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Home My WebLink About20181288.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 April 18, 2018 Dear Sir or Madam: RECEIVED APR 2 3 2018 WELD COUNTY COMMISSIONERS On April 19, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Aka Energy Group, LLC - Gilcrest Gas Plant. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MPH, Executive Director and Chief Medical Office eu►e,�v lit_ Cz-r) pwCERIcRITnaiccc� t�ubo�.3Q—►� e�.4�ntir�f�p), og oy-23- 2018-1288 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Aka Energy Group, LLC - Gilcrest Gas Plant - Weld County Notice Period Begins: April 19, 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: Aka Energy Group, LLC Facility: Gitcrest Gas Plant Oil Et Gas Sector Natural Gas Processing Plant 13472 Weld County Road 40 Weld County The proposed project or activity is as follows: Addition of new and replacement equipment. (ie. EG Dehy, (3) Generator Engines, 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): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 07WE0881 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Timothy Sharp 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 Department of Public Health Environment Air Pollution Control Division Summary of Preliminary Analysis - Fugitive Components Source Company Name Facility Name Permit No AIRS Permit Engineer Application Date Review Date Aka Energy Group, LLC Gilcrest Gas Plant 07WE0881 123/0098/014 Timothy Sharp 8/31/2017 9/21/2017 Summary of Emissions VOC (tpy) Benzene (Ib/yr) Toluene (lb/yr) Ethylbenzne (lb/yr) Xylenes (lb/yr) n -Hexane (Ib/yr) Uncontrolled Requested Emissions 30.6 584 637 26 255 3,292 Controlled Requested Emissions 12.5 250 278 11 106 1,444 Reportable? I I Yes Yes No Yes Yes Total HAP, Uncontrolled (tpy) 2A Total HAP, Controlled (tpy) I 1.0 Highest HAP, Uncontrolled (tpy) 1.6 n -Hexane Emission Factors Emission Factor Source: Controls Stream VOC Fraction: Gas 0.2500 Light Oil 1.0000 Heavy Oil 1.0000 Water/Oil 1.0000 Comments/Notes: EPA -453/R-95-017, Table 2-4 Control Efficiencies from Table 5-3, quarterly monitoring (EPA -453/R-95-017) Stream HAP Components (wt frac HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.0020 0.0170 0.0170 0.0170 Toluene 0.0020 0.0220 0.0220 0.0220 Ethylbenze 0.0001 0.0005 0.0010 0.0010 Xylene 0.0010 0.0050 0.0050 0.0050 n -Hexane 0.0100 0.1200 0.1200 0.1200 Printed 4/17/2018 Page 1 or 1 Colorado Department of Public Health Environment Air Pollution Control Division Summary of Preliminary Analysis - Fugitive Components Source Company Name Facility Name Permit No AIRS Permit Engineer Application Date Review Date Aka Energy Group, LLC Gilcrest Gas Plant 07WE0881 123/0098/026 Timothy Sharp 8/31/2017 9/21/2017 Summary of Emissions VOC (tpy) Benzene (lb/yr) Toluene (lb/yr) Ethylbenzne (lb/yr) Xylenes (Ib/yr) n -Hexane (lb/yr) Uncontrolled Requested Emissions 8.4 65 69 3 29 354 Controlled Requested Emissions 0.8 5 5 0 2 28 Reportable? I I No No No No Yes Total HAP, Uncontrolled (tpy) 0.3 Total HAP, Controlled (tpy) I 0.0 Highest HAP, Uncontrolled (tpy) 0.2 n -Hexane Emission Factors Emission Factor Source: Controls Stream VOC Fraction: Gas 0.2500 Light Oil 1.0000 Heavy Oil 1.0000 Water/Oil 1.0000 Comments/Notes: EPA -453/R-95-017, Table 2-4 Control Efficiencies from Table 5-3, quarterly monitoring (EPA -453/R-95-017) Stream HAP Components (wt frac HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.0020 O.0170 0.0170 0.0170 Toluene 0.0020 0.0220 0.0220 0.0220 Ethylbenze 0.0001 0.0005 0.0010 0.0010 Xylene 0.0010 0.0050 0.0050 0.0050 n -Hexane 0.0100 0.1200 0.1200 0.1200 Printed 4/17/2018 Page 1 or 1 Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID Aka Energy Group, LLC Gilcrest Gas Plant 13472 Weld county Rd. 40 G-1 Permit No. AIRS Review Date Permit Engineer 07WE0881 123/0098/034 02/08/2018 Timothy Sharp Requested Action Issuance No. New permit/newly reported emission 3 Emission Point Description One (1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 2088 horsepower. This engine shall be equipped with an oxidation catalyst and air - fuel ratio control Electricity generation Natural Gas Consumption Requested (mmscf/yr) 93.36 Requested (mmscf/m) 7.93 Fuel Heat Value (btu/scf) 905 BSCF (Btu/hp-hr) 6929 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 5840 Uncontrolled Controlled NOx Manufacturer -- VOC Manufacturer/AP-42 -- CO Manufacturer — Formaldehyde Manufacurer -- SOX AP -42; Table 3.2-2(7/2000); Natural Gas No Control TSP AP -42; Table 3.2-2 (7/2000); Natural Gas No Control PM10 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control Other Pollutants Point Summary of Criteria Emissions (tpy) Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 6.7 6.7 10.1 0.0% VOC 14.7 3.7 22.0 75.0% CO 30.9 7.7 46.4 75.0% SOx 0.0 0.0 0.0 0.0% TSP 0.4 0.4 0.6 0.0% PM10 0.4 0.4 0.6 0.0% PM2.5 0.4 0.4 0.6 0.0% Total HAPs* 8.1 2.2 12.5 71.1% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants (lb/yr HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 14248 3562 21372 75.0% Toluene 726 363 1089 50.0% Acetaldehyde 706 353 1060 50.0% Acrolein 434 217 651 50.0% Methanol * 317 50.0% Benzene * * 210 50.0% n -Hexane * * - 141 50.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ #VALUE! Reg 7 XVILE Standards (g/hp-hr) NOx: NA CO: NA _ VOC: NA Reg 7 XVI.B (Ozone NAA requirements) applies? Yes MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area source requirements? Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes points 034, 037, 038 refer to the installation of 3 generator engines any two of which will be opperating at any single time. For example, while one is having maintenance the other two will be running. Thus, the hourly limits will be reduced for each Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 9: Received Date: Review Start Date: 36851 8/31/2017:" 9/21{2017 Section 01- Facility Information Company Name: .AKAEEnecgy.Group, 10 County AIRS ID: 123 Plant AIRS ID: :Q094, Facility Name: G€Lrest Gas Plant; Physical Address/Locatio 13472 Weld County Road 40 Type of Facility: ��ax'raccssfri�Rja�� What industry segment?'dit &Na€ural-as Prodaction & Processing-- --. Is thisfacility located in a NAAQS non -attainment area? If yes, for what pollutant? [ arbon Monoxide (CO) Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range [articulate Matter (PM) zone (NOx & VOC) AIRS Point tl Emissions Source Type Equipment Name Emissions Control? Permit U Issuance a Self Cert Required? Action Engineering Remarks 036 > •\'..,%, 6Yel yetratpt EG , I' � � Ye'> : .., 07W90881 3 �l .. s , Perrtti� _.., tu[odificatiart new point ta.:.._ facility -wide ,: Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? p g y tf tjct (npr'P Section 05 -Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No _= --- -.- r :• If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx ❑ ❑ CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ U ❑ Is this stationary source a major source? IjoW Pf- .t If yes, explain what programs and which pollutants here SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ O ❑ ❑ ❑ ❑ ❑ Non -Attainment New Source Review (NANSR) ❑ ❑ Glycol Dehydrator Emissions Inventory Section 01- Administrative Information (Facility AIRs ID: Cou 0045 Plant :35 Poin Section 02- Equipment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number: Design Capacity: Recirculation Pump Information Number of Pumps Pump Type Make: Model: Design/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboiler Bumer Stripping Gas Dehydrator Equipment Description MMscf/day flash tank, and reboler burner One (1) Ethylene Glycol (EG) natural gas dehydration unit (Make:, Model:, Serial Number: ) with a design capacity of 20 MMscf per day. This emissions unit is equipped with 2 (Make:, Model: ( electric driven glycol pump with a design capacity of it gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and reboiler burner. Emissions from the still vent are routed to an air-cooled condenser, and then to the Thermal Oxidizer. Emissions from the Emission Control Device Description: flash tank are routed directly to the Thermal Oxidizer. Section 03 - Processing Rate Information for EmissionsEstimates Primary Emissions - Dehydrator Still Vent and Flash Tank (If present) Requested Permit Limit Throughput= l x7;300.0:-.MMsof per year Potential to Emit (PTE) Throughput = 7,300 MMscf per year Secondary Emissions- Combustion Device(s) for Air Pollution Control Still Vent Control Condenser: Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Still Vent Gas Heating Value: Still Vent Waste Gas Vent Rate: Flash tank Control Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flash Tank Waste Gas Vent Rate: Control Efficiency % Control Efficiency % Wet Gas Processed: Still Vent Primary Control: 7,300.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 0.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Wet Gas Processed: Flash Tank Primary Control: 0.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 0.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Glycol Dehydrator Emissions Inventory Section 04- Emissions Factors & Methodologies Dehydrator Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate psig deg F gpm STILLVENT Control Scenario Primary Secondary Pollutant Uncontrolled (Ib/hr) Controlled (lb/hr) Controlled ills/hr) VOC „„ .3.1(05 3( 0.15552 0 Benzene .. 0.435a - 0.023755 0 Toluene "0;6885 - 0.004415 0 Ethylbenzene 0..0403' - 0.000165 0 Xylenes 'p' t7,f799G f:& 0.00298 0 n -Hexane fl:04S7- 0.002485 0 224-TMP 0,00AL19illi - 0.000000 0 FLASH TANK Control Scenario Primary Secondary Pollutant Uncontrolled (Ib/hr) Controlled (Ib/hr) Controlled (Ib/hr) VOC 3iyl 1.4477 1.4477 1.4477 Benzene -`,0.0014 0.0014 0.0014 Toluene __ .0.0001+. 0.0001 0.0001 Ethylbenzene 0,0005 0.0001 0.0001 Xylenes 0.E f? 01 0.0001 0.0001 n -Hexane 0.0037 0.0037 0.0037 224-TMP 0,0001 0.0001 0.0001 Emission Factors Glycol Dehydrator Pollutant Uncontrolled (Ib/MMscf) (Wet Gas Throughput) Controlled (Ib/MMscf) (Wet Gas Throughput) VOC 5.47 0.19 Benzene 0.5718 Toluene 0.10608 0.023506 0.005298. 0.000198 0.003576 0.002982 Ethylbenzene 0.00408 Uylene 0.07164 n -Hexane 0.06408 224 TMP 0.00024 6E-06 Pollutant Still Vent Primary Control Device Emission Faster Source Uncontrolled Uncontrolled (1b/MMetu) (Ib/Nivlscf( (Waste Heat (Waste Gas Combusted) Combusted) PM10 0.0000 PM2.5 0.0000 SOx 0.0000 NOx 0.063tl 0.0000 CO 0.3T00 0.0000 Emission Factor Source Pollutant Still Vent Secondary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) (Waste Heat (Waste Gas Combusted( Combusted) PM10 PM2.5 0.0000 0.0000 505 0.0000 NOx 'i 0.0000 CO 0.0000 Emission Factor Source Pollutant Flash Tank Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu( (Ib/MMscf( (Waste Heat (Waste Gas Combusted) Combusted) PM10 0.0000 0.0100 0.0000 0.0000 0.0000 NOx CO Emission Facbr Source Pollutant Flash Tank Secondary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) (Waste Heat (Waste Gas Comhusted( Combusted) PM10 PM2.5 0.0000 0.0000 0.0000 0.0000 0.0000 SOx NOx CO Glycol Dehydrator Emissions Inventory Section 05 - Emissions Inventory Did operator request a buffer? Requested Buffer (%): Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Unfits Uncontrolled Controlled (tons/year) (tons/year) PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 sox 0.0 0.0 0.0 0.0 0.0 NOx 0.0 0.0 0.0 0.0 0.0 CO 0.0 - 0.0 0.0 0.0 0.0 VOC 20.0 20.0 0.7 20.0 0.7 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (lbs/year) (lbs/year) (Ibs/year) Benzene 4174 4174 208 4174 208 Toluene 774 774 39 774 39 Ethylbenzene 30 30 1 30 1 Xylene 523 523 26 523 26 n -Hexane 468 468 22 468 22 224 TMP 2 2 0 2 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B,D Regulation 7, 'action XVII.B.2.e Regulation 7, Section XII.H Regulation 8, Part E, MACE Subpart HA (Area) Regulation 8, Part E, MACE Subpart HH (Major) Regulation 6, Part E, MACT Subpart HHH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Dehydrator is not subject to Regulation 7, Section XVII.B, D.3 The control device for this dehydrator Is not subject to Regulation 7, Section XVII.R.2. Dehydrator is subject to Regulation 7, Section XII.H Deity Is not subject to MACT HH - Only TEG dehydrators have area -source requiremen you have Indicated that this facility Is not subject no Major Source requirements of MI You have indicated that this facility is not subject to MAR HHH. Section 07 - Initial and Periodic Sampling and Testing Requirements Was the extended wet gas sample used In the GFyCalc model/Process model site -specific and collected within a year of application submittal? ,Vaa If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits Does the company request a control device effidency greater than 95%for a flare or combustion device? lYo 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 09 - Ina/enter, SCC Coding and Emissions Factors AIRS Point P Process ll SCC Cade 035 01 PM10 PM2.5 500 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Pollutant Emissions Factor Control % 0.000 0.0 0.000 0.0 0.000 0.0 0.000 0.0 5.5 96.6 0.000 0.0 0.572 95,0 0.106 95.0 0.004 95.1 0.072 95.0 0.064 95.3 0.000 97.5 Units b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMsd Colorado Department of Public Health Environment Air Pollution Control Division Summary of Preliminary Analysis - Fugitive Components Source Company Name Facility Name Permit No AIRS Permit Engineer Application Date Review Date Aka Energy Group, LLC Gilcrest Gas Plant 07WE0881 123/0098/036 Timothy Sharp 8/31/2017 9/21/2017 Summary of Emissions VOC (tpy) Benzene (Ib/yr) Toluene (lb/yr) Ethylbenzne (Ib/yr) Xylenes (Ib/yr) n -Hexane (Ib/yr) Uncontrolled Requested Emissions 25.3 480 522 21 211 2,697 Controlled Requested Emissions 2.7 54 61 2 23 318 Reportable? I I Yes Yes No No Yes Total HAP, Uncontrolled (tpy) 2.0 Total HAP, Controlled (tpy) 0.2 Highest HAP, Uncontrolled (tpy) 1.3 n -Hexane Emission Factors Emission Factor Source: Controls Stream VOC Fraction: Gas 0.2500 Light Oil 1.0000 Heavy Oil 1.0000 Water/Oil 1.0000 Comments/Notes: EPA -453/R-95-017, Table 2-4 Control Efficiencies from Table 5-3, quarterly monitoring (EPA -453/R-95-017) Stream HAP Components (wt frac HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.0020 0.0170 0.0170 0.0170 Toluene 0.0020 0.0220 0.0220 0.0220 Ethylbenze 0.0001 0.0005 0.0010 0.0010 Xylene 0.0010 0.0050 0.0050 0.0050 n -Hexane 0.0100 0.1200 0.1200 0.1200 Printed 4/17/2018 Page 1 or 1 Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID Aka Energy Group, LLC Gicrest Gas Plant 13472 Weld county Rd. 40 G-2 Permit No. AIRS Review Date Permit Engineer 07WE0881 123/0098/037 02/08/2018 Timothy Sharp Requested Action Issuance No. New permit/newly reported emission 3 Emission Point Description One (1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 2088 horsepower. This engine shall be equipped with an oxidation catalyst and air - fuel ratio control Electricity generation Natural Gas Consumption Requested (mmscf/yr) 93.36 Requested (mmscf/m) 7.93 Fuel Heat Value (btu/scf) 905 BSCF (Btu/hp-hr) 6929 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 5840 Uncontrolled Controlled NOx Manufacturer — VOC Manufacturer/AP-42 — CO Manufacturer — Formaldehyde Manufacurer — SOX AP -42; Table 3.2-2 (7/2000); Natural Gas No Control TSP AF -42; Table 3.2-2 (7/2000); Natural Gas No Control PM10 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control Other Pollutants Point Summary of Criteria Emissions (t Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 6.7 6.7 10.1 0.0% VOC 14.7 3.7 22.0 75.0% CO 30.9 7.7 46.4 75.0% SOX 0.0 0.0 0.0 0.0% TSP 0.4 0.4 0.6 0.0% PM10 0.4 0.4 0.6 0.0% PM2.5 0.4 0.4 0.6 0.0% Total HAPs* 8.1 2.2 12.5 71.1% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants (lb/yr) HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 14248 3562 21372 75.0% Toluene 726 363 1089 50.0% Acetaldehyde 706 353 1060 50.0% Acrolein 434 217 651 50.0% Methanol * * 317 50.0% Benzene * * 210 50.0% n -Hexane * * 141 50.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT 777Z #VALUE! Reg 7 XVII.E Standards (g/hp-hr) NOx: NA CO: NA VOC: NA Reg 7 XVI.B (Ozone NAA requirements) applies? Yes MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area source requirements? Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes points 034, 037, 038 refer to the installation of 3 generator engines any two of which will be opperating at any single time. For example, while one is having maintenance the other two will be running. Thus, the hourly limits will be reduced for each Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID Aka Energy Group, LLC Gilcrest Gas Plant 13472 Weld county Rd. 40 G-3 Permit No. AIRS Review Date Permit Engineer 07WE0881 123/0098/038 02/08/2018 Timothy Sharp Requested Action Issuance No. New permit/newly reported emission 3 Emission Point Description One (1) Caterpillar, Model G3516C, Serial Number To Be Determined, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 2088 horsepower. This engine shall be equipped with an oxidation catalyst and air - fuel ratio control Electricity generation Natural Gas Consumption Requested (mmscf/yr) 93.36 Requested (mmscf/m) 7.93 Fuel Heat Value (btu/scf) 905 BSCF (Btu/hp-hr) 6929 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 5840 Uncontrolled Controlled NOx Manufacturer -- VOC - Manufacturer/AP-42 -- CO Manufacturer — Formaldehyde Manufacurer -- SOX AP -42; Table 3.2-2 (7/2000); Natural Gas No Control TSP AP -42; Table 3.2-2 (7/2000); Natural Gas No Control PM10 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control Other Pollutants Point Summary of Criteria Emissions (t Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 6.7 6.7 10.1 0.0% VOC 14.7 3.7 22.0 75.0% CO 30.9 7.7 46.4 75.0%. SOx 0.0 0.0 0.0 0.0% TSP 0.4 0.4 0.6 0.0% PM10 0.4 0.4 0.6 0.0% PM2.5 0.4 0.4 0.6 0.0% Total HAPs* 8.1 2.2 12.5 71.1% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants (lb/yr HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 14248 3562 21372 75.0% Toluene 726 363 1089 50.0% Acetaldehyde 706 353 1060 50.0% Acrolein 434 217 651 50.0% Methanol * 317 50.0% Benzene * * 210 50.0% n -Hexane. * * 141 50.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ #VALUE! Reg 7 XVII.E Standards (g/hp-hr) NOx: NA CO: NA VOC: NA Reg 7 XVI.B (Ozone NAA requirements) applies? Yes MACT ZZZZ (area source) Is this engine subject to MACT 7777 area Yes source requirements? NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes points 034, 037, 038 refer to the installation of 3 generator engines any two of which will be opperating at any single time. For example, while one is having maintenance the other two will be running. Thus, the hourly limits will be reduced for each Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health £r Environment CONSTRUCTION PERMIT 07WE0881 Draft Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 3 Aka Energy Group, LLC Gilcrest Gas Plant 123/0098 13472 Weld County Road 40 Weld County Natural Gas Processing Plant Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Description C-1 001 One (1) Caterpillar, Model G3516LE, Serial Number WPW01963, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 1297 horsepower at 1400 RPM. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural gas compression. C-6 002 One (1) Waukesha Model F1197G, Serial Number 87655, natural gas -fired, four-cycle standard rich -burn reciprocating internal combustion engine, site rated at 166 horsepower. This engine is equipped with an air -fuel ratio controller and a Non -Selective Catalytic Reduction (NSCR) system for the control of NOx, CO and VOC. This emission unit powers a natural gas compressor. C-7 003 One (1) Waukesha Model F1197G, Serial Number 1060271, natural gas -fired, four-cycle standard rich -burn reciprocating internal combustion engine, site rated at 166 horsepower. This engine is equipped with an air -fuel ratio controller and a Non -Selective Catalytic Reduction (NSCR) system for the control of NOx, CO and VOC. This emission unit powers a natural gas compressor. COLORADO Air Pollution Control Division 3xuGk Me<:.kisv Lrtrromert Page 1 of 33 Facility Equipment ID AIRS Point Description C-3 005 One (1) White -Superior, Model 8G825, Serial Number 20220, natural gas -fired, four-cycle standard rich -burn reciprocating internal combustion engine, site rated at 708 horsepower. This engine is equipped with an air -fuel ratio controller and a Non -Selective Catalytic Reduction (NSCR) system for the control of NOx and CO and VOC. This emission unit is used for natural gas compression. This emission unit may be used interchangeably with point 033 and emission limits contained in this permit are combined for these points. C-4 007 One (1) Waukesha, Model L5790GSI, Serial Number C13524/1, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 1215 horsepower at 1200 RPM. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. V-50 010 VOC emissions from plant blowdown vent C-2 011 One (1) Waukesha, Model L7044GSI, Serial Number C- 14656/1, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. LEAKS (KKK) 014 Fugitive emissions from equipment leaks from existing emission components subject to NSPS subpart KKK. C-5 016 One (1) Waukesha, Model L5790GSI, Serial Number C13525/1, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 1215 horsepower at 1200 RPM. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. LOADOUT 022 Truck loadout of condensate. Emissions from the loadout are uncontrolled and are routed to the plant vent. LEAKS (OOOO) 026 Fugitive emissions from equipment leaks subject to NSPS subpart OOOO. COLORADO Air Pollution Control Division 3 r„„rl3't�rat �t Y.uta7w Hcttg+ 6 Envimre tort Page 2 of 33 Facility Equipment ID AIRS Point Description C-3 033 One (1) Caterpillar, Model G3508B, Serial Number TBD, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 690 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control This emission unit is used for natural gas compression. This emission unit may be used interchangeably with point 005 and emission limits contained in this permit are combined for these points. LEAKS (0000a) 036 Fugitive emissions from equipment leaks subject to NSPS subpart OOOOa. EG 035 One (1) Ethylene Glycol (EG) natural gas dehydration unit (Make: TBD , Serial Number:TBD ) with a design capacity of 20 MMscf per day. This emissions unit is equipped with one (1) (Make: TBD, Model: TBD) electric driven glycol pump and one (1) backup pump with a design capacity of 10 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and reboiler burner. Emissions from the still vent are routed to an air-cooled condenser, and then to the Thermal Oxidizer. Emissions from the flash tank are routed directly to the Thermal Oxidizer. G-1 034 Three (3) Caterpillar, Model G3516C, Serial Number: TBD, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 2088 horsepower each. These engines shall be equipped with oxidation catalysts and air -fuel ratio controllers. These emission units are used for electricity generation. Emission limits contained in this permit are combined for these points. G-2 037 G-3 038 Points 001, 002, 003, 005, 007, 011, 016, 033, 034, 037, 038: These engines may be replaced with another engine in accordance with the temporary engine replacement provision or with another an engine of the same make and model specified for each point in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. COLORADO AirPatiutian Control Division neputr-ent eit C'whor lent: Page 3 of 33 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 after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. Point 035: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of permit. • Manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. Points 033, 034, 037, 038: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of permit. • manufacture date • construction date • order date • date of relocation into Colorado • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 7. 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. COLORADO Mr Pollution Control Division d PUl)ft 64,E J L."i4Y��+iil'3Y2fl Page 4 of 33 EMISSION LIMITATIONS AND RECORDS 8. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type SOX H2S NOX VOC CO C-3 005 --- --- 1156 476 2328 Point 033 Point LOADOUT 022 --- --- --- 1003 --- Point EG 035 --- --- --- 170 --- Point G-1 034 --- --- 3431 1868 3941 Point G-2 037 -- --- G-3 038 --- --- (Note: Monthly limits are based on a 31 -day month) The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,631 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 4077 lb/month. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type SOX H2S NOX VOC CO C-1 001 --- --- 18.8 1.9 1.7 Point C-6 002 --- --- 2.4 0.2 1.6 Point C-7 003 --- --- 2.4 0.2 1.6 Point C-3 005 6.8 2.8 13.7 Point C-3 033 Point C-4 007 --- --- 8.2 4.7 11.7 Point V-50 010 --- --- --- 5.3 --- Point C-2 011 --- - - 16.2 4.1 16.2 Point LEAKS (KKK) 014 --- --- --- 14.5 --- Fugitive C-5 016 --- --- 8.2 4.7 11.7 Point LOADOUT 022 --- -- --- 5.9 --- Point LEAKS (OOOO) 026 --- --- --- 0.8 --- Fugitive COLORADO Air Pollution Control Division t>66,3im6nt of Putt': He Yh 6 E--'irurx?tzr, Page 5 of 33 EG 035 --- --- --- 1.0 --- Point LEAKS (OOOOa) 036 --- --- --- 2.9 --- Fugitive G-1 034 --- - --- 20.2 11.0 23.2 Point G-2 037 --- --- G-3 038 --- --- See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Limits listed above for AIRS Point 005 & 033 apply to the summation of emissions from both points Facility -wide emissions of each individual hazardous air pollutant shall be less than 9.6 tons per year (tpy). Facility -wide emissions of total hazardous air pollutants shall be less than 24.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 9. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) . E. ) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than: • 100 tons per year of NOx; and • 25 tons per year of total hazardous air pollutants (HAP) 10. Point 035: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into GRI GlyCalc and be provided to the Division upon request. COLORADO Air Pollution Control. Division �?z'1) r^.:t ut. £'uiy7 Heca:s v.7 ,^rn�rt�ies, Page 6 of 33 11. Points 005, 033, 034, 037, 038: Compliance with the emission limits in this permit shall be demonstrated using the emission factors in the "notes to permit holder". Emissions shall be calculated for each engine based on their respective emission factors, manufacturer -provided fuel consumption and actual hours of operation. The total combined emissions from both engines shall be used to demonstrate compliance with the limits in this permit. 12. Points 014, 026, 036: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. 13. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled C-1 001 Oxidation catalyst and air/fuel ratio controller VOC, CO and HAPS C-6 002 Non -Selective Catalytic Reduction (NSCR) and air/fuel ratio controller NOx, VOC, CO and HAPS C-7 003 Non -Selective Catalytic Reduction (NSCR) and air/fuel ratio controller NOx, VOC, CO and HAPS C-3 005 Non -Selective Catalytic Reduction (NSCR) and air/fuel ratio controller NOx, VOC, CO and HAPS C-4 007 Non -Selective Catalytic Reduction (NSCR) and air/fuel ratio controller NOx, VOC, CO and HAPS C-2 011 Non -Selective Catalytic Reduction (NSCR) and air/fuel ratio controller NOx, VOC, CO and HAPS LEAKS (KKK) 014 LDAR VOC, HAPS C-5 016 Non -Selective Catalytic Reduction (NSCR) and air/fuel ratio controller NOx, VOC, CO and HAPS LEAKS (0000) 026 LDAR VOC, HAPS C-3 033 Oxidation Catalyst V0C, CO and HAPS DENY 035 Flash Tank: Thermal Oxidizer VOC, HAPS Still Vent: Routed to a condenser and Thermal Oxidizer LEAKS (0000a) 036 LDAR VOC, HAPS G-1 034 Oxidation Catalyst and air/fuel ratio controller VOC, CO, HAPs G-2 037 Oxidation Catalyst and air/fuel ratio controller VOC, CO, HAPs G-3 038 Oxidation Catalyst and air/fuel ratio controller VOC, CO, HAPs COLORADO Mr Pollution Control Division ,`<Tp(erti ter RilaS�:. hn'v Eraronment Page 7 of 33 PROCESS LIMITATIONS AND RECORDS 14. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) C-1 001 Consumption of natural gas as a fuel 86.3 MMscf/yr ___ C-6 002 Consumption of natural gas as a fuel 13.1 MMscf/yr --- C-7 003 Consumption of natural gas as a fuel 13.1 MMscf/yr --- C-3 005 Consumption of natural gas as a fuel 49.7 4.3 C-3 033 MMscf/yr MMscf/month C-4 007 Consumption of natural gas as a fuel 85.1 MMscf/yr --- V-50 010 Total volume of residue gas vented due to maintenance activities 3.5 MMscf/yr C-2 011 Consumption of natural gas as a fuel 112.6 MMscf/yr --- C-5 016 Consumption of natural gas as a fuel 85.1 MMscf/yr 5LOADOUT 4247 022 Condensate Loading BBL/yr BBL/month EG 035 Natural gas throughput 7,300.0 MMscf/yr 620 MMscf/month G-1 034 G-2 037 Consumption of natural gas as a fuel 280.1 MMscf/yr 23.8 MMscf/month G-3 038 The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate COLORADO Air Pollution Control. Division Page 8 of 33 throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 15. Points 005, 033: Compliance with the process limits in this permit shall be demonstrated using the manufacturer -provided fuel consumption and actual hours of operation for each engine respectively. The total combined fuel consumption for both engines shall be used to demonstrate compliance with the limits in this permit. 16. Points 034, 037, 038: Compliance with the process limits in this permit shall be demonstrated using the manufacturer -provided fuel consumption and actual hours of operation for each engine respectively. The total combined fuel consumption for all three engines shall be used to demonstrate compliance with the limits in this permit. 17. Point 035: This unit shall be limited to the maximum lean glycol circulation rate of 10 gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. (Reference: Regulation Number 3, Part B, II.A.4) 18. Point 035: On a weekly basis, the owner or operator shall monitor and record operational values including: chiller temperature and pressure, flash tank temperature and pressure, wet gas inlet temperature and pressure. These records shall be maintained for a period of five years. STATE AND FEDERAL REGULATORY REQUIREMENTS 19. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 20. Points 001, 002, 003, 005, 007, 010, 011, 014, 016, 022, 026, 033, 034,035, 036, 037, 038: Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. It 4.) 21. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) Specific Requirements for Natural Gas -Fired Engines (Points 001, 002, 003, 005, 007, 011, 016, 033, 034, 037, 038) 22. Points 001,033, 034, 037, 038: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. 23. Points 005, 007, 011, 016: This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. COLORADO Mr Pollution Control Division W,.le Page 9 of 33 7, Section XVI.B.1. For rich burn reciprocating internal combustion engines, a non- selective catalyst reduction system and an air fuel controller shall be required. 24. Points 001, 005, 007, 011 016: This equipment is subject to the requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E.3 (State only enforceable). Any lean or rich burn reciprocating internal combustion engine constructed or modified before February 1, 2009 with a manufacturer's name plate design rate greater than 500 horsepower shall install and operate both a non -selective catalyst reduction and an air fuel controller or an oxidation catalyst by July 1, 2010. The operator shall operate and maintain the air pollution control equipment to manufacturer specifications or equivalent to the extent practicable and shall keep manufacturer specifications or equivalent on file. Records of maintenance shall be kept on site or at a local field office with site responsibility, for Division review. Please note that replacements of this engine in accordance with the AOS in Attachment A may be subject to this or other requirements in Regulation 7, Section XVII.E. 25. Points 001, 005, 007, 011 016, 033, 034, 037, 038: This equipment may be subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ≥500HP July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 Note: Per Regulation No. 7, Section XVII.B.4, internal combustion engines that are subject to an emission standard or an emissions control requirement in a federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Best Available Control Technology ("BACT") limit, or a New Source Performance Standard under 40 CFR Part 60 are not subject to this Section XVII. Specific Requirements for the Plant Blowdown Vent (Point 0101 26. The permittee shall record each time the plant blowdown vent is used. The permittee shall record the start and finish time of each such event. COLORADO Air Pollution Control Division Page 10 of 33 27. The permittee shall calculate the volume of gas released from each event. The permittee shall record such parameters necessary to calculate the volume of gas released such as pressure and pipeline dimensions. The calculations determining the volume from each release shall clearly show the methodology to estimate the volume of gas vented and shall be made available to the Division upon request. 28. The permittee shall calculate the VOC emissions from each event using the volume of gas calculated and the most recent representative gas analysis as required by this permit. VOC emissions from each event shall be summed to obtain monthly emissions from venting. Monthly emissions shall be used in a rolling twelve month total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants (Points 014, 026 and 036): 29. This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 30. Point 014: This source is subject to Regulation No. 7, Section XII.G.1 (State only enforceable). For fugitive VOC emissions from leaking equipment, the leak detection and repair (LDAR) program as provided at 40 C.F.R. Part 60, Subpart KKK (see Regulation Number 6, Part A, Subpart KKK) shall apply, regardless of the date of construction of the affected facility. The operator shall comply with all applicable requirements of Section XII. 31. Point 014, 026: This source is subject to Regulation No. 7, Section XII.G.1 (State only enforceable). To comply with Regulation No. 7, Section XII.G.1, the source shall follow the leak detection and repair (LDAR) program as provided at 40 C.F.R. Part 60, Subpart OOOO in lieu of following 40 C.F.R. Part 60, Subpart KKK. 32. Point 014, 026: The fugitive emissions addressed by AIRS ID 026 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution including, but not limited to, the following: • §60.5365 Applicability - The group of all equipment, except compressors, within a process unit for which you commence construction, modification or reconstruction after August 23, 2011 is an affected facility per §60.5365(f). • §60.5400 Standards - The group of all equipment, except compressors, within a process unit must comply with the requirements of §60.5400 and §60.5401. • §60.5410 - Owner or operator must demonstrate initial compliance with the standards using the requirements in §60.5410(f). • § 60.5415 - Owner or operator must demonstrate continuous compliance with the standards using the requirements in §60.5415(f). • § 60.5421 - Owner or operator must comply with the recordkeeping requirements of §60.5421(b). COLORADO AirPoilution Control Division De(xrtirke tI iet itn Cr Environment Page 11 of 33 • S 60.5422 - Owner or operator must comply with the reporting requirements of paragraphs (b) and (c) of this section in addition to the requirements of S 60.487a(a), (b), (c)(2)(i) through (iv), and (c)(2)(vii) through (viii). 33. Point 036: This source is subject to Regulation No. 7, Section XII.G.1 (State only enforceable). To comply with Regulation No. 7, Section XII.G.1, the source shall follow the leak detection and repair (LDAR) program as provided at 40 C.F.R. Part 60, Subpart OOOOa in lieu of following 40 C.F.R. Part 60, Subpart KKK. Specific Requirements for the Truck Loadout (Point 022) 34. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 35. 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.E): a. Hoses, couplings,.and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches {including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations to ensure compliance with the conditions above. The inspections shall occur for each loading session but no more frequently than once every 14 days. Each inspection shall be documented in a log available to the Division on request. d. Loading pump shut -offs, set stop meters, or comparable equipment shall be employed to prevent the over filling of transport vehicles. 36. 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. Specific Requirements for the Glycol Dehydration Unit (Point 035) 37. This source is subject to Regulation Number 7, Section XII.H. 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 glycol natural gas dehydrators; and • Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. (Regulation Number 7, Section XII.H.1.) COLORADO Air Pollution Control Division D,:pera"fou Pcbl Hea' Page 12 of 33 38. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XII.H. Beginning May 1, 2005, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XII. OPERATING Et MAINTENANCE REQUIREMENTS 39. Points 001, 002, 003, 005, 007, 011, 016, 033, 034, 035, 037, 038: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your OEM plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 40. Point 036: Within one hundred and eighty days (180) after commencement of operation, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. 41. Points 033, 034, 037, 038: A source initial compliance test shall be conducted to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Formaldehyde 42. Point 035: A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) and hazardous air pollutants (HAPs: Benzene, Toluene, Xylenes, nHexane) in order to demonstrate compliance with a minimum destruction efficiency of 95% 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. This test shall be run with the thermal oxidizer operating at the minimum operating temperature as indicated in the OEM plan for this point. The operator shall monitor !COLORADO Air Pollution Control Division tis�` YFW HeBx':n,Fs EriVrtorIrro4 Page 13 of 33 and record the thermal oxidizer operating temperature during the initial compliance 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 43. Points 001, 002, 003, 005, 007, 011, 016, 033, 034, 037, 038: These engines are subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your 0&tM plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 44. Point 010: The permittee shall complete a gas analysis on a semiannual basis of gas samples that are representative of gas that may be vented from the plant blowdown vent (point 010). 45. Points 014, 026 and 036: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. 46. Point 035: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the dehydration unit on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. 47. , Point 035: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, on a weekly basis to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 48. All previous versions of this permit are cancelled upon issuance of this permit. 49. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per COLORADO Air Pollution Control Division "eoe:mm t of Ptiar₹ic l k.a.h 6 E kir0r,nre it Page 14 of 33 year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Points 001, 002, 003, 005, 007, 011, 016, 018, 019, 028 and 029: Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 50. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS: 51. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 52. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are (COLORADO Aix Pollution Control Division U,,zparttr.ert of pubic a €cc h 6 e-<ironrrt2et Page 15 of 33 located in the Requirements to Self -Certify for Final Authorization section of this permit. 53. 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. 54. 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. 55. 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 or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 56. 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. 57. 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: DRAFT Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 3 This issuance Issued to Aka Energy Group, LLC. Modification to remove points 031 and 032. ;COLORADO I Air _Pollution Control Division i I Depart”le.^.t cr %Nit 1.R.,4th u E;;rirorirrtert Page 16 of 33 Modification of component count and emissions for points 014, and 026. Addition of points 034, 035, 036, 037, 038. Issuance 2 September 22, 2016 Issued to Aka Energy Group, LLC. Modification to remove points 018, 019, 023, 024, 025, 028, 029, 030. These points were never installed. Addition of (2) RICE, (1) TEG Dehydrator, and modification of point 022 to remove emission controls. Issuance 1 June 16, 2014 Issued to Aka Energy Group, LLC. Change in permit limits to Points 001, 002, 003, 005, 007, 010, 011, 014 and 016. Addition of (4) RICE, truck loadout, amine sweetening unit, amine reboiler and burner for the thermal oxidizer. Initial Approval - Modification 1 September 24, 2008 Modification to replace engine with point ID 001 with a Caterpillar G3516LE. Initial Approval January 29, 2008 Issued to Aka Energy Group, LLC C O1.ORADO Air Pollution Control Division Page 17 of 33 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http: / /www. cdphe. state. co. us/ regulations/ai rregs/ 100102agcccommonprovisionsreg. pdf . 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 Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 001 Formaldehyde 50000 6513 Yes 1628 Acetaldehyde 75070 722 Yes 361 Acrolein 107028 444 Yes 222 Methanol 67561 216 No 108 n -Hexane 110543 96 No 48 Benzene 71432 112 No 56 Toluene 108883 704 No 352 002 and 003 EACH Formaldehyde 50000 321 Yes 161 Acetaldehyde 75070 37 No 18 Acrolein 107028 35 No 17 Methanol 67561 64 No 32 Benzene 71432 21 No 11 Toluene 108883 7 No 4 005 and 033 BOTH Formaldehyde 50000 5064 Yes 2532 Acetaldehyde 67561 366 Yes 183 Acrolein 75070 225 No 113 Methanol 107028 273 Yes 137 Benzene 71432 78 No 39 Toluene 108883 357 Yes 178 COLORADO Air Pollution Control Division ( Apart:w r l tetlt Page 18 of 33 007 and 016 EACH Formaldehyde 50000 2347 Yes 1173 Methanol 67561 261 Yes 130 Acetaldehyde 75070 238 No 119 Acrolein 107028 224 No 112 Benzene 71432 135 No 67 1,3 -Butadiene 106990 56 No 28 Toluene 108883 48 No 24 011 Formaldehyde 50000 3245 Yes 1622 Methanol 67561 649 Yes 324 Acetaldehyde 75070 314 Yes 157 Acrolein 107028 296 Yes 148 Benzene 71432 178 No 89 1,3 -Butadiene 106990 75 No 37 Toluene 108883 63 No 31 014 Benzene 71432 484 Yes 202 Toluene 108883 515 Yes 218 Ethylbenzene 100414 22 No 9 Xylenes 1130207 220 No 89 n -Hexane 110543 2638 Yes 1122 022 Benzene 71432 21 No 21 n -Hexane 110543 181 No 181 026 Benzene 71432 65 No 5 Toluene 108883 96 No 5 Ethylbenzene 100414 3 No 0 Xylenes 1130207 29 No 2 n -Hexane 110543 354 Yes 28 035 Benzene 71432 4174 Yes 208 Toluene 108883 774 Yes 39 Ethylbenzene 100414 29 No 2 Xylenes 1130207 522 Yes 26 n -Hexane 110543 468 Yes 23 034 Formaldehyde 50000 14248 Yes 3562 Acetaldehyde 75070 706 Yes 353 Acrolein 107028 434 Yes 217 Benzene 71432 110 No 55 Toluene 108883 689 Yes 344 COLORADO Air Pollution Control Division tefii'rcCXtiU'r Yimer,( Page 19 of 33 037 Formaldehyde 50000 14248 Yes 3562 Acetaldehyde 75070 706 Yes 353 Acrolein 107028 434 Yes 217 Benzene 71432 110 No 55 Toluene 108883 689 Yes 344 038 Formaldehyde 50000 14248 Yes 3562 Acetaldehyde 75070 706 Yes 353 Acrolein 107028 434 Yes 217 Benzene 71432 110 No 55 Toluene 108883 689 Yes 344 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 0.4351 1.5 0.4351 1.5 CO 0.5512 1.9 0.0386 0.133 VOC 0.1740 0.6 0.0435 0.150 50000 Formaldehyde 0.0754 0.26 0.0189 0.065 75070 Acetaldehyde 0.0084 0.0288 0.0042 0.0144 107028 Acrolein 0.0051 0.0177 0.0026 0.0089 67561 Methanol 0.0025 0.0086 0.0013 0.0043 110543 n -Hexane 0.0011 0.0038 0.0006 0.0019 71432 Benzene 0.0013 0.0045 0.0006 0.0022 108883 Toluene 0.0081 0.0281 0.0041 0.0140 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7600 Btu/hp-hr, a site -rated horsepower value of 1297, and a fuel heat value of 1000 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer + AP -42 Manufacturer + AP -42 50000 Formaldehyde Manufacturer Manufacturer Points 002 and 003 each: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 2.817 11.5 0.3674 1.5 CO 3.6744 15 0.2450 1 VOC 0.0735 0.3 0.0367 0.15 50000 Formaldehyde 0.0245 0.1 0.0122 0.05 67561 Methanol 0.0031 0.0125 0.0015 0.0062 75070 Acetaldehyde 0.0028 0.0114 0.0014 0.0057 107028 Acrolein 0.0026 0.0107 0.0013 0.0054 71432 Benzene 0.0016 0.0065 0.0008 0.0032 106990 1,3 -Butadiene 0.0007 0.0027 0.0003 0.0014 COLORADO Air Pollution Control Division Page 20 of 33 CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr 108883 Toluene 0.0006 0.0023 0.0003 0.0011 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 9000 Btu/hp-hr, a site -rated horsepower value of 166, and a fuel heat value of 1000 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer/AP-42 Manufacturer/AP-42 VOC Manufacturer Manufacturer 50000 Formaldehyde GRI Field Data GRI Field Data Point 005: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 3.307 12.000 0.274 1.000 CO 3.031 11.00 0.552 2.000 VOC 0.110 0.400 0.055 0.200 50000 Formaldehyde 0.0276 0.1000 0.0138 0.0500 67561 Methanol 0.0055 0.0200 0.0028 0.0100 75070 Acetaldehyde 0.0028 0.0101 0.0014 0.0051 107028 Acrolein 0.0026 0.0095 0.0013 0.0048 71432 Benzene 0.0016 0.0057 0.0008 0.0029 106990 1,3 -Butadiene 0.0007 0.0024 0.0003 0.0012 108883 Toluene 0.0006 0.0020 0.0003 0.0010 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8000 Btu/hp-hr, a site -rated horsepower value of 708.6 bhp, and a fuel heat value of 1000 Btu/scf. Emissions limits contained in this permit are based on the highest controlled emission factors for each pollutant between point 005 and point 033. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer Point 033: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 0.304 1.000 0.304 1.000 CO 0.947 3.110 0.473 1.555 VOC 0.253 0.830 0.126 0.190 50000 Formaldehyde 0.116 0.380 0.058 0.190 67561 Methanol 0.0025 0.0082 0.0013 0.0041 75070 Acetaldehyde 0.0084 0.0275 0.0042 0.0137 107028 Acrolein 0.0051 0.0169 0.0026 0.0084 71432 Benzene 0.0013 0.0043 0.0007 0.0022 106990 1,3 -Butadiene 0.0003 0.0009 0.0001 0.0004 108883 Toluene 0.0082 0.0268 0.0041 0.0134 COLORADO 1 Air Pollution Control Division `olrc.t e a of Pt 1lcqithb.Er.;;irOrrnerl Page 21 of 33 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7243 Btu/hp-hr, a site -rated horsepower value of 690 bhp, and a fuel heat value of 1000 Btu/scf. Emissions limits contained in this permit are based on the highest controlled emission factors for each pollutant between point 005 and point 033. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer/AP-42 Manufacturer 50000 Formaldehyde Manufacturer Manufacturer Points 007 and 016: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 3.0314 11 0.1929 0.7 CO 2.2046 8 0.2756 1 VOC 0.2205 0.8 0.1102 0.4 50000 Formaldehyde 0.0276 0.1 0.0138 0.05 67561 Methanol 0.0031 0.0111 0.0015 0.0056 75070 Acetaldehyde 0.0028 0.0101 0.0014 0.0051 107028 Acrolein 0.0026 0.0095 0.0013 0.0048 71432 Benzene 0.0016 0.0057 0.0008 0.0029 106990 1,3 -Butadiene 0.0007 0.0024 0.0003 0.0012 108883 Toluene 0.0006 0.0020 0.0003 0.0010 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8000 Btu/hp-hr, a site -rated horsepower value of 1215, and a fuel heat value of 1000 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EF Source Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer + AP -42 Manufacturer + AP -42 50000 Formaldehyde Manufacturer Manufacturer Point 010: Emissions are calculated using the results of representative gas analyses and a calculation of the amount of gas released during each event that the blowdown vent is used. Point 011: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 3.7752 13.1 0.2882 1 CO 3.3718 11.7 0.2882 1 VOC 0.1441 0.5 0.0721 0.25 50000 Formaldehyde 0.0288 0.1 0.0144 0.05 67561 Methanol 0.0058 0.0201 0.0029 0.0101 75070 Acetaldehyde 0.0028 0.0097 0.0014 0.0049 107028 Acrolein 0.0026 0.0090 0.0013 0.0045 71432 Benzene 0.0016 0.0056 0.0008 0.0028 106990 1,3 -Butadiene 0.0007 0.0024 0.0003 0.0012 108883 Toluene 0.0006 0.0021 0.0003 0.0011 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7650 Btu/hp-hr, a site -rated horsepower value of 1680, and a fuel heat value of 1000 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source COLORADO Air Pollution Control Division Page 22 of 33 CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer Point 014: Emission estimate for fugitive equipment leaks are based on the following component counts: Group 1: Wet gas, condensate, engine oil and other heavy liquids Strea m V0C (wt%) Benzene (wt%) Toluene (wt%) Ethyl- benzene (wt%) Xylene (wt%) n -hexane (wt%) Connectors Flanges Pump Seals Valves o LLI Open Line Gas 25 0.2 0.2 0.01 0.1 1.0 3634 0 0 1904 51 15 Heavy Liquid 100 1.7 2.2 0.05 0.5 12 690 0 0 270 9 0 Light Liquid 100 1.7 2.2 0.05 0.5 12 9 0 11 59 2 0 Water /Oil 100 1.7 2.2 0.05 0.5 12 57 0 0 24 0 0 Group 2: Propane refrigerant, methanol, antifreeze Stream V0C Benzene Toluene Ethyl- Xylene n- Connectors Pump Seals Valves o (wt%) (wt%) (wt%) benzene (wt%) hexane (wt%) (wt%) m m31 Gas 100 --- --- --- --- --- 448 0 0 136 0 Heavy 100 --- --- --- --- --- 0 0 0 0 0 Liquid Light 100 --- --- --- --- --- 9 0 9 36 2 Liquid Water/0i 100 --- --- --- --- --- 0 0 0 0 0 I *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Compliance with emissions limits in this permitwill be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. COLORADO Air Pollution Control Division �v3r"I"�*t[ �r 3'u¢at?� btec rt iz nrne,A Page 23 of 33 Point 022: Pollutant Emission Factors Uncontrolled lb/BBL loaded - Source Emission Factors Controlled lb/BBL loaded - Source VOC 0.236 CDPHE PS Memo14-02 --- --- The uncontrolled VOC emission factor was calculated using State approved emission factors for hydrocarbon liquid loadout in PS Memo 14-02. This loadout operation is not controlled. Point 035: The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Controlled emissions are based on a thermal oxidizer control efficiency of 95%. Total actual flash tank and still vent combustion emissions are based on the sum of the emissions for the still vent primary control and flash tank primary control. Total combustion emissions are based on the following emission factors: Primary Control: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Waste Gas Combusted Source NOx 0.0641 TCEQ CO 0.5496 TCEQ VOC 5.5 GlyCalc 71432 Benzene 0.572 GlyCalc 108883 Toluene 0.106 GlyCalc 100414 Ethylbenzene 0.00397 GlyCalc 1130207 Xylenes 0.0715 GlyCalc 110543 n -Hexane 0.0641 GlyCalc Note: The combustion emission factors are based on a heating value of 500 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the waste gas flow from the regenerator overheads stream in the monthly GlyCalc report and by the hours per month the waste gas was routed to this control device. Point 026: Emission estimate for fugitive equipment leaks are based on the following component counts: Group 1: Wet gas, condensate, engine oil and other heavy liquids Strea m VOC (wt%) Benzene (wt%) Toluene (wt%) Ethyl- benzene (wt%) Xylene (wt%) n -hexane (wt%) Connectors -n 0 tic' N Pump Seals Valves o D- `,° Gas 25 0.2 0.2 0.01 0.1 1.0 254 0 0 131 0 Heavy Liquid 100 1.7 2.2 0.05 0.5 12 0 0 0 0 0 Light Liquid 100 1.7 2.2 0.05 0.5 12 0 0 0 0 0 Water /Oil 100 1.7 2.2 0.05 0.5 12 0 0 0 0 0 Group 2: Propane refrigerant, methanol, antifreeze {COLORADO I Air Pollution Control. Division .'vi Vv.iPx E'vtrorunrrc Page 24 of 33 Stream VOC (wt%) Benzene (wt%) Toluene (wt%) Ethyl- benzene (wt%) Xylene (wt%) n - hexane (wt%) Connectors Flanges Pump Seals Valves Gas 100 --- --- --- --- --- 356 70 3 124 Heavy Liquid 100 --- --- --- --- --- 26 0 0 13 Light Liquid 100 --- --- --- --- --- 30 0 0 15 Water/Oi l 100 --- --- --- --- --- 0 0 0 0 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. Point 036: Emission estimate for fugitive equipment leaks are based on the following component counts: Group 1: Wet gas, condensate, engine oil and other heavy liquids Strea m VOC (wt%) Benzene (wt%) Toluene (wt%) Ethyl- benzene (wt%) Xylene (wt%) n -hexane (wt%) Connectors -n a m N Pump Seals Valves Other * Gas 25 0.2 0.2 0.01 0.1 1.0 3028 0 0 1586 42 Heavy Liquid 100 1.7 2.2 0.05 0.5 12 575 0 0 225 7 Light Liquid 100 1.7 2.2 0.05 0.5 12 7 0 9 49 1 Water /Oil 100 1.7 2.2 0.05 0.5 12 47 0 0 20 0 Group 2: Propane refrigerant, methanol, antifreeze Stream VOC Benzene Toluen Ethyl- Xylene n- Connectors Pump Seals Valves o (wt%) (wt%) e (wt%) benzene (wt%) (wt%) hexane (wt%) a m s 9, COLORADO lution Control Division Page 25 of 33 Gas 100 --- --- --- --- --- 373 0 0 113 0 Heavy Liquid 100 --- --- --- --- --- 0 0 0 0 0 Light Liquid 100 --- --- --- --- --- 7 0 7 30 1 Water/ Oil 100 -- --- --- --- --- 0 0 0 0 0 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/ hr -component): Component Gas Service Heavy Oil Light Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. Point 034: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 0.159 0.500 0.159 0.5 CO 0.732 2.300 0.183 0.575 VOC 0.347 1.090 0.08675 0.2725 50000 Formaldehyde 0.530 0.1325 75070 Acetaldehyde 0.00836 0.00418 107028 Acrolein 0.00514 0.00257 71432 Benzene 0.00130 0.00065 108883 Toluene 0.00815 0.004075 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6929 Btu/hp-hr, a site -rated horsepower value of 2088, and a fuel heat value of 905 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer Point 037: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 0.159 0.500 0.159 0.5 CO 0.732 2.300 0.183 0.575 'COLORADO Air Pollution Control Division Page 26 of 33 CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr V0C 0.347 1.090 0.08675 0.2725 50000 Formaldehyde 0.530 0.1325 7507O Acetaldehyde 0.00836 0.00418 107028 Acrolein 0.00514 0.00257 71432 Benzene 0.00130 0.00065 108883 Toluene 0.00815 0.004075 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6929 Btu/hp-hr, a site -rated horsepower value of 2088, and a fuel heat value of 905 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source N0x Manufacturer Manufacturer CO Manufacturer Manufacturer V0C Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer Point 038: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr N0x 0.159 0.500 0.159 0.5 CO 0.732 2.300 0.183 0.575 V0C 0.347 1.090 0.08675 0.2725 50000 Formaldehyde 0.530 0.1325 75070 Acetaldehyde 0.00836 0.00418 107028 Acrolein 0.00514 0.00257 71432 Benzene 0.00130 0.00065 108883 Toluene 0.00815 0.004075 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6929 Btu/hp-hr, a site -rated horsepower value of 2088, and a fuel heat value of 905 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source N0x Manufacturer Manufacturer CO Manufacturer Manufacturer V0C Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer 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) All engines are subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting - effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf COLORADO l Air Pollution Control Division I Dep rt' .e tte(thU G, avor,r e,A. Page 27 of 33 8) All engines are subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://.www.epa.gov/ttn/atw/area/fr181a08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html 9) Point 036: This source is subject to 40 CFR, Part 60, Subpart OOOOa-Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting — effective August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: https://www.gpo.gov/fdsys/pko/FR-2016-06-03/pdf/2016-11971.pdf 10) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, CO, formaldehyde, benzene, toluene, xylenes, n -Hexane, total HAPS NANSR Synthetic minor Source of: NOx, VOC PSD Synthetic Minor Source of: CO MACT ZZZZ Area Source Requirements: Applicable MACT HH Area Source Requirements: Applicable 11) 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 r 12) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet. Please use this form to complete the self -certification requirements as specified in the permit conditions. Further guidance on self -certification can be found on our website at: http:/ /www.cdphe.state.co.us/ap/oilgaspermitting.html COLORADO Air Pollution Control Division DePartmem!N Pti E t. He vt L4 ;..:atYLlrv:�2r: Page 28 of 33 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements 'COLORADO Air Pollution Control Division Page 29 of 33 applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability • Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http: / /www.colorado.gov/cs/Satellite/CDPH E-AP/CBON / 1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. COLORADO Air Pollution Control Division Page 30 of 33 If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and S02, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ 502: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E - State -only requirements COLORADO! Air Pollution Control Division •`epwt-4..t of Public liNeith G E';virf rv=.Yez;t Page 31 of 33 Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500<Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for COLORADO Air Pollution Control Division `u2F s =eent-of NAIL,. t ieeYn ok^roorment Page 32 of 33 any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. COLORADO Air Pollution Control Division I Department 0 RA I rerr tit iJ EmPorlttertt Page 33 of 33 Glycol Dehydration Unit APEN - Form APCD-2 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this A'EN and application must be completed for both new and existing facilities, incluaiTig 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 Glycol Dehydration (Dehy) Units 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-2OO) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/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: 07WE0881 AIRS ID Number: 123 / 0098 / S [Leave blank unless APCD has already assigned a permit s and AIRS ID] Company equipment Identification: EG [Provide Facility Equipment ID to identify how this equipment ;s referenced within your organization) Section 1 - Administrative Information Company Name': Aka Energy Group, LLC Site Name: Gilcrest Gas Plant Site Location: 13472 Weld County Road 40 Mailing Address: (include Zip Code) 125 Mercado Street, Suite 201 Durango, CO 81301 E -Mail Address': ehinkley@redcedargathering.com Site Location County: Weld NAICS or SIC Code: 1321 Permit Contact: Ethan Hinkley Phone Number: (970) 764-6495 w"lip 4171-,7kra. 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. ( 2p1 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 1 un� 22 \ lam+ 2 j) CD Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 r„,.c„ . 1 I Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ [Leave blank unless APCD has already assignetl a permit a and AIRS ID] Section 2- Requested Action l] NEW permit OR newly -reported emission source -OR- Q MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑i Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: ' 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: dehydration of natural gas Facility equipment Identification: EG For existing sources, operation began on: / / For new or reconstructed sources, the projected start-up date is: 1 /15 /2018 ❑� Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions days/week Yes Yes Form APCD-202-Glycol Dehydration Unit APEN - Revision 02/2017 2 i weeks/year No No Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ [Leave blank unless APCD has already assigned a permit z and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: TBD TBD Ethylene Glycol (EG) Model Number: Reboiler Rating: Ethylene Glycol Regeneration Skid 3.5 ❑ DiEthytene Glycol (DEG) Glycol Pump Drive: 0 Electric ❑ Gas If Gas, injection pump ratio: Pump Make and Model: TBD Glycol Recirculation rate (gal/min): Lean Glycol Water Content: 1.5 Max: 10 Wt. MMBTU/hr hr ❑ TriEthylene Glycol (TEG) Requested: 10 # of pumps: Acfm/gpm 2 Dehydrator Gas Throughput: Design Capacity: 20 MMSCF/day Per" i Requested: MMSCF/year Actual: _T MMSCF/year Inlet Gas: Pressure: 850 Water Content: Wet Gas: Flash Tank: Pressure: 55 Cold Separator: Pressure: 846 psig lb/MMSCF psig. psig Stripping Gas: (checi one) 0 None ❑ Flash Gas ❑ Dry Gas ❑ Nitrogen Flow Rate: scfm Temperature: 80 E Saturated Dry gas: Temperature: 28 Temperature: _20 -F lb/MMSCF ❑ NA ❑ NA Additional Required Information: O Attach a Process Flow Diagram • Attach GRI-GLYCaIc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) El Attach the extended gas analysis (including BTU Et n -Hexane, temperature, and pressure) Form APCD-202 Glycol Dehydration Unit APEN - Revision 02/2017 3 Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ (Leave blank unless APCD has already aasipnec a permit end AIDS iDj Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or LITM) 40.274905°/-104.802882° r are �� D ha eight �Ab it dri Levee .- stet w >�mQ. Flovsr ite C YelaCit se TO TSD 1400 Indicate the direction of the stack outlet: (check ones ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): - C . C Form APCD-202 Glycol Dehydration Unit APEN - Revision 02/2017 4 Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ [Leave blank unless APCD has alreadv asst nc a nerr-ut A,RS ID" Section 6 - Control Device Information Condenser: Used for control of: VOC/HAP Type: shell/tube Make/Model: TBD p Maximum Temp 160 F Average Temp Requested Control Efficiency 0 % VRU: Used for control of: Size: Make/Model: ■ Requested Control Efficiency VRU Downtime or Bypassed Combustion Device: Used for control of: VOC/HAP Rating: TBD MMBtu/hr Type: Thermal oxidizer Make/Model: TBD Requested Control Efficiency: 95 % 500 Btu/scf MMBtu/hr GI Manufacturer Guaranteed Control Efficiency 98 ro Minimum Temperature: TBD Waste Gas Heat Content 0.1 Constant Pilot Light: • Yes ■ No Pilot burner Rating Closed Loop System: Used for control of: • Description: System Downtime Other: Used for control of: Description: • Control Efficiency 0 o Requested o Form APCD-2O2 -Glycol Dehydration Unit APEN - Revision 02/2017 c7 5 I � a`' Permit Number: 07WE0881 AIRS ID Number: 123 /0098( [Leave blank unless APCD has already assrgned a Gerrit 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, please describe the control equipment AND state the overall control efficiency ( , From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor ` Source (Ap-i2, Mfg. etc) e ` - tS As a Actual quill Emission, ��ril.tit � ��. 5, Uncontrolled (Tons/year) Controlleds (Tons/year) Uncontrolled Controlled (Tons/year) (Tons/year) PM - - - - - - - SO„ - - - - - - - NOx - - - - - - - CO - - - - - - - VOC 5.5 Ib/MMSCF GRI-GLYCaIc 20.0 tons/yr 1.0 tons/yr Benzene 5.72E-01 Ib/MMSCF GRI-GLYCaIc 4174 lb/yr 208 lb/yr Toluene 1.06E-01 Ib/MMSCF GRI-GLYCaIc 774 lb/yr 39 lb/yr Ethylbenzene 3.97E-03 lb/MMSCF GRI-GLYCaIc 1 29 Ib/yr 2 lb/yr Xylenes 7.15E-02 Ib/MMSCF GRI-GLYCaIc I 522 lb/yr 26 lb/yr n -Hexane 6.41 E-02 Ib/MMSCF GRI-GLYCaIc 468 lb/yr 23 lb/yr 2,2,4- Trimethytpentane 8.22E-05 Ib/MMSCF GRI-GLYcaic 1 lb/yr 0 lb/yr Other: I 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-202 Glycol Dehydration Unit APEN - Revision 02/2017 6 I `; Permit Number: 07WE0881 AIRS ID Number: 123 t0098/ [Leave blank unless APCD has already assigred a pern;t K and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. lam•--b,J sr�� Signature of Legally A zed Person (not a vendor or consultant) Ethan Hinkley Name (please print) I��22�17 Date Air Quality Compliance Maria* Title Check the appropriate box to request a copy of the: E] Draft permit prior to issuance Draft permit prior to public notice (Checking arty of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-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-202 -Glycol Dehydration Unit APEN - Revision 02/2017 7IAwOtti 4/17/2018 State.co.us Executive Branch Mail - Aka Gilcrest - EG dehydrator changes STATE OF COLORADO Sharp - CDPHE, Timothy <timothy.sharp@state.co.us> Aka Gilcrest - EG dehydrator changes Joe Miller <jmiller@mtn-air.com> To: "Sharp - CDPHE, Timothy" <timothy.sharp@state.co.us> Tue, Mar 20, 2018 at 5:10 PM Hi Timothy - Thanks for getting this out! Per below, yes, Point 035 should have a process limit of 7,300 mmscf/yr (20 mmscfd). (Will get back with full comments in the next day or 2.) Thanks again Joe From: Sharp - CDPHE, Timothy[mailto:timothy.sharp@state.co.us] Sent: Monday, March 19, 2018 6:05 PM [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0/?ui=2&ik=01917fb5148dsver=z8 JB6tBO LQ.en. &view=pt&msg=16245ad bd7e49554&cat=Task%20Email &search=cat&sim 1=1624; Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All_sections of this APEN and application must be completed for both new and, existing facilities; includi updates. An application with missing information may be determined incomplete and may be returned longer application processing times. You may be charged an additional APEN fee if the APEN is filled ou incorrectly or is missing information and requires re -submittal. This APEN is to be used for reciprocating internal combustion engines (RICE). if yourengine is a diesel compression ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.)_ In • addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of ail available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, Ii.C. for revised APEN requirements. Permit Number: 07WE0881 AIRS ID Number: 123 /0098 /O'f L f (Leave blank unless APCD has already assigned a permit t and AIRS ID] Section 1 - Administrative Information Company Name': Aka Energy Group, LLC Site Name: Gllcrest Gas Plant Site Location: 13472 Weld County Road 40 Mailing Ada1 Address: (Include Zip 125 Mercado Street, Suite 201 Code Portable Source Home Base: Durango, Co 81301 Site Location County: Weld NAICS or SIC Code: 1321 Permit Contact: Ethan Hinkley Phone Number: (970) 764-6495 E -Mail Address': ehmkiey@redcedargathering.com Use the €ull, 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 arty processing invoices wilt be issued by APCD via e-mail to the address provided. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1'2017 R� �(^ 36gs 13 Permit Number: 07WE0881 AIRS ID Number: 123 /0098 / {Leave blank unless APC0 has already assigned a permit = and AIRS ID.} Section 2 - Requested Action 0 NEW permit OR newly -reported emission source (check one below) 0 STATIONARY source O PORTABLE source D. Request coverage under a Construction Permit O Requestcoverage under General Permit GP025 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along with the APEN Filing fee. - OR - MODIFICATION to existing permit (check each box law that applies( O Change fuel or equipment ❑ Change company name 0 Add point to existing permit O Change permit limit O Transfer of ownership" O Other (describe below). -OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT AC'noNS - Q APEN submittal for permit-exempt/grandfathered source Q Notification of Alternate Operating Scenario (AO5) permanent replacements Additional Info Et Notes: one (I) Caterpillar G3516C generator engine, hours and emissions indicated are 2/3 fun time operation, per APCD; three (3) identical units to be installed with two (2) operating and one (1) as a backup Only one engine may be reported per APEN for GP02 coverage. Coverage under GP0Z is voluntary. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-1O4) must be submitted. 5 This does not apply to General Permit GPO2,. as it does not contain a provision. for AOS permanent replacements. Section 3 - General Information Dotes this engine have.a Company Equipment Identification No, (e.g. ENG-1, Engine 3, etc)? yes If yes, provide the Company Equipment Identification No. G-1 General description of equipment and purpose: generation of electricity For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (sttp: //www.cotorado.gov/cdphe /attainment) Normal Hours of Source Operation: 24 Seasonal use percentage: Dec -Feb: 25 3/9/2018 0 Yes Q No hours/day 7 days/week.52 weeks/year Mar -May: 25 June -Aug: 28 Sept -Nov: 25 Form APCD-2Q1 - Reciprocating Internal. Combustion Engine APEN, - Revision 1 2017 2 Permit Number; 07WE0881 • AIRS ID Number; 123 /0098 / [Leave blank unless APCD has aiready assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: p Primary and/or Peaking O Pump Q Water Pump OEmergency Back-up Q Other: Compression What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Caterpillar What is the maximum designed horsepower rating? 2175 hp What is the engine displacement? l/cyl Engine Model: G3516C Serial Number§: TBD hours/year What is the maximum manufacturer's site -rating? 2088 hp 1416 kW What is the engine Brake Specific Fuel Consumption, at 100% Load? 6929 BTU/hp-hr Engine Features: Cycle Type: O 2 -Stroke 0 4 -Stroke Combustion: Q Lean Burn Ignition Source: E Spark O Compression Aspiration: D Natural Is this engine equipped with an Air/Fuet ratio controller (AFRC)? Q Yes ❑ No If yes, what type of AFRC is in use? O 02 Sensor (mV) ONOx Sensor (ppm) D Other: Is this engine equipped with a Low-NOr design? 0 Yes O No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 (will be new units) What date was this engine ordered? after 6/12/2006 © Rich Burn Q Turbocharged What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? TBD What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? O Yes O Na If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must be submitted if coverage under GPO2 is requested, Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1 /2017 Permit Number: 07WE0881 AIRS ID Number: 123. /0.098 /.. [Leave blank unless APCD has already assigned a permit l and. AIRS ID] Section 5 -'Stack Information Geographical Coordinates$• tttude/l.Dngltudet or UTM) 40.27508.9°1-104;803763° a �`�'i arg el a Grow l.@Ye „v-.. ' F'a'd>.t� a.� Pni�� . �' �i - Flo>kr to ` a` e. Oa � la a ,�., � ear. ate r*'n. -,a G-1 854 12366 Indicate the direction of the Stack outlet: (check one) ❑ Downward ❑ Other (describe): Upward [] Horizontal Indicate the stack opening and size: (check one) ❑r Circular Interior stack diameter (inches); ❑ Square/Rectangle Interior stack diameter (inches): ❑ Other (describe): O Upward with obstructing raincap Interior stack depth (inches): Section 6 - Fue[ Data and Throughput Information ,atuaire rnial e t�se- 15,986 93.4 From what year is the actual onnuol'arnount? _ Indicate the type of fuel used: Pipeline Natural Gas (irssurned fuel heatingvalue of 1;020'BTU/scf) ❑✓ Field Natural Gas Heating value:. 905 BTU/scf ❑; Propane (assumed fuel heating value: of 2,300 BTU/scf) Landfill Gas. Heating Value:. BTU/scf El Other (describe):: Heating Value (give units): y. Requested values wiU.beconie permit limitations. Requested limit(s):should consider .future.process growth, If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. cotoat.a' Form APCD-201 - Reciprocating Internal Combustion Engine APEi : - Revision 1/2017 4 i Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 [Leave blank unless APCD has already assigned a pe rittt ;t -and MRS ID) Section 7 Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? Q Yes ❑ No If yes, describe the control, equipment AND state the overall control efficiency (% reduction): TSP (PM) PM10 PM2.5 SOx, NOx VOC oxidation catalyst 75% CO. oxidation catatysf 75% Other: o:idahen catalyst (144P) 75% formaldehyde: 50% other HAP Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? TSP (PM) PM1a PMMt z s 9.99E-03 tb.4�MAABtu do Poll aurce AP=42, fg. etc) AP42 Emissions, Inventory Incvntrolied; Emissions {Tonsfyear) oilers ions 1 year} 0.4 0,4 9.99E-03 fe/MRABtu AP 42 0.4 SOk NOX VOC 4.99E-03 IJMMBtu AP 42 5.68E-04 16JMMBtu AP 42 0.4 0.02 0.5 g1Lhp-hr manufacturer 5.7 CO 1',09 g1bh,1-hr manutacbaerlAP 42 3.7 2.30 grbhp.hr manufacturer 34.9 7.7 Does the emissions source have any uncontrolled actual emissions of non -criteria 0 Yes Q No pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbslyear? If yes, please use the following table to report the non -criteria pollutant (HAP) emissionsfrom source: Formaldehyde Acetaldehyde Acrotein Benzene Other: Ion -Criteria Reportab 50000 75070 107028 71432 toluene.105588 0.53 8.366E-03 5.14E-03 Poilutoot, refhil.AB:u 1.30E-03 . t5fl4MBtu 8.15E-03 Ib/Mt4Btu gfbhp-hr manufacturer AP 42 GRf GRI Inventory 14240 706 434 110 639 3552 217 55 344 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank, Form APCD-2O1 - Reciprocating Internal Combustion Engine APEN - Revision 1'2017 5 Ia Permit Number: O7WEO881 AIRS ID Number: 123 /0098 / (leave bla:ix unless APCD has already assigred a per -nit air AIRS ID) Section 8 - Applicant Certification ( hereby certify that alt information contained herein and information submitted with this application is complete, true - and correct. if this is a registration for coverage under general permit GP02, L further certify that this source is and will be operated in full compliance with each condition of general permit GP02. Signature of Legally Authorized P •n (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box to request a copy of the: ID 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, LL.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $1,500, if applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-BI 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 r Small Business Assistance Program (303) 692-3175 or (303) 692.3148 Or visit the APCD website at: https: /1www.colorado.gov/cdphe/apcd C 0 - Reciprocating, Internal Combustion Engine APEN - ievssion 1 /2017 Reciprocating Internal Combustion Engine APEN - Form APCD-2Q1 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`tn. longer application processing times. You may be charged an additional APEN fee if the APEN is fill-'—'" incorrectly or is missing information and requires re -submittal. This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a dit ignition engine or your emissionn unit does not fall into the RICE category, there may be a more specific. APE your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc:): In addition, the General APEN (Form APCD-200) is availableif the specialty APEN options will not satisfy your reporting needs. A Lst of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www,colorado.govlcdphelapcd, 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: 07WE0881 AIRS iD Number: 123 / 0098 / o'31 - [Leave blank unless APCD has already assigned a permi, n and AIRS ID] Section 1 - Administrative information Company Name': Aka Energy Group, LLC Site Name: Gilcrest Gas Plant Site Location: 13472 Weld County Road 40 Mailing Address: 125 Mercado Street, Suite 201 (Include Ilp Code, Portable Source Home. Base: Durango, CO 81301 Site Location County: Weld NAICS or SIC Code: 1321 Permit Contact: Ethan Hinkley Phone Number: (970) 764-6495 E -Mail Address2: ehinkley@redcedargathering.t.Q, i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APE). Any changes will require additional paperwork. Permits, exemption letters, and arty processing invoices will be issued by APCD via e-mail to the address provided. 376605 Form APCD-201 - Reciprocating Internal Combustion Engine APEN Revision 1'ZD17 Permit Number: 07WE0881 AIRS ID Number: 123 /0098 / [Leave blank unless APCD has already- assigner a permit = and AIRS ID] Section 2 - Requested Action NEW permit OR newly -reported emission source (check one be(ow) ❑ STATIONARY source O PORTABLE source ❑r Request coverage under a Construction Permit O Request coverage under General Permit. GP023 (Natural Gas Only) if General Permit coverage is requested, the General Permit registration fee of Si,5O0.Oo must be submitted along with the APEN Filing fee. - OR- I _E MODIFICATION. to existing permit (check each box.betaw rhos applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit O Change permit limit O Transfer of ownership'' O Other (describe below) -OR ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - [3 APEN submittal far permit-exempt/grandfathered source O Notification of Alternate Operating Scenario (AOS) permanent replacements Additional Info a Notes: one (1) Caterpillar G3516C generator engine: hours and emissions indicated are 2/3 full time operation, per APCD: three (3) identical units to be installed with two (2) operating and one (1) as a backup 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-1o4) must be submitted. 5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? yes if yes, provide the Company Equipment Identification No. G-2 General description of equipment and purpose: generation of electricity For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 3/9/2018 Wilt this equipment be operated in any NAAQS nonattainment area? (haw/ /wvvw.colorado. gov/ cdphe f attai nrnent) Normal Hours of Source Operation: 24 hours/day 7 ❑ Yes O No Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 days/week 52 weeks/year June -Aug: 25 Sept -Nov: 25 Form APCD-201 Reciprocating. Internal Combustion Engine APEN Revision 1:'2017 21 Permit Number: 07WE0881 AIRS ID Number: 123 /0098 / [Leave blank unless APCD has already assigned a permit w and AIRS ID Section 4 - Engine Information_ Engine Function: Primary and/or Peaking fl Pump ❑ Water Pump O Emergency Back-up ❑ Other: Compression What is the maximum number of hours this engine will be used far emergency back-up power? Engine Make: Caterpillar Engine Model: G35160 Serial Number&; TBD 0 What is the maximum designed horsepower rating? 2175 hp What is the engine displacement? What is the maximum manufacturer's site -rating? 2088 hp 1416 kW What is the engine Brake Specific Fuel Consumption at 100% Load? 6929 BTU/hp-hr hours/year t/cyl Engine Features: Cycle Type: ❑ 2 -Stroke 0 4 -Stroke Combustion: O Lean Burn O Rich Burn Ignition Source: a Spark ❑ Compression Aspiration: CJ Natural (Q Turbocharged is this engine equipped with an Air/Fuel ratio controller (AFRO)?0 Yes O No If yes,what type of AFR.C is in use? Q 02 Sensor (mV) ❑NOx Sensor (ppm) Is this engine equipped with a Low-NOx design? Yes O No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 (will be new units) O Other: What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? TBD What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? rile his APEN reporting an AOS replacement engine? ❑ Yes O No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: fi The serial number must be submitted if coverage under GP02 is requested. Form APC0 201 - Reciprocating Internal Combustion Engine APEN - Revision 1,2017 ,cr�a cc;os �-r 3 ber: O7WE0881 AIRS ID Number: 123 /0098 / [Leave blank unless APCD has a:ready assigned a permit and MR. Section 5 - Stack Information Indicate the direction of the Stack outlet: (check one) Upward 0 Downward 0 Horizontal aphca nude /Lang 40,275089°/-104.803763 Q Other (describe):. indicate the stack opening and size: (check One) El Circular Square/Rectangle Q: Other (describe): O Upward with obstructing raincap Interior stack diameter (inches): Interior stack diameter (inches): Interior stack. depth (inches): Section 6 - Fuel Data and Throughput Information From what year is the actual annual ama,nt?' Indicate the type of fuel useds: © Pipeline Natural Gas (assumed fuel heatingvalue of 1,020 BTUiscf) d Field Natural Gas Heating value:: 905 BTU/scf E3 Propane (assumed fuel heating value of 2,300 BTU/ scf) [j Landfill Gas. Heating Value: STU/scf O Other (describe): Heating Value (give units): 7 Requested values will became permit limitations. Requested timit(s) should consider future process growth. If fuel heating value is different than the listed assumed value. provide this information in the "Other" field. Form APCD-201 Reciprocating internal Combustion Engine /xPEN:- Revision 1/2017 4 Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / [Leave blank unless APCD has already assIgnEd a permit„ acid AIRS ID1 Section 7 • Emissions Inventory information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission. calculations. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No Ifyes, describe the control equipment AHD state the overall control efficiency (.5,,‘ reduction). TSP (PM) PMio PM2.5 Sax NO0 VOC oxtda,ar. 75% CO =dawn Catalyst 75% Other: oxidation catalyst (HAP) 75% tetmatGenyye; 50% owes HAP Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? TSP (PM) PM10 PhA2,5 9:99E-03 curie.' etc) , ibiNttve$ a AP 42. ncontrolled Emissions (ions/year) lied tS ear) 0.4 0.4 9.99E-03 IGtMMBtu AP 42 ne 0.4 Sox NOx voC 9.99E-03 Btu AP 42 04 0.4 5.88E-04 ItliMMBttr. AP 42 0.02 0.5 gibhp-hr manufacturer 57 5.7 1,09 g.5hp-hr manuiacturstiAP 42 3.7 CO e'b5p-Pr manufacturer 309 7.7 Does the emissions source have any uncontrolled actual emissions of non criteria El Yes O No pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than. 250 tbs/year? If yest please use the following table to report the non -criteria pollutant (HAP) emissions from source: Acetaldehyde Acrolein Benzene Non -Criteria Reportable Pollutant Emissions Inventory ,ical Actual si 75070 107028 71432 Emission Faitor 0.53 8.30E-03 5.14E-03 g+bh54 r ).bad1.{Btu F0 W.MBtu AP 42 AP42 705 434 Formaldehyde • 50000 mar,ctuser 14248 353 217 Other: toluene 106883 1,30E-03 fMta to GRI ..15`5-03 14.iMBtu :GRI 110 588 55 Requested values will become permit limitations. Requested tirnitis) should consider future process growth. 9 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 Reciprocating internal Combustion Engine APE:N - Revision 1 2017 Permit Number: 07WE0881 E0881 AIRS ID Number: 123 /0098 / (Leave bunk- unless APO has 3trcadi assigned a ;:erreit " alle AIRS iD.j Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will be operated in full compliance with each condition of general permit GP02. z j4 i > Signature of Legally Authortzr P?rson (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box to request a copy of the: Ell Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with S152.90 and the General Permit For more information or assistance call: registration fee of $1,5110, if applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-84 4300 Cherry Creek Drive South Denver, Co 80246`1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 69.33150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado,gov/cdphe/apcd 'r`.rm APCD-201 ' t<.eciproca i u iriterna4-Comtbust cjn Engire APEI4 • Rev, Lion 1 201 6 i` NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 01WEQBB1. Company Name: Aka Energy Group, LLC Plant Location: 13472 Weld County Road 40 Person to Contact: Ethan Hinkley E-mail Address: ehinkley@recicedarg. AIRS ID Number: 123/0098 County: Weld Phone Number: (970) 764-6495 Fax Ntarrlber. Zip Code: Chemical Abstract Service (CAS) Chemical Name Number Control Equipment Emission Factor Emission Factor / Reduction (%) (Include Units) Source 67-5 1 methanol oxidation catalyst/50% 2.50E-03 lb/MMBtu AP 4 Uncontrolled Actual Emissions (lbs/year) 211 Controlled Actual Emissions (lbs/year) 06 110 -54- n -hexane oxidation catalyst/50% 111E-03 lb/MMBtu AP 42 g4 47 Calendar Year for which Actual Data Applies: 0X -- Signature of Person 1�:��'"� Author ized 0 to Supply Data Ethan Hinkley Name of Person Legally Authorized to Supply Data (Please print) i/4ls' Date Air Quality Compliance Manager Title of Person Legally Authorized to Supply Data Form Revision Date; April 14,,_2014 GUIDANCE FOR NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM Non -Criteria Reportable Air Pollutant Emission Notice Addendum: This form must be filed for each emission point (individual or grouped) that has uncontrolled actual emissions equal to or greater than 250 Pounds per year of any non -criteria reportable pollutant listed in Regulation 3, Appendix B. Permit Number: For New Permit Applications leave this blank. For modifications to existing permits, please list the permit number previously issued by the APCD. AIRS ID Number: For a new Air Pollutant Emission Notice (APEN) or new Permit Applications leave this blank. For modifications to existing APEN/permits, please list the emissions point AIRS ID number previously issued by the APCD, Chemical Abstract Service (CAS) Number and Chemical Name: Please list the CAS number and common chemical name for each non -criteria reportable air pollutant that is emitted from this emission point, A list of CAS numbers and common chemical names may be found in Regulation 3, Appendix B. This can also be found on the chemical Safety Data Sheet (SDS) Control Equipment f Reduction (%): Please list the type of control equipment used (Le. SCR, NSCR, Flare, Thermal Oxidizer, etc.) and report the minimum percent reduction achieved by the control equipment. Emission Factor: If applicable, please list the emission factor used to calculate the emission rates listed in the actual emission columns. Emission Factor Source: Example emission factor sources include; AP -42, GRI HAP Calc., EPA TANKS, GRI GLY Cale, Manufacturer's Emission Factor, and Mass Balance. Uncontrolled Actual Emissions: Enter the actual uncontrolled data year (projected first year emissions for new sources) emissions (Ibs/year) from the reported emission point excluding any emission reduction achieved by control equipment. Controlled Actual Emissions: If emissions are controlled, enter the actual controlled data year (projected first year emissions for new sources) emissions (lbs/year) from the reported emission point including the emission reduction listed in the "Control Equipment Reduction (%)" column. Enter "N/A" if the emissions are uncontrolled. SUBMITTAL OF THIS ADDENDUM MUST BE ACCOMPANIED BY AN AIR POLLUTANT EMISSION NOTICE (APEN) All sections of the APEN and Addendum must be completed for both new and existing facilities, including APEN updates. An application with missing information maybe determined incomplete and may be returned to you or result in longer engineer processing times. Please note there is an APEN filling fee. You may be charged an additional APEN fee if the APEN or Addendum is filled out incorrectly or missing information and requites re -submittal. Copies of this form may be obtained on the Internet under Construction Permit Forms and APENS: httly://www.colorado.govicdphelapcd Form Revision Date: April (4: 2Q't4 Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and maybe longer application processing times. You may be charged an additional APEN fee if the APEN incorrectly or is missing information and requires re -submittal, This ADEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression ignition engine or your emission unit does not fait into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc,), in addition, the General APEN (Form APCD-200) is available if the specialty APEN options wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the AirPollution Control Division (APCD) website at: www.cotorado.govfcdphe/pcd. 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: 07WE0881 AIRS ID Number: 123 /0098 / <)3 g [Leave blank unless APCD has already assigned a permit = and AIRS ID] Section 1 - Administrative information Company Name': Aka Energy Group, LLC Site Name: Gilcrest Gas Plant Site Location: 1 Site Location 3472 Weld County Road 40 County: Weld Mailing Address; (Include Zip125 Mercado Street, Suite 201 Portable Source Home Base: Durango, CO 81301 NAIC5 or SIC Code: 1321 Permit Contact: Ethan Hinkley Phone Number: (970) 764-6495 E Mail Address'': ei inkiey� in. redcedargathedng.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will requireadditional. paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via a -mail to the address provided. 376606 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / [Leave blank unless APCD has ai eaoy o ne twit ant. Add ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source Q PORTABLE source • Request coverage under a Construction Permit O Request coverage under General Permit GP02' (Natural Gas0nty) If General Permit coverage is requested, the General Permit registration fee of $1,300.00 must be submitted along with the APEN Filing fee. -OR- ® MODIFICATION to existing permit ttheck ecch box belJw cnoraaFrres1 O Change fuelor equipment. Q Change company name Add point to existing permit O Change permit limit. Q Transfer of ownership' ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Blank APENs wilt not be accepted) - ADDITIONAL PERMIT ACTJ0Ns ❑ APEN submittal for permit-exempt/grandfathered source O Notification of Alternate Operating Scenario (AOS) permanent replacements Additional info a Notes: one (i ) Caterpillar G3E16G generator engcne floors and emissions indicated are 2'3 full time ope,ailon,per APCO; three (3) identical units to be installed with two (2) operating and one (1) as a backup 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 Far transfer of ownership, a completed Transfer of ownership Certification Form (Form APCO.104) must be submitted. 5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. teg. ENG-1, Engine 3, etc)?. yes If yes, provide the Company Equipment Identification No. G-3 General description of equipment and purpose: generation of electricity For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 3/9/2O18 Will this equipment be operated in any hlAAQS nonattainment area? (httiti://www.colorado_gov/cdphe/attainment) Normal Hours of Source Operation:. 24 hours/day 7 ❑Yes ❑ND Seasonal use -percentage: Dec -Feb: 25 Mar -May: 25 days/week 52 weeks/year June -Aug: 25 Sept -Nov: 25 Form APCD-201 • Reciprocating internal. Combustion Engine. APEN - Rev'is r n 112Q17 2 I Permit Number: 07WEO881 AIRS ID Number: 123 /0098 I [Leave blank. unless APCI.D has already assisned a permit and AIRS ID] Section 4 - Engine Information Engine 0 Primary and./or Peaking O Emergency Back-up Function: O - Pump ❑ Water Pump ❑ - Other: ❑ Compression What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Caterpillar Engine Model: G0516C Serial Number4: TBD hours/y€ar What is the maximum designed horsepower rating? 2175 hp What is the engine displacement? What is the maximum manufacturer's site -rating? 2088 hp 1416 kW What is the engine Brake Specific Fuel Consumption at 100% Load? 6929 BTU/hp-hr t/cyl Engine Features: Cycle Type: O 2 -Stroke 0 4 -Stroke Combustion: El Lean Burn O Rich Burn Ignition Source: 0 Spark ❑ Compression Aspiration: ❑ Natural 0 Turbocharged' Is this engine equipped with an Air/Fuel ratio controller (AFRC)? El Yes O No If yes, what type of AFRC is in use? ❑ O2 Sensor (mV) ONOx Sensor (ppm) ❑ Other: Is this engine equipped with a Low-NOx design? 0 Yes ❑ No Engine Dates: What is the manufactured date of this engine? after 7/1/2007 (will be new units) What date was this engine ordered? after 6/12/2006 What is the date this engine was first located to Colorado? after 7/1/2010 What is the date this engine was first placed in service/operation? TBD What is the date this engine commenced construction? after 6/12/2006 What is the date this engine was last reconstructed or modified? n/a Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No If yes, provide the make, model, and serial number of the aid engine below: Engine Make: Engine Model: Serial Number: s The seria[ number must be submitted if coverage under GP02 rs requested. Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 1 /2017 Permit Number: C7WE0881 AIRS iD Number: 123 /0098 / [Leave blank unless APCD has already assigned a perrn = and AI�,5 1P.] Section 5 - Stack Information Get:rap (i.atitude Coordinates ,lade or uTML} 40.27509Q°/-104. 803818 n •�.r1 t rt ,. n ., �a x '. .. G' -2 _ , . . Q, r� 854 i 2366 Indicate the direction of the Stack outlet: rcr,ecx one) Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: /check one) Circular O Square/Rectangle ❑ Other (describe): II Upward with obstructing raincap Interior stack diameter (inches): Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information 15,986 93,4 From what year is the actual annual amount? Indicate the type of fuel used':. ❑ Pipeline Natural Gas (assumed fuel heating value of 1.,020 BTU/scf) Field Natural. Gas Heating value: 905 BTU/scf Propane (assumed fuel heating value of 2,300 BTU/scf) Landfill Gas Heating Value BTU/scf ❑ Other (describe): Heating Value (give units): :Requested values will become permit Limitations. Requested Limit(s) should consider future process growth. b If fuel heating value is different than the listed assumed value, provide this information in the 'Other" field. Form APCD-Z0t - Reciprocating Internal Cc nbust.ion Engine APEN - Revision 1:`2017 4 1 Permit Number: 07WE0881- AIRS ID Number: 123 /0098 / [Leave [stank, unless APCD has already asstgne1 a pernnt arc AIRS iD Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations, Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): TSP (PM) PM la PM2,s Equipment Description Overall RequestedCon EfficiencFy' reduction inemtssa SOX NOx VOC CO Other: oxid400r, Mtalyst 75% oxida5 on catayst. 75% oxidation catalyst (HAP) 75%.tormal4ehyde; 50% OtsetHAP Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? TSP (PM) A? 42 PMao PM2,5 9.99E-03 9.45:03 ..Crites IbAAMBtu otlutant Ernissior Uncontrolled: €missions: ('Tonstyear). entory 0.4 0.4 tons year) IWMMBiu AP 42 0.4 0,4 Sox NOx VOC 5,88E-04 IIbeidMBtu i323.4149tu AP42 AP42 0.4 0.02 0,4 0,02 CO gronp.tu manufacturer 1.09 2.30 ht sethp-hr martutacturaCAP 42 manufaciurer 14.7 30.5 8.7 3.7 77 Does the emissions source have any uncontrolled actual emissions of non -criteria Yes D No pollutants (e.g. HAP - hazardous air pollutant.) equal to or greater than 250 lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Formaldehyde 50000 0.53. eiettp-hr Acetaldehyde Acrolein Benzene Other: Criteria` Report le°Pollutant Emissions Inventory Emission Factor Source (AP -42 fi�ltg. etc) 14248 1ncorttro nssions, xidil yea. 75070 107028 71432 1ouena108883 8.36E-03 ib,'.MBlu AP 42 5.14E-03 ICJMMetu AP 42 Gal 1.305.03 . 0FMMBlu 1 8.15E-03 IotMMBtu GRI 1 434 110 639: 353 217 55 344 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 1,12017 Permit Number: 07WE0881 MRS ID Number: 123 /0098 / [Leave blank unless APCD 'has already assigned a yernit F and AIRS II)] Section a - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true acid correct if this is a registration for coverage under general permit GPO2, 1 further certify that this source is and will be operated in full compliance with each condition of general permit GP02. ti/ . 2/2r/l8 Signature of Legally Authorizeson (not a vendor or consultant) Date Ethan Hinkley Air Quality Compliance Manager Name (please print) Title Check the appropriate box to request a copy of the: CI Draft permit prior to issuance Draft permit prior to public notice (Checking any of nese 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, 1I.C. for revised APES requirements. Send this form along with 5152.90 and the General Permit For more information or assistance call: registration fee of S1,500, if applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-BI 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692.3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-231 Reciprocating internal Comoustion Ermine AKIN - Rev sio' 112 17 NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 07WE0881 Company Name: Aka Energy Group, LLC Plant Location: 13472 Weld County Road 40 Person to Contact: Ethan Hinkley E-mail Address: ehinkley@redced'argathering.com AIRS ID Number: 123/0098 County: Weld Zip Code: Phone Number: (970) 764.6495 Fax Number: Chemical Abstract Service (CAS) Number Chemical Name Control Equipment Emission Factor / Reduction (%) (Include Units) methanol n -hexane oxidation catalyst/50% 2.50E-03 lb/MMBtu Emission Factor Source AP42 Uncontrolled Actual Emissions (lbs/year) 211 Controlled Actual Emissions (bs/year) 106 oxidation catalyst/50% 1.11E-03 lb/MMBtu AP42 94 47 Calendar Year for which Actual Data Applies: Signature of Person Le Ily Authorized to Supply Data Ethan Hinkley Name of Person Legally Authorized to Supply Data (Please print) 21* Date Air Quality Compliance Manager Title of Person Legally Authorized to Supply Data Form Reviggn Date, April 14, 2014 GUIDANCE FOR NON -CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM Non -Criteria Reportable Alr Pollutant Emission Notice Addendum: This form must be filed for each emission point (Individual or grouped) that has uncontrolled actual emissions equal to or greater than 250 pounds per year of any non -criteria reportable pollutant listed in Regulation 3, Appendix. B. Permit Number: For New Permit Applications leave this blank. For modifications to existing permits, please list the permit number previously issued by the APCD, AIRS ID Number: For a new Air Pollutant Emission Notice (APEN) or new Permit Applications leave this blank. For modifications to existing APENlperrnits, please list the emissions point AIRS ID number previously Issued by the APCD. Chemical Abstract Service (CAS) Numberand Chemical Name: Please list the CAS number and common chemical name for each non -criteria reportable air pollutant that is emitted from this emission point. A list of CAS numbers and common chemical names may be found in Regulation 3, Appendix B. This can also be found on the chemical Safety Data Sheet (SDS) Control Equipment! Reduction (%): Please list the type of control equipment used (i.e. SCR, NSCR, Flare, Thermal Oxidizer, etc.) and report the minimum percent reduction achieved by the control equipment. Emission Factor: If applicable, please list the emission factor used to calculate the emission rates listed in the actual emission columns, Emission Factor Source: Example emission factor sources include: AP -42, GRI HAP Cale., EPA TANKS, GRI GLY Calc., Manufacturer's Emission Factor, and Mass Balance. Uncontrolled Actual Emissions:: Enter the actual uncontrolled data year (projected first year emissions for new sources) emissions (lbs/year) from the reported emission point excluding any emission reduction achieved by control equipment. Controlled Actual Emissions: If emissions are controlled, enter the actual controlled data year (projected first year emissions for new sources) emissions (lbs/year) from the reported emission point including the emission reduction listed in the "Control Equipment Reduction (%)" column. Enter "N/A" if the emissions are uncontrolled. SUBMITTAL,OF THIS ADDENDUM MUST BE ACCOMPANIED BY AN AIR POLLUTANT EMISSION NOTICE (APEN) All sections of the APEN and Addendum 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 to you or result in longer engineer processing times. Please note there is an APEN filling fee. You may be charged an additional APEN fee if the APEN or Addendum is filled out incorrectly or missing information and requires re -submittal. Copies of this form may be obtained on the Internet under Construction Permit Forms and APENS;http://www.colorado.gov/cdphetapcd form Revision Date: April 14, 2014 Fugitive Component Leak Emissions APEN - Form APCD-203 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application mist be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for fugitive component leak emissions. If your emission source does not fa category, there may be a different specialty APEN available for your operation (e.g. natural gas v condensate tanks, paint booths, etc.). In addition, the General APEN (Form APCD- 200) is available APEN options do not meet your reporting needs. A list of specialty APENs is available 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: 07WE0881 AIRS ID Number: 123 / 0098/014 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Aka Energy Group, LLC Site Name: Gilcrest Gas Plant Site Location: 13472 Weld County Road 40 Mailing Address: 125 Mercado Street, Suite 201 (Include Zip Code) Durango, CO 81301 Permit Contact: Ethan Hinkley E -Mail Address2: ehinkley@redcedargathering.com Site Location Weld County: NAICS or SIC Code: 1321 Phone Number: (970) 764-6495 I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 368517 p COLORADO NW. b Cnr6v�.ew� Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / 014 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source (check one below) -OR - ❑� MODIFICATION to existing permit (check each box below that applies) ❑ Change process or equipment 0 Change company name 0 Add point to existing permit 0 Change permit limit 0 Transfer of ownership3 0 Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑r Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Reduce equipment counts and emission limits for equipment never installed. For Section 5, some equipment services streams with 100% VOC and 0% HAP; see Attachment C for full breakdown. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information For existing sources, operation began on: January 2001 For new or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: 0 Well Production Facility4 ❑ Natural Gas Compressor Station4 0 Natural Gas Processing Plant4 ❑ Other (describe): hours/day days/week weeks/year 4 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 ACOLORADO 2 I � °"PotAs /1auh6 Lwvb®a O Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ 014 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? before August 23, 2011 Will this equipment be operated in any NAAQS nonattainment area?5 0 Yes 0 No Will this equipment be located at a stationary source that is considered a ❑ Yes Q No Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors Yes ❑ No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? 0 Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? El Yes ❑✓ No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? ❑ Yes ❑✓ No Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑ Yes ✓❑ No Is this equipment subject to Colorado Regulation No. 7, Section XII.G?❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ❑ Yes El No 5 See http://www.colorado.gov/cdphe/state-implementation-plans-sips for which areas are designated as attainment/non- attainment. Section 5 - Stream Constituents ❑✓ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. .Y-,,,,y,,,,,,,,,,,,,*A Stream VOC (w BenzeneToluene Ewa - -.nom Ethylbenzene rXylene �Wt % n Hexane wt % 2 2 4 ' ' Tnmethylpentane Gas 25 0.20 0.20 0.01 0.1 1.0 0.01 Heavy Oil (or Heavy Liquid) 100 1.7 2.2 0.05 0.5 12.0 0.05 Light Oil (or Light Liquid) 100 1.7 2.2 0.05 0.5 12.0 0.05 Water/Oil 100 1.7 2.2 0.05 0.5 12.0 0.05 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 ® COLORADO 3 `�gsaux. t.m . * Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ 014 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Geographical Information 40.274538°/-104.802349° Attach a topographic site map showing location Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ▪ LDAR per 40 CFR Part 60, Subpart KKK ❑ Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump ❑✓ Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa ❑ Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 86% light liquid pump, 81% connectors ❑ LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: O No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 4i Ir.COLORADO '.d"f,n-,. Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ 014 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. 0 Table 2-4 was used to estimate emissions'. D Table 2-8 (< 10,000ppmv) was used to estimate emissions'. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: E Estimated Component Count ❑ Actual Component Count conducted on the following date: see Attachment C �€ �il i ."1:•i tt ect r ,.�,.g .°^' lantesa ?�'#.4's'r'i,..£ady.*fx-2wY.kL¢nn2he3`&iSJ+''"Nei:J>r;Ts`f�.fnsz'a 4 ^�r' �.� N ,.,,a ... dd• l.+l".` -.�r. �. v Pum 3ea ...A=.✓! ... ,'� n,. A- al e 1..ei c5n°:i�1N.w1 5<.� ..� s� ,~� E.� e�9 "fr- si-%._-'. ,-s vK��-��?..n -`�� Count8 4082 0 15 0 2040 51 Emission Factor 2.0E-04 3.9E-04 2.0E-03 2.4E-03 4.5E-03 8.8E-03 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component 4"b^ Heavy Oil ,. . . L1 Ill �£ -- Count8 690 0 0 n/a 270 9 Emission Factor 7,5E-06 3.9E-07 1.4E-04 n/a 8.4E-06 3.2E-05 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component iq ig light Oil or Lht :Luid) r , �. Count8 18 0 0 20 95 4 Emission Factor 2.1E-04 1.1E-04 1.4E-03 1.3E-02 2.5E-03 7.5E-03 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component ,t,t'' Water Qr� x ter' .,-..-- Count8 57 0 0 0 24 0 Emission Factor 1.1E-04 2.9E-06 2.5E-04 2.4E-05 9.8E-05 1.4E-02 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The Other equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 51A-'.COLORADO �" Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / 014 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 9 - Criteria and Non -Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: o calculate these emissions.) hemsa ctua Annual;Emissions Requested Annual Permits fission: L imit(s) Die �� a rotted , '(tons/yearj , , n r fled jtvn`s/year) �UncgntroTt�d (tons/year)E Co tro(ted , � {tans/yearj VOC 35.7 14.5 Does the emissions source have any actual emissions of individual non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 ® Yes ❑ No lbs/year? to reoort the non -criteria pollutant (HAP) emissions from source: ernioal::Name ==,-- CAS _. ti. 'Ed -1 An ufal Emissions � € e C. F" 'hh'E tFR-i `hs� .#' 1 �+�i'&'�`r'.fn PlY L" X:,``4>... Requested Annual Permit Emission LimrtC) r > , lum e z Uncontrolle. n??_, Controlled slyear� x: Uncontrolled �sTyear) . Controlled ° x _ ; ibsyear, Benzene 71432 484 202 Toluene 108883 515 218 Ethylbenzene 100414 22 9 Xylene 1330207 220 89 n -Hexane 110543 2638 1122 2,2,4 Trimethvlpentane 540841 22 9 Other: 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 AV COLORADO 6 1 • V == Permit Number: 07W E0881 AIRS ID Number: 123 / 0098 / 014 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally Authorize erso n (not a vendor or consultant) Ethan Hinkley Name (print) .?f fi 7 Date Air Quality Compliance Manager Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance n 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 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 7 1 AMY COLORADO H..Mn 6 Lxronm.n. Fugitive Component Leak Emissions APEN - Form APCD-203 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, includi updates. An application with missing information may be determined incomplete and may be returned longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for fugitive component leak emissions. If your emission source does not fall into this category, there may be a different specialty APEN available for your operation (e.g. natural gas venting, condensate tanks, paint booths, etc.). In addition, the General APEN (Form APCD- 200) is available if the specialty APEN options do not meet your reporting needs. A list of specialty APENs is available 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: 07WE0881 AIRS ID Number: 123 / 0098 / 026 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Aka Energy Group, LLC Site Name: Gilcrest Gas Plant Site Location: 13472 Weld County Road 40 Mailing Address: 125 Mercado Street, Suite 201 (Include Zip Code) Durango, CO 81301 Permit Contact: Ethan Hinkley E -Mail Address2: ehinkley@redcedargathering.com Site Location Weld County: NAICS or SIC Code: 1321 Phone Number: (970) 764-6495 I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 36.8516 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 COLORADO Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / 026 [Leave blank unless APCD has already assigned a permit i# and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source (check one below) -OR - (] MODIFICATION to existing permit (check each box below that applies) O Change process or equipment 0 Change company name ❑ Add point to existing permit O Change permit limit 0 Transfer of ownership3 0 Other (describe below) - OR • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source (] Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: Reduce equipment counts and emission limits for equipment never installed. For Section 5, some equipment services streams with 100% VOC and 0% HAP; see Attachment C for full breakdown. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information For existing sources, operation began on: 6/16/2014 For new or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: ❑ Well Production Facility4 ❑ Natural Gas Compressor Station4 Natural Gas Processing Plant' ❑ Other (describe): hours/day days/week weeks/year 4 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 coteaano 2 I - Department Mv,muk twmc r,wo9...m Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / 026 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? after August 23, 2011 but before September 18, 2015 Will this equipment be operated in any NAAQS nonattainment area?5 E Yes 0 No Will this equipment be located at a stationary source that is considered a ❑ Yes 2 No Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors 0 Yes ❑ No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑ Yes ✓❑ No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? 0 Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? 0 Yes E No Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ✓❑ Yes ❑ No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? ❑ Yes ✓❑ No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? 0 Yes E No 5 See http://www.colorado.gov/cdphe/state-implementation-plans-sips for which areas are designated as attainment/non- attainment. Section 5 - Stream Constituents ❑ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. Stream � VOC (w : Benzene wt Toluene � { 1 vY } :,t Ethylbenzene - w ) Xylene ( N -n Hexane , Icyt:'fb) 2,2,4 ,�Tnmethylpentane . ..IAA %):6'''''`" 0.01 Gas 25 0.20 0.20 0.01 0.1 1.0 Heavy Oil (or Heavy Liquid) 100 1.7 2.2 0.05 0.5 12.0 0.05 (or Light Liquid) Light Oil0.05Water/Oil 100 1.7 2.2 0.05 0.5 12.0 100 1.7 2.2 0.05 0.5 12.0 0.05 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 COLORADO 3 �� NpGh4 La+ue,un-J Permit Number: 07WE0881 AIRS ID Number: 123 /0098/ 014 [Leave blank unless APCD has already assigned a permit d and AIRS ID] Section 6 - Geographical Information eographicat:Coordinates Latitude/Longitude or UTM) _ 40.274538°/-104.802349° Attach a topographic site map showing location Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑✓ LDAR per 40 CFR Part 60, Subpart KKK ❑ Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump ❑✓ Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa ❑ Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 86% light liquid pump, 81% connectors ❑ LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: ❑ No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 4 I A. COLORADO Counts 0 15 Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / 014 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. 0 Table 2-4 was used to estimate emissions'. ❑ Table 2-8 (< 10,000ppmv) was used to estimate emissions'. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑✓ Estimated Component Count ❑ Actual Component Count conducted on the following date: see Attachment C ump Seals- 2040 alves Other9 4082 0 51 Emission Factor 2.0E-04 3.9E-04 2.0E-03 2.4E-03 4.5E-03 8.8E-03 Units kgihr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component Heavy Oil (or Heavy Liquid) Counts 690 0 0 n/a 270 9 Emission Factor 7.5E-06 3.9E-07 1.4E-04 n/a 8.4E-06 3.2E-05 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component Light Oil (or Light Liquid Counts 18 0 0 20 95 4 Emission Factor 2.1E-04 1.1E-04 1.4E-03 1.3E-02 2.5E-03 7.5E-03 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component Water/Oi 1:; Counts 57 0 0 0 24 0 Emission Factor 1.1E-04 2.9E-06 2.5E-04 2.4E-05 9.8E-05 1.4E-02 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component ' Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The Other equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 'COLORADO 5,,: Le Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / 026 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Criteria and Non -Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: U e the data re orted in Section 8 to calculate these emissions. (s P �` " Chemical Name ( .11.� - k:}' 1 x y Fa' y CASE Number �✓.TSwN„ t i... '4' `. v��.. k actual: Annual.l missions _ Requested AnnualPermi �Emission=Limit(s) Uncontrolled �^ . ,,,,,,v.7..Y Xc+�°N �_k Xtons/year) Controlled1° iy. £.-• ₹ , vv t (tons/year) �r..n Y'T.rs Uncontrolled "irons%year) .. - ' Controlled" . .. ..; W (tons/year) VOC 8.4 0.8 Does the emissions source have any actual emissions of individual non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 ❑ Yes ® No lbs/year? If yes, use the following tame to report the non cnler Id pullulain. Ir mr) CI I II3DIVI IJ II VIII ]VW LC Chemical Name t Actual Annual Emissions Requested Annual Permit Emission Limit(s)µ Number Uncontrolled (ibslyear) _ Controlled9 (lbslyear) Uncontrolled (lbs/year) Controlled1° (lbslyear) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4 Trimethylpentane 540841 Other: 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 COLORADO 6 AV; IasOAb fn.aO 19 Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / 026 [Leave blank unless APCD has already assigned a permit H and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally Authorized P n (not a vendor or consultant) erbe Ji'7 Date Ethan Hinkley Air Quality Compliance Manager Name (print) Title Check the appropriate box to request a copy of the: ID Draft permit prior to issuance ID 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, ILG. for revised APEN requirements. Send this form along with $152.90 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 �J�\ COLORADO % �i'�: O %..al w .. Fugitive Component Leak Emissions APEN - Form APCD-203 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 return rein longer application processing times. You may be charged an additional APEN fee if the APEN is fil' incorrectly or is missing information and requires re -submittal. This APEN is to be used for fugitive component leak emissions. If your emission source does not fall into this category, there may be a different specialty APEN available for your operation (e.g. natural gas venting, condensate tanks, paint booths, etc.). In addition, the General APEN (Form APCD- 200) is available if the specialty APEN options do not meet your reporting needs. A list of specialty APENs is available 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: 07WE0881 AIRS ID Number: 123 / 0098 / 036 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Aka Energy Group, LLC Gilcrest Gas Plant Site Location: 13472 Weld County Road 40 Mailing Address: (Include Zip cue) 125 Mercado Street, Suite 201 Durango, CO 81301 Permit Contact: Ethan Hinkley E -Mail Address2: ehinkley@redcedargathering.com Site Location Weld County: NAICS or SIC Code: 1321 Phone Number: (970) 764-6495 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. 368515 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision COLORADO 7/2017 Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action 0 NEW permit OR newly -reported emission source (check one below) -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change process or equipment 0 Change company name El Add point to existing permit ❑ Change permit limit 0 Transfer of ownership3 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t Notes: For Section 5, some equipment services streams with 100% VOC and 0% HAP; see Attachment C for full breakdown. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 11/15/2017 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: ❑ Well Production Facility's ❑ Natural Gas Compressor Station's 0 Natural Gas Processing Plants ❑ Other (describe): hours/day days/week weeks/year 4 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 p COLORADO 2mV 4w Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? after September 18, 2015 Will this equipment be operated in any NAAQS nonattainment area?5 El Yes ❑ No Will this equipment be located at a stationary source that is considered a ❑ Yes 2 No Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors Yes ❑ No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑ Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? ❑ Yes 2 No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? 0 Yes O No Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? 0 Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section k/II.B.3? O Yes 2 No 5 See http://www.colorado.Rov/cdphe/state-implementation-plans-sips for which areas are designated as attainment/non- attainment. Section 5 - Stream Constituents ❑✓ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of -each applicable stream. Streamer-Tnmethylpentane r. v".ZA4, t,,, -r-, VOC ". 3.E ,m .. Benzene :e*x^.^ 'N2. .:L- Toluene i ,rF.. Ethylbenzene wt Sb a.>:+c ., q'=� .. ylene wt 9E;\ ,..�n ..- n Hexane wt %t 5 . x,2,4 i =. ) ,, . Gas 25 0.20 0.20 0.01 0.1 1.0 0.01 Heavy Oil (or Heavy Liquid) 100 1.7 2.2 0.05 0.5 12.0 0.05 Light Oil (or Light Liquid) 100 1.7 2.2 0.05 0.5 12.0 0.05 Water/Oil 100 1.7 2.2 0.05 0.5 12.0 0.05 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 Ay -COLORADO 31 L� 61Pubtic Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Geographical Information 40.274908°/-104.803142° Attach a topographic site map showing location Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK 0 Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump 0 Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑� LDAR per 40 CFR Part 60, Subpart 0000/0000a ❑✓ Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 86% light liquid pump, 81% connectors ❑ LDAR per Colorado Regulation No. 7, Section XVII.F 0 Other6: ❑ No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 .COLORADO 41 V 144.11 Ertutrtmene. Permit Number: 07WE0881 AIRS ID Number: 123 /0098 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ❑ Table 2-4 was used to estimate emissions7. El Table 2-8 (< 10,000ppmv) was used to estimate emissions7. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: 2 Estimated Component Count ❑ Actual Component Count conducted on the following date: see Attachment C t 5"' 4'm Ml"pn sa "YYF rte' �r'a'F +. t�Y'& " "r „h{ ¢kk`1.i'-P �� Egfilpment�yp�� '.£',.,,�Yrr� .m�k ?"P.FE� 3 a 3y!`�«+H Ka' `'""�a.aK i'," Se ic �tS i � �� nectq x ct ," la r> es a� a . O e Ended PW� „ YS Pump Serfs y yt Yalve� s� Other a��4's iyS �"�� av§wz3 }G. 4Y'2Y �{%1Y ` '.'Y.t` �s.a,�-eC''$'4-� �} cl^S '�=G '.l �-""�'-� " ?� '+�.'"'$ ` £fir ' .ib..�.+-Y�'a A _X3 '4e2' 'Y "� W e 'r e i "..n1' B c, 'r? - ., Count8 3401 0 12 0 1699 42 Emission Factor 2,0E-04 3.9E-04 2.0E-03 2.4E-03 4.5E-03 8.8E-03 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component �l-'; ' 44eiT+'h` CtC4 ea, ll % , eavyr Liqui,1}� i4,1�.' tt a iT �0 'F+�P.c. &Ji'+S5rv-v+5'5 W fr e a $v' d`✓c .kK#v"`2` W3m Y .ukF% F Count8 575 0 n/a 225 7 Emission Factor 7.5E-06 3.9E-07 1.4E-04 n/a 8.4E-06 3.2E-05 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component w"��5-s'rsWi3 �' 1 i o ..ig t Liquid) %,a ,aa� .r »e a+�t.e�i- �£-3'c t� r•- Count8 14 0 0 16 79 2 Emission Factor 2.1E-04 1.1E-04 1.4E-03 1.3E-02 2.5E-03 7.5E-03 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component e 11e1:ef/Dili r.,m !"- �"iwx' � v a�`r'{ r �'�AS Z' _ - " 3`.'a a'Y£ _ �} -= _ y- _� 'F' ? {` - ;,, s Count8 47 0 0 0 20 0 Emission Factor 1.1E-04 2.9E-06 2.5E-04 2.4E-05 9.8E-05 1.4E-02 Units kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component kg/hr/component 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The Other equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-2O3 - Fugitive Component Leak Emissions APEN - Revision 7/2017 COLORADO 5 Al.=., ....,, Permit Number: 07WE0881 AIRS ID Number: 123 /0098 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Criteria and Non -Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: in Section 8 to calculate these emissions. 5`^ �� #��'2-ti. #ua Annual .rX=i - 4n-Y'.wi. Emiisstons� ar -- Mgv' '£ Y -- .a' Requested Annual Permit Emission Lmmit{s) £�w'7• its` i_-;-•,---". '3'. g "* t T ChacY 3 ea = amen �? Su F'.�"& urn e co trolled a 1 ut►syea� p Contr�lle �a o s! ear �fif Y ._ . Uncontrolled x ". (tons/years . Controlled s� Rk y~\ = (tons/yearj VOC 29.5 2.9 Does the emissions source have any actual emissions of individual non -criteria pollutants (e.g. HAP- hazardous air pollutant) emissions equal to or greater than 250 ® Yes ❑ No lbs/year? reoort the non -criteria pollutant (HAP) emissions from source: � Cheer I Name � x te a '-. � # ' � _. .x- � Emiss � Actua A0N* io s equested Annual per t.Er isslor Limits) Nurnbei„II plied "Flb year) C ►�£rolled lbs/year`) � „lincontrolled jibs yeaVviv Controlled (lbs/year)�, µr Benzene 71432 400 45 Toluene 108883 426 49 Ethylbenzene 100414 18 2 Xylene 1330207 182 20 n -Hexane 110543 2179 255 2,2,4 Trimethvlpentane 540841 18 2 Other: 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 COLORADO 61. bap:rime. of Palk Permit Number: 07WE0881 AIRS ID Number: 123 / 0098 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signature of Legally Autho ' d Person (not a vendor or consultant) *1(7 Date Ethan Hinkley Air Quality Compliance Manager Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance QQ 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 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2017 Eninronnw Air COLORADO Hello