
0.3
3.0
30.8
13.6
0.7
SSEFs accepted; requested 98% control
008
17WE1142
Loadout when tACT not available
0.0
9.9
0.1
0.2
0.0
0.2
0.1
0.0
000
Cancelled -
Gaslack 0.1230. sn: FP -62£193
was XP pf/oi, cancelled Jan 2018
APEN-Exempt / Insignificants
Heaters (24)
0.5
0.5
6.6
0.4
5.5
0.1
0.5
0.5
6.6
0.4
5.5
0.1
from Jan 2018 revised application
Fugitives
0.4
0.0
0.4
0.0
from Jan 2018 revised application
FACILITY TOTAL
2.2
2.2
0.0
3.4
159.1
1,574.2
0.4
193.4
36.0
2.2
2.2
0.0
3.4
28.5
46.7
0.4
44.4
2.3
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (PSD and OP)
HAPS: Syn Minor n -hexane and total
HH: Syn Minor + affected Area
7777: Syn Minor
Permitted Facility Total
1.7
1.7
0.0
3.4
152.5
1,573.9
0.0
187.9
35.9
1.7
1.7
0.0
3.4'
22.0
46.3
0.0
38.9
2.2
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
1.7
1.7
0.0
3.4
22.0
46.3
0.0
38.9
Pubcom required based on new synthetic minor
limits
Note 1
Total VOC Facility Emissions (point and fugitive
(A) Change in Total Permitted VOC emiss ons (point and fugitive)
47.1
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
46.3
Application received a wholesale revision in January 2018.
Note 2
Page 1 of 2
Printed 2/7/2018
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 9F6D
Facility Name Orr State 40-36 Pad
Emissions - uncontrolled (Ibs Der year
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
"""""
TOTAL (ipy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP02
Waukesha F18GSI, sn: C-12669/1
544
74
70
42
81
18
0.4
002
GP02
Waukesha F18GSI, sn: C-10550/1
544
74
70
42
81
18
0.4
003
GP02
Doosan D146L, sn: EEZOG300622
623
85
80
48
93
20
0.5
004
GP02.CAl
Caterpillar S3406TA, sn: 4FO04178
005
GP06
Cummins QSM11-G4 NR3, sn: 3526988
26
153
19
187
0.2
006
GP08
Prod water storage (800 bbl)
441
594
0.5
007
17WE1141
Condensate storage (3200 bbl)
6532
6284
353
2983
50680
419
33.6
008
17WE1142
Loadout when LACT not available
31
32
2
16
357
3
0.2
0O,`.
Oa'7?,..c0y d
r':. G,1230, ',i1; ":,. 0,
APEN-Exempt / Insignificants
Heaters (24)
10
0
0
237
0.1
Fugitives
3
11
2
17
46
1
0.0
FACILITY TOTAL
TOTALJtpy)
0.9
0.2
0.1
3.7
3.2
0.2
1.5
26.0
0.1
0.2
0.0
0.0
36.0
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (Ibs Der year
POINT
PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
'>'°"""
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP02
Waukesha F18GSI, sn: C-12669/1
544
74
70
42
81
18
0.4
002
GP02
Waukesha F18GSI, sn: C-10550/1
544
74
70
42
81
18
0.4
003
GP02
Doosan D146L, sn: EEZOG300622
623
85
80
48
93
20
0.5
004
GP02.CAI
CaterpillarG3406TA, sn' 4FO84178
005
GP06
Cummins QSM11-G4 NR3, sn: 3526988
26
153
19
187
0.2
006
GP08
Prod water storage (800 bbl)
9
12
0.0
007
17WE1141
Condensate stora a 3200 bbl
131
126
7
60
1014
8
0.7
008
17WE1142
Loadout when LACT not available
1
1
1
1
7
1
0.0
000
..c..vC:i(E'd
.:::3t' c .k Ga2'30. >, FP -62096
APEN-Exempt / Insignificants
Heaters (24)
10
0
0
237
0.1
Fugitives
3
11
2
17
46
1
0.0
0.0
0.0
0.0
FACILITY TOTAL
TOTALJtpy)
0.9
0,2
0.1
0.2
0.1
0.0
0.0
0.7
0.1
0.0
0.0
0.0
2.3
2
1239F6D.xlsx 2/7/2018
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Company Name: 5RCE)tei
County AIRS ID:
Plant AIRS ID:
Facility Name: 'Qk
Physical Address/Locatic NESE quadrant of Section 36, Township 6N, Range 67W, in Weld County, Colorado
Type of Facility: ≥exploration &" Froduetton WejlFad
What industry segment? O l &cNatural Gas Productt"ona& Processing
Is this facility located in a IIAAQS non -attainment area?
If yes, for what pollutant? Don Monoxide (CO)
Weld
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
NESE
67
iculate Matter (PM) Eno (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit It
Issuance S
Self Cert
Required?
Action
Engineering
Remarks
CGc
�'. ,.
sn, @flS t a k
j1
TNK3 &
, ;... _�
.
"'
7W61141
CPI
Yes
Permltinttial
Issuance
000
H drOl llid
adirt
jD J
p
NCr
iy
" W x42
CPI
Yes ",
1
fssuarit
3 ili33r
". '� ,✓�/, _ -
l tbf ' ....
.,.,
\\
.�.:.
..3.11.lii5 .:'
Section 03 - Description of Project
New synthetic minor E&P-site in ozone non -attainment area.
Project also includes three (3) GP02 registrations for engines, one (1) GP0S registration for produce
generator engm
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting
age tanks and one (1) GP06'
Fa
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required?
If yes, for what pollutants? llil3li311 ; ,,,
If yes, attach a copy of Technical Services Unit modeling results summary.
i
Section 06 - Facility -Wick 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)
Yes
SO2 NOx CO
1
VOC PM2.5
✓
Is this stationary source a major source?
If yes, explain what programs and which pollutants hers SO2 NOx co voc
PM2.5
PM10
PM10
TSP
TSP
HAPs
❑ ❑✓
HAPs
❑ ❑
Hydrocarbon Loadout Emissions Inventory
Section 01- Administrative Information
Facility AIRs ID:
12.3
9060 0
Plant P:
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
EnclOSed eomltoo
98.00
Requested Overall VOC & HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions- Hydrocarbon Loadout
Actual Volume Loaded =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Volume Loaded =
Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = ..:6,44.01 Barrels (bbl) per year
Barrels (bbl) per year
Barrels (bbl) per year
Heat content of waste gas= .. 2755: Btu/sd
Volume of waste gas emitted per year = 165900 scf/yea
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
Does the company use the state default emissions factors to estimate emissions?
Loading Loss Equation
1= 12.46'5'P'M/T
default for DJ Basin
180 MMBTU per year
374 MMBTU per year
374 MMBTU per year
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
<
r,, ,,m�
A9;G1r'°`.`-e5.2:2'Su3xt:.—ernes'z.€s?ai':,rriq,116dlca2cd C(s5,-0.5) ,i,a
P
True Vapor Pressure
6.2 :-..
psia
M
Molecular Weight of Vapors
45.28
Ib/Ib-mol
T
Liquid Temperature
525.67 !
Rankine
L
Loading Losses
3.992585341
lb/1000 gallons
0.167688584 Ib/bbl
Component
Mass
Fraction
Emission Factor
Units
Source
Benzene
,^
0.00154
0.00025824
lb/bbl
ProMax otnpna (W jB'.scream)
Toluene
i„
0.00167
0.000271656
lb/bbl
Ethylbenzene
0000101
,: '.
1.69365E-05
lb/bbl
Xylene
„ ,
'
P 000806 ,..','
0.000135157
lb/bbl
n -Hexane
;0.018 „
0.003018395
lb/bbl
224TMP
0.000146
2.44825E-05
lb/bbl
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(Ib/bbl) (Ib/bbl)
(Volume Loaded)
(Volume
Loaded)
3.35E-03
5.16E-06
5.43E-06
3.39E-07
2.70E-06
6.04E -OS
4.90E-07
VOC
Benzene
Toluene
2.58E-114
2.72E-04
1.69E-55..........
Ethylbenzene
Xylene
.35E-04.,.,.,.
n -Hexane
224 TMP
2.45E-05
Emission Factor Source
Emission Factor Source
Pollutant
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(Ib/bbl)
(Volume
Loaded)
2.36E-05
2.36E -OS
1.86E-06
2.15E-04
9.81E-04
(waste heat combusted)
PM10
PM2.5
0.0075
50x
NOx
CO
0.0006
0.0680....._
0.3100.,,,,,,,,,
2 of 3
K:\PA\2017\17W E1142.CP1.xlsm
Hydrocarbon Loadout Emissions Inventory
Section OS - 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) (tans/year)
PM10
PM2.5
SOx
NOx
VOC
CO
0.00139
0.001
0.001
0.00139
0.00139
0.00139
0.001
0.001
0.00139
0.00139
0.00011
0.0001
0.00
0.00011
0.00011
0.01
0.01
0.01
0.01
0.01
9.91
4.76
0.10
9.91
0.20
0.06
0.03
0.03
0.06
0.06
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
31
15
0
31
1
32
15
0
32
1
2
1
0
2
0
16
8
0
16
0
357
172
3
357
7
3
1
0
3
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
RACT- Regulation 3, Part B, Section III.D.2.a
(See regulatory applicability worksheet for detailed analysis)
The loadout must be operated with submerged fill to satisfy RACT.
Section 07 - Initial and Periodic Sampling and Testing Requirements
r
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
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point ft
008
Process 8
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (3=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
VOC 3.9926 98 lb/1,000 gallons transferred
Benzene 0.0061 98 lb/1,000 gallons transferred
Toluene 0.0065 98 lb/1,000 gallons transferred
Ethylbenzene 0.0004 98 lb/1,000 gallons transferred
Xylene 0.0032 98 lb/1,000 gallons transferred
n -Hexane 0,0719 98 lb/1,000 gallons transferred
224 TMP 0.0006 98 lb/1,000 gallons transferred
3 of 3 K:\PA\2017\17WE1142.CP1.xlsm
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
SRC Energy, Inc.
123
9F6D
Orr State 40-36 Pad
History File Edit Date
Ozone Status
1/1012018
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
POINT
AIRS
ID
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
GP02
Waukesha F18GSI, sn: C-12669/1
0.3
0.3
54.1
7.7
54.1
0.4
0.3
0.3
3.9
2.7
7.7
0.4
new GP02
002
GP02
Waukesha Fl8GSI, sn: C-10550/1
0.3
0.3
54.1
7.7
54.1
0.4
0.3
0.3
3.9
2.7
7.7
0.4
new GP02
003
GP02
Doosan D146L, sn: EEZOG300622
0.3
0.3
30.4
0.5
56.5
0.5
0.3
0.3
0.3
0.2
0.3
0.5
new GP02
004
OP02.CN
Caterpillar G3408TA, sn: 4FD04175
cancelled Jan 2018
005
GP06
Cummins OSM11-G4 NR3, sn: 35269881
0.5
0.5
3.4
10.9
3.8
9.5
0.2
0.5
0.5
3.4
10.9
3.8
9.5
0.2
new GP06
006
GP08
Prod water storage (800 bbl)
6.0
0.5
6.0
0.0
new GP08
007
17WE1141
Condensate storage (3200 bbl)
0.3
0.3
3.0
1,538.3
13.6
33.6
0.3
0.3
3.0
30.8
13.6
0.7
SSEFs accepted; requested 98% control
008
17WE1142
Loadout when LACT riot available
0,0
9.9
0.1
0.2
0.0
0.2
0.1
0.0
008
Canceled
C.aslwA C1J230. so: FP -82083
was XP pilot, cancelled Jar, 2010
APEN-Exempt / Insignificants
Heaters (24)
0.5
0.5
6.6
0.4
5.5
0.1
0.5
0.5
6.6
0.4
5.5
0.1
from Jan 2018 revised application
Fugitives
0.4
0.0
0.4
0.0
from Jan 2018 revised application
FACILITY TOTAL
2.2
2.2
0.0
3.4
159.1
1,574.2
0.4
193.4
36.0
2.2
2.2
0.0
3.4
28.5
46.7
0.4
44.4
2.3
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (PSD and OP)
HAPS: Syn Minor n -hexane and total
HH: Syn Minor + affected Area
7777: Syn Minor
Permitted Facility Total
1.7
1.7
0.0
3.4
152.5
1,573.9
0.0
187.9
35.9
1.7
1.7
0.0
3.4
22.0
46.3
0.0
38.9
2.2
Excludes units exempt from permits/APENs
(4) Change in Permitted Emissions
1.7
1.7
0.0
3.4
22.0
46.3
0.0
38.9
Pubcom required based on new synthetic minor
limits
Note 1
Total VOC Facility Emissions (point and fugitive
(D) Change in Total Permitted VOC emissions (point and fugitive)
47.1
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
46.3
Application received a wholesale revision in January 2018.
Note 2
Page 1 of 2
Printed 2/7/2018
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 9F6D
Facility Name Orr State 40-36 Pad
Emissions - uncontrolled (Ibs per year
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
1140''
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP02
Waukesha F18GSI, sn: C-12669/1
544
74
70
42
81
18
0.4
002
GP02
Waukesha F18GSI, sn: C-10550/1
544
74
70
42
81
18
0.4
003
GP02
Doosan D146L, sn: EEZOG300622
623
65
80
48
93
20
0.5
004
GP02.CN
Caterpillar G3406TA, sir .4FO04178
005
GP06
Cummins QSM11-G4 NR3, sn: 3526988'
26
153
19
187
0.2
006
GP08
Prod water storage (800 bbl)
441
594
0.5
007
17WE1141
Condensate storage (3200 bbl)
6532
6284
353
2983
50680
419
33.6
008
17WE1142
Loadout when LACT not available
31
32
2
16
357
3
0.2
000
Cc:zn &/sd
.i:'36 ... Fe:'-u2Qft3
APEN-Exempt / Insignificants
Heaters (24)
10
C
0
237
0.1
Fugitives
3
11
2
17
46
1
0.0
FACILITY TOTAL
TOTALJtpy)
0.9
0.2
0.1
3.7
3.2
0.2
1.5
26.0
0.1
0.2
0.0
0.0
36.0
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minitnus
Emissions with controls (Ibs per year
POINT
PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
"40°^-
TOTAL (tpy)
Previous
FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP02
Waukesha F18GSI, sn: C-12669/1
544
74
7D
42
81
18
0.4
002
GP02
Waukesha F18GSI, sn: C-10550/1
544
74
70
42
81
18
0.4
003
GP02
Doosan D146L, sn: EEZOG300622
623
85
80
48
93
20
0.5
004
GP02.CN
Cate;piitarG3406TA, Af7: 4FO04 /76
005
GP06
Cummins QSM11-G4 NR3, sn: 3526988
26
153
19
187
0.2
006
GP08
Prod water storage (800 bbl)
9
12
0.0
007
17WE1141
Condensate storage (3200 bbl)
131
126
7
60
1014
8
0.7
008
17WE1142
Loadout when LACT not available
1
1
1
1
7
1
0.0
00O
Ca;acoltee:
:asrucx L,.==28c?. s... , .'-02T96
APEN-Exempt
/ Insignificants
Heaters (24)
10
0
0
237
0.1
Fugitives
3
11
2
17
46
1
0.0
0.0
0.0
0.0
FACILITY
TOTAL
TOTALftpy)
0.9
0.2
0.1
0.2
0.1
0.0
0.0
0.7
0.1
0.0
0.0
0.0
2.3
1239F6D.xlsx 2/7/2018
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE1141
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
SRC Energy, Inc.
Orr State 40-36
123/9F6D
NESE Section 36 T6N R67W
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
007
Eight (8) 400 barrel fixed roof storage
vessels used to store condensate.
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. 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 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
COLORADO
Air Pollution Control Division
:Ua:rir x::t f Public 1e "n u E:vir6rr t t
Page 1 of 8
3. his pert `.ire if $,_ ner o ••.rator o he source for which this permit was issued:
cation operation of this source within 18 months
iss ce • : this const _" ction permit or the date on which such
tion r a•.. it as s ' -dul to comm ce as set forth in the permit application
ociated .. the t; ( • ues co ction 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.)
.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO),
VOC
CO
TNK 1-8
007
---
3.0
30.8
13.7
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
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.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TNK 1-8
007
Enclosed Combustors (Four [4] IES 96")
VOC and HAP
COLORADO
Air Pollution Control Division
or Public I-reri th 6 L-Mr6rrrtertt
Page 2 of 8
8. his so e :ll limit ` e foil; in maxi processing rates as listed below. Monthly
essin ates , all be ma tamed by the owner or operator and made
let Di in .n req Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
TNK 1-8
007
Condensate
throughput
2,363,959 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 with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the endosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
COLORADO
Air Pollution Control Division
DDeparim .:4 or A Health & Environment
Page 3 of 8
or a period of two years, made available to
ust be met within 90 days of the date that
14. ' ragby are su E o 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 (oak) 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 review and approval
at least thirty (30) days prior to testing. No compliance test shall be conducted without prior
approval from the Division. (Regulation Number 3, Part B., Section III.G.3)
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
OLORADO
Air Pollution Control Division
rYrknt Gf tkb U 1-ie&th C, E^:ert'+ert
Page 4 of 8
llutant
or five (5 . ons per year, whichever is less, above the
bmitte °- e Division.
•
• 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
Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission
Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a
source or activity is to be discontinued, the owner must notify the Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
COLORADO
Air Pollution Control Division
artment rubt, ₹t nv Emtrcmnizrt
Page 5 of 8
By:
orcement), -121 (injunctions), -122 (civil
Andy Gruel, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to SRC Energy, Inc.
COLORADO
Air 38o€I�stion Control Division
Notes
1) Th ''ermit ld pis +wired ees f th proce ng time for this permit. An invoice for these
fe b ssu aft;the rrnit.issu h°". The per holder shall pay the invoice within 30 days
o of - vilur .., e invill 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)
007
Benzene
71432
6532
131
Toluene
108883
6284
126
Ethylbenzene
100414
353
7
Xylenes
1330207
2983
60
n -Hexane
110543
50680
1014
2,2,4-
Trimethylpentane
540841
419
8
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 007:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.0025
0.0025
AP -42 Ch. 13-5
CO
0.0115
0.0115
AP -42 Ch. 13-5
VOC
1.30143
0.0260
ProMax model
based on a site -
specific
pressurized
samplec ed
collected
12/21/2017.
71432
Benzene
0.00276
0.0001
108883
Toluene
0.00266
0.0001
100414_
Ethylbenzene
0.00015
0.000003
1330207
Xylene
0.00126
0.00003
110543
n -Hexane
0.02144
0.0004
540841
2,2,4-Trimethylpentane
0.00018
0.000004
COLORADO
Air Pollution Control Division
szD ret�r4t`w%tc hGvmmzrt
Page 7 of 8
sed on the flare control efficiency of 98%. NOx
ontent of 2407.7 Btu/scf.
6) In
t
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 facility is classified as follows:
Emission Notice (APEN) associated with
was received by the Division. A revised
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: NOx, VOC, CO, HAPs (total and n -hexane)
NANSR
Synthetic Minor Source of: NOx, VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control. Division
uv ^.rYt,xent t Yuv _ Iaea f �S E ; �rcrrrr�see.
Page 8 of 8
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE1142
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
SRC Energy, Inc.
Orr State 40-36 Pad
123/9F6D
NESE Section 36 T6N R67W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LDG-1
008
Truck loadout of condensate by
submerged fill.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. 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 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
COLORADO
Mr Pollution Control Division
Department ot. PutAie iealth L' € iroYJ:te=:t
Page 1 of 7
after either, the date of i th date which such
construction or activity wa the• F d t �_ co nc . as se ort v n the per ` t application
associated with this permi , ` 'iscont r co u on • . • - • • of ei • - months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation
Number 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
LDG-1
008
---
---
0.2
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
6. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants Controlled
LDG-1
008
Enclosed Flare
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
008
Condensate Loaded
118,198 barrels
ICOLORADO
Air Pollution Control Division
tor:
Page 2 of 7
The owner or operator shall on x _ ly •cess sed • th calend month.
Compliance with the annua fling t (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity
for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
10. This source is located in an ozone non -attainment or attainment -maintenance area and is subject
to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3,
Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and
emissions shall be controlled by a flare. (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):
a. The owner or operator shall inspect onsite loading equipment during loading operations
to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking,
or other liquid or vapor loss during loading and unloading. The inspections shall occur at
least quarterly. 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.
13. The owner or operator shall:
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
'COLORADO
Air Pollution Control Division
Dep&tnvrtt of Public, i Iccith E.::"varutiei:t
Page 3 of 7
your OOM plan are subject t•ivisio pp a or to.< ' •,enta :fin. (Refers e:
Regulation Number 3, Part B
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. 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)
16. 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 review and approval
at least thirty (30) days prior to testing. No compliance test shall be conducted without prior
approval from the Division. (Regulation Number 3, Part B., Section III.G.3)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or 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
!COLORADO
I Air Pollution Control Division
^apartment is Publ t. Her '.. & Envvenmert
Page 4 of 7
• No later than 30 day
GENERAL TERMS AND CONDITION
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such 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.
By:
Andy Gruel, P.E.
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to SRC Energy, Inc.
COLORADO
Mr Pollution Control Division
`D..>Wr rzd Puhf s_IiGOwn o E,;:von.ner.t
Page 5 of 7
Notes to Permit Holder at the time o
1) The permit holder is required tE • it. An e 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-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
008
Benzene
71432
31
1
Toluene
108883
32
1
Ethylbenzene
100414
2
1
Xylenes
1330207
16
1
n -Hexane
110543
357
7
2,2,4-
Trimethylpentane
540841
3
1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 008:
Pollutant
CAS #
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
N0x
2.15E-04
2.15E-04
AP -42 Ch. 13.5
CO
9.81E-04
9.81E-04
V0C
1.68E-01
3.35E-03
AP -42 Ch.13.5
Benzene
71432
2.58E-04
5.16E-06
Eng. Calc using ProMax
output based on site -
specific sample
Toluene
108883
2.72E-04
5.43E-06
Ethylbenzene
100414
1.69E-05
3.39E-07
Xylene
1330207
1.35E-04
2.70E-06
n -Hexane
110543
3.02E-03
6.04E-05
2,2,4-
Trimethylpentane
540841
2.45E-05
4.90E-07
COLORADO
Air Pollution Control Division
Page 6 of 7
The uncontrolled VOC emission
using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 6.2 psia
M (vapor molecular weight) = 45.28 lb/lb-mot
T (temperature of liquid loaded) = 525.67 °R
(version 1/95)
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the ProMax output ("Working and Breathing" stream) by the
VOC emission factor.
Controlled emission factors are based on a flare efficiency of 98% and a collection efficiency of 100%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, HAPs (n -hexane and total)
NANSR
Synthetic Minor Source of: VOC, NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart 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
3 t•evarttiesecit Public Health is EY:v¢oreherit
Page 7 of 7
44
\620
Condensate Storage Tank(s) APEN X01
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 loadings, 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: 17WE1141
1141
AIRS ID Number: 123 / 9F6D / 007
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': SRC Energy, Inc.
Site Name: Orr State 40-36 Pad
Site Location: NESE Sec. 36 T6N R67W
Mailing Address:
(Include Zip Code) 5400 W. 11th Street, Suite C
Greeley, CO 80634
Site Location
County: Weld
NAICS or SIC Code: 211111
Permit Contact: Brad Rogers
Phone Number: (970) 475-5242
E -Mail Address2: brogers@srcenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
±0 r 0522
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017
. COLORADO
,
p di
Permit Number: 17WE1141
AIRS ID Number: 123 / 9F6Di 007
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
❑� Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
- OR
D MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name
❑ Change permit limit O Transfer of ownership3 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
Additional Info Et 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: 7/29/2017
Normal Hours of Source Operation: 24 hours/day 7 days/week 52
Storage tank(s) located at:
Exploration a Production (EaP) site
weeks/year
O Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
•
Yes
•
No
Are Flash Emissions anticipated from these storage tanks?
i0
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
•
Yes
•
No
If "yes", identify the stock tank gas -to -oil ratio:
0.003
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
•
p
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual•
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
•
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017
2 I AVxuw�•
COLORADO
Permit Number: 17WE1141
1141
AIRS ID Number: 123 / 9F6D/ 007
[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:
1,136,525.7
From what year is the actual annual amount?
2017
Average API gravity of sates oil: 46.9 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
2, 363, 959.0
RVP of sales oil: 9.6
O 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
6/2017
7/2017
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123-43967
Orr State #25N -35B -M
DI
05 - 123-43968
Orr State #25C -35-M
o
05 - 123-43969
Orr State #23N -35C -M
o
05 - 123-43970
Orr State #10N -35A -M
17
05 - 123-43971
Orr State #10C -35-M
o
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EttP 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)
40.442473/-104.834459
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 O Downward
❑ Horizontal O Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
o Other (describe):
O Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017
3 I ®'v COI=
� of Z?
%u:Nb Enwonmv.0
Permit Number: 17WE1141
AIRS ID Number: 123 I 9F6D/ 007
[Leave blank unless APCD has already assigned a permit # 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.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOCs and HAPs
Rating: 261
MMBtu/hr
Type: (4) Enclosed Combustors Make/Model: (4) I ES - 96"
Requested Control Efficiency: 98
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1076 F
Waste Gas Heat Content: 2407.7 Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.06 MMBtu/hr
O Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (EttP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 14 psig
Describe the separation process between the well and the storage tanks:
(12) Horizontal 36" Worthington 3 -phase separators, (12) 24" Leed 3 -phase horizontal
separators, (4) 2 -phase vertical separators, and (2) Worthington 60" gas busters
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 4
COLORADO
KeeMtrEntnmillemeW
Permit Number: 17WE1141
AIRS ID Number: 123 / 9F6D/ 007
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
(
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
ECD
98
NOx
CO
HAPs
ECD
98
Other:
From what year is the following reported actual annual emissions data? 2017
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/ ear
(Tons/year)
Controlled
Emissions 7
(Tons/ ear
(Tons/year)
Uncontrolled
Emissions
Tons/ear
(Tons/year) )
Controlled
Emissions
(Tons/year)
VOC
4.327
lbs/bbl
ProMax
2,458.87
49.18
1,538.27
30.77
NOx
0.068
Ib/MMBtu
AP -42
N/A
4.98
N/A
2.99
CO
0.310
Ib/MMBtu
AP -42
N/A
22.72
N/A
13.64
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service CAS
(CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
g
Uncontrolled
Emissions
Pounds/ year
(Pounds/year) )
Controlled
Emissions7
(Pounds/year)
Benzene
71432
2.76E-03
Ibs/bbl
ProMax
3,136.81
62.74
Toluene
108883
2.66E-03
lbs/bbl
ProMax
3,023.16
60.46
Ethylbenzene
1OO414
1.49E-04
Ibs/bbl
ProMax
169.34
3.39
Xylene
1330207
1.26E -O3
Ibs/bbl
ProMax
1,432.02
28.64
n -Hexane
11O543
2.14E-02
Ibs/bbl
ProMax
24,365.50
487.31
2,2,4-
Trimethylpentane
540841
1.77E -O4
lbs/bbl
ProMax
201.17
4.02
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 02/2017
®V, COLORADO
Permit Number: I7WE 1 141
AIRS ID Number: 123 / 9F6D/ 007
[Leave blank unless APCD has already assigned a permit N 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 operates .4fl$ com fiance with each condition of the applicable General Permit.
1.12.2018
gnature of Legally Authorized Person (not a vendor or consultant) Date
Brad Rogers
Supervisor of Health and Environmental
Name (print)
Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
O Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
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-205 - Condensate Storage Tank(s) APEN - Revision 02/2017
6 1 07
COLORADO
arn.n .a..v
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
SRC Energy, Inc.
Source Name:
Condensate Tanks - Orr State 40-36 Pad
Emissions Source AIRS ID2:
123 / 9F6D / 007
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 -123 - 43972
Orr State # 10N -35C -M
►1
05 -123 - 43973
Orr State # 15N -35B -M
►1
05 -123 - 43974
Orr State # 23C -35-M
/1
05 -123 - 43975
Orr State # 15C -35-M
►1
05 -123 - 43976
Orr State # 36N -35B -M
►/
05 -123 - 43977
Orr State # 36C 35-M
05 -123 - 43978
Orr State # 36N -35C -M
.1
05 -123 - 43979
Orr # 25C -32-M
a
05 -123 - 43980
Orr # 11N -32C -M
/1
05 -123 - 43981
Orr # 11C -32-M
05 -123 - 43982
Orr # 25N -32B -M
//
05 -123 - 43983
Orr # 23C -32-M
/1
05 -123 - 43984
Orr # 11N -32B -M
��
05 -123 - 43985
Orr # 23N -32B -M
A.
05 -123 - 43986
Orr # 14N -32C -M
►/
05 -123 - 43987
Orr # 23N -32A -M
05 -123 - 43988
Orr # 36C -32-M
05 -123 - 43989
Orr # 36N -32B -M
►1
05 -123 - 43990
Orr # 14C -32-M
►1
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
CondAddendum.docx
Hydrocarbon Liquid Loading APEN - Form APCD-208 '.1/1,,_ „
Air Pollutant Emission Notice (APEN) and I Fel,
2
Application for Construction Permit 4,PCoYI18
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if
the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on
the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission -of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 17WE 1142
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: LDG-1
AIRS ID Number: 123 /9F6D / 008
[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. -
Orr State 40-36 Pad
Site Location: NESE Sec. 36 T6N R67W
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.
3 513
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017
1 I AVCOLORADO
i��ltt�6 Env omnnl
Permit Number: 17WE 1142
AIRS ID Number: 123 i9F6D/ 008
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
✓❑ NEW permit OR newly -reported emission source
0 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 ownership' ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
on throughput
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Applying for individual permit to establish enforceable limit
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:
/ /
07/ 29 /2017
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
O Yes ❑ No
❑ Yes 0 No
El Yes 0 No
✓❑ Yes ❑ No
✓❑ Yes ❑ No
❑✓ Yes O No
❑ Yes O No
2 1 AVCOLORADO
iwlhSErtv�ne nt
Permit Number: 17WE1142 AIRS ID Number: 123 /9F6D/ 008
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 2 Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume
Loaded4:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
118,197.95
Bbl/yr
Actual Volume
Loaded:
56,826
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:
0.6
Average temperature
of bulk liquid loading:
66
°F
True Vapor
Pressure
6.2
Psia 60 °F
Molecular weight of
displaced vapors
45.28
Lb/lb-mot
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume
Loaded5:
Bbl/yr
Actual Volume
Loaded:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Product Density: Lb/ft3
Load Line Volume: ft3/truckload Vapor Recovery Line Volume
ft3 /truckload
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
artment
-COLORADO
Faal:h 6 £nuunnmuni
Permit Number: 17WE 1142
AIRS ID Number: 123/9F611008
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.442473/-104.834459
Operator :
Stack ID No.
Discharge Height
t
Above Ground Level
(Feet)
Tem'
p
('F)
Flow Rate
(ACFM)
Velocit `
y
(ft/sec)
Indicate the direction of the stack outlet: (check one)
El Upward
El Horizontal
❑ 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: 261 MMBtu/hr
Type: Enclosed combustor Make/Model: IES — 96" High Efficiency
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
98
98
%
1076 Waste Gas Heat Content 2555 Btu/scf
Constant Pilot Light: ✓❑ Yes ❑ No Pilot burner Rating 0.06 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
CO4OADO
4AVR
nE mm
Permit Number: 17WE1142 AIRS ID Number: 123/9F6D/008
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
PM
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
SOX
NO„
CO
VOC
(4) 96" IES Combustors
98%
HAPs
(4) 96" IES Combustors
98%
Other:
❑ Using State Emission Factors (Required for GP07) VOC
❑ 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? 2017
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source `
(AP -42, `
Mfg. etc)
Actual Annual Emissions .'
-: ,
Requested Annual Permit
s
Emission Ltrtf�s)
{
Uncontrolled
(Tons/year) -
Controlled5
(Tons/year) c'
Uncontrolled
(Tons/year)
, Controlled
(Tons/year),
PM
SOX
NO),
VOC
1.68E-01
Ibsibbl
ProMax
4.76
0.10
9.90
0.20
CO
Benzene
2.58E-04
Ibsibbl
ProMax
7.34E-03
7.34E-03
1.53E-02
3.05E-04
Toluene
2.72E-04
Ibs/bbl
ProMax
7.73E-03
7.73E-03
1.61E-02
3.22E-04
Ethylbenzene
1.70E-05
Ibs/bbl
ProMax
4.83E-04
4.83E-04
1.00E-03
2.01E-05
Xylenes
1.35E-04
Ibsibbl
ProMax
3.84E-03
3.84E-03
7.98E-03
1.60E-04
n -Hexane
3.01E-03
Ibsibbl
ProMax
8.56E-02
8.56E-02
1.78E-01
3.56E-03 ,
2,2,4-
Trimethylpentane
2.44E-05
Ibs/bbl
ProMax
6.94E-04
6.94E-04
1.44E-03
2.88E-05
Other:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
AAnnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
COLORADO
Department al Public_
HaahM'u Enviunmcnl
Permit Number: 17WE1142
AIRS ID Number: 123 /9F6D/ 008
[Leave blank unless APCD has already assigned a permit A' and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will
be operated in full compliance with each condition of the applicable General Permit.
Signature of Legally Authorized Person (not a vendor or consultant)
Brad Rogers
z / 20) Zo t P
D e
Health and Environmental. Supervisor
Name (print) Title
Check the appropriate box to request a copy of the:
❑Q Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $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 �w COLORADO
'P/
Hello