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Home My WebLink About20172828.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Brian Macke bmacke@srcenergy.com August 7, 2017 Ref: Permit No: 17WE0395 Et 17WE0396 SUBJECT: Draft Permit and Related Public Notice Dear Brian Macke: RECEIVED AUG 1 1 2017 WELD COUNTY COMMISSIONERS The Air Pollution Control Division has prepared a public comment package for the Synergy Resources Corporation - Evans 7-26 Pad. The thirty (30) day public notice period will begin on August 10, 2017. This public notice period is being provided in accordance with the Colorado Air Pollution Prevention and Control Act and Regulation No. 3, Part B, Section III.C. For thirty (30) days from the beginning of the notice period, copies will be available for public inspection at the respective county clerk's office(s). During the thirty -day period, please review your permit and call your permit engineer with any questions or concerns you may have. This application is complete and in proper form. It meets the requirements of the Colorado Air Quality Control Commission's Regulation No. 3, Part B, Section III.B. Sincerely, Betsy Gillard Stationary Sources Air Pollution Control Division Enclosures 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe PO tot; C John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer RP -Ai cc : pLCrnm! TP), HLCUT), 3T), g(al/t7 ecvCC-CZ /CH/Sm/cK) $�l5rl� 2017-2828 COLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 August 7, 2017 Dear Sir or Madam: On August 10, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Synergy Resources Corporation - Evans 7-26 Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Synergy Resources Corporation - Evans 7-26 Pad - Weld County Notice Period Begins: August 10, 2017 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: Synergy Resources Corporation Facility: Evans 7-26 Pad Exploration and production SWNE Sec. 26 T5N R66W Weld County The proposed project or activity is as follows: New oil and gas production well pad servicing 22 on -site wells. Comingled liquid/gas from the wells passes through 22 3 -phase horizontal high-pressure (HP) separators that route gas to a sales pipeline. Produced water is routed to 2 produced water tanks, and condensate from the HP separators is routed to two low-pressure "gas busters" for further separation of gas from condensate. The gas is compressed by 3 vapor recovery units (VRUs) and routed to the sales pipeline. The VRUs are powered by 3 natural gas RICE. The condensate from the gas busters is routed to 16 storage tanks and the water is routed to the produced water tanks. The produced water and condensate tanks route vapors to 4 enclosed combustors. The 16 condensate tanks unload through a lease automatic custody transfer (LACT) unit and into a sales pipeline. In the event of temporary sales oil pipeline inaccessabtlity, the condensate tanks will be unloaded via tanker truck. The facility also has a diesel -fired generator to provide power to the custody transfer meter. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE0395 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: Betsy Gillard Colorado Department of Public Health and Environment ADO 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 21 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Betsy Gillard 361558 4/25/2017 6/21/2017 Company Name: Synergy Resources Corporation County AIRS ID: 123 Plant AIRS ID: 9F21 Facility Name: Evans 7-26 Pad Physical Address/Location: SWNE quadrant of Section 26, Township 5N, Range 66W, in Weld County, Colorado Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing - Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑Carbon Monoxide (CO) E articulate Matter (PM) +❑Ozone (NOx & VOC) Weld Quadrant Section Township Range SWNE 5N Section 02 - Emissions Units In Permit Application AIRs Point44 Emissions Source Type Equipment Name Emissions Control? Permit # Issuance it Self Cert Required? Action Engineering Remarks 001 Condensate Tank TK-1 - TK-16 Yes 17WE0395 1 Yes Permit Initial Issuance 002 Hydrocarbon Liquid loading Yes 17WE0396 1 Yes - ,.. Permit Initial Issuance 003 Produced Water Tank Yes GP08 •, 004 Diesel RICE Yes GP06 005 Natural Gas RICE -- ' Yes GP02 006 Natural Gas RICE Yes GP02 007 Natural Gas RICE Yes GP02 Section 03 - Description of Project New oil and gas production well pad servicing 22 on -site wells. Comingled liquid/gas from the wells passes through 22 3 -phase horizontal high-pressure (HP) separators that route gas to a sales pipeline. Produced water is routed to 2 produced water tanks, and condensate from the HP separators is routed to two low- pressure "gas busters" for further separation of gas from condensate. The gas is compressed by 3 vapor recovery units (VRUs) and routed to the sales pipeline. The VRUs are powered by 3 natural gas RICE. The condensate from the gas busters is routed to 16 storage tanks and the water i s routed to the produced water tanks. The produced water and condensate tanks route vapors to 4 enclosed combustors. The 16 condensate tanks unload through a lease automatic custody transfer (LACT) unit and into a: sales pipeline: in the event of temporary sales oil pipeline inaccessability, the condensate tanks will be unloaded via tanker truck. The facility also has a diesel -fired generator to provide power to the custody transfer meter. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Perini Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? No Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ El ❑ ❑ ❑ ❑ o 0 0 ❑ ❑ ❑ CI O O Condensate Storage Tanks) Emissions Inventory Section 01- Administrative Information Facility AIRs ID: 123. 9F21 001::. County Plant Point Section 02 - Eouioment Description Details Detailed Emissions Unit Description: Emission Control Device Description: 16400 -bbl fixed -roof condensate storage tanks connected by liquid manifold. Four (4)'.enclosed combustors. • Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput 2,101,477 2521,785. 2,521,785 Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2409 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 21.1322 scf/bbl Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = Actual Condensate Throughput While Emissions Controls Operating = :.: 2,101,477. Barrels (bbl) per year 106,981 MMBTU per year 128,378 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 128,378 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Control Device Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Condensate Throughput) (Condensate Throughput) Uncontrolled Uncontrolled (Ib/MMBtu) waste heat combusted) (Ib/bbl) Condensate Throughput) 0:0680: 0.3100:...... Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.S NOR CO 2233.0 1860.9 37.2 2233.0 44.7 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 4.4 3.6 3.6 4.4 4.4 19.9 16.6 16.6 19.9 19.9 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year( (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 6.4995 5.4162 0.1083 6.4995 0.1300 12999 260 9.9232 8.2693 0.1654 9.9232 0.1985 19846 397 0.2610 0.2175 0.0044 0.2610 0.0052 522 10 3.8798 3.2331 0.0647 3.8798 0.0776 7760 155 54.6219 45.5180 0.9104 54.6219 1.0924 109244 2185 , 0.2837 0.2364 0.0047 0.2837 0.0057 567 11 2 of 6 K:\PA\2017\17 W E0395.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Facility attainment -area status has not been established yet Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XI I.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7. Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-0 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section OS - Technical Analysis Notes Emission calculations are from ProMaxsimulation, modeled using a site -specific pressurized'. liquidcondensate off of the gas buster. Sample condensate tanks combusted is from the simulation. Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point rt Process 8 5CC Code 001 OS Uncontrolled Emissions Pollutant Factor Control % Units PM70 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.08 0 lb/1,000 gallons condensate throughput VOC 42.2 98 lb/1,000 gallons condensate throughput CO 0.38 0 lb/1,000 gallons condensate throughput Benzene 0.12 98 lb/1,000 gallons condensate throughput Toluene 0.19 98 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 98 lb/1,000 gallons condensate throughput Xylene 0.07 98 lb/1,000 gallons condensate throughput n -Hexane 1.03 98 lb/1,000 gallons condensate throughput 224 TMP 0.01 98 lb/1,000 gallons condensate throughput 3 of 6 K:\PA\2017\17 W E0395. CP1. xlsm ProMax simulation calculations Er a a 00 00 User -specified condensate throughput 12090.66 std 287.8729 bbl/hr a c 000) w4 �= o} gs I 2 4.3317E-02 Cr t0 O) O) M eel M V) V) n V) V O) V l0 V) lO t0 V) O) a 00 V a -I 0 V) N m c-1 VD N V) C' I, M N0 V V) l0 cH 00 n V CO n 0 V Q N 0 n 0 V) a-1 e-1 l 00 n 0 V N .--� m lL1 N N O lD 0 0 0 0 0 to m a In oo v to co to a -I v 00 V m M O 00 O O) Ln o V) n V) l0 C N 00 00 0 N 00 c0 CO O) V) O ni n N N N CO N a W LD M 01 01 O V) LD N• c -I co H N c-1 ci V c -I en en ey e-i LL 0 N • N N N U Z U U r0 x 0) C 2.79675 0.141513 v a -I m N rn 00 a c-1 V O 0o n O m V) V N N • o N 00 2.72467 0.141676 r >,- .0 a M O) 0 cg Q N O N Ln N n U O To l0 en 00 In c -I LO M W O O V o O O en rn 0 Ci O O O N N a --I 9 00 00 H co n M N n 0 n v N VD N n Q 00 CO L0 0 o o "' o I') N 00 N 0 01 0 O Cr V N 0) C a a) c > IT v c m _ ✓ C 3> @ U U N m H w X > > 002 Truck Condensate Loadout Calculations AP -42: Chapter 5.2 Equation 1 L = 12.46*S*P*M/T L = loading losses in lb per 1000 gallons loaded S = Saturation Factor P = true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T = temperature of bulk liquid loaded [deg. R] 1 degree Fahrenheit = 460.67 degree Rankine S P M T L Source 0.6 Submerged loading: ded AP -42 4.21 psia 44.14 lb/lb-mole 528 deg. R 2.63 lb/10^3 gal 1.11E-01 lb/bbl Annual requested Throughput Annual requested VOC emissions ProMax/AP-42 ProMax Field Data 252167 BBL/yr 10591014 gal/yr 27867 lb/yr 13.93 tpy Regulatory Considerations This facility is not condisdered a terminal (in Reg. 7) because average daily throughput will be below 20,000 gallons at 691 gallons per day. This facility is not considered a bulk plant (in Reg. 7) because it does not distribute gasoline. NCRPs HAP mass fractions are from ProMax W&B stream Component Mass Frac. lb/yr Emission Factor Reportable? Benzene n -hexane Touene Xylenes 0.00186 51.83 0.000206 lb/bbl N 0.0222 618.64 0.002453 lb/bbl y 0.00298 83.04 0.000329 lb/bbl N 0.00117 32.60 0.000129 lb/bbl y CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0395 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Synergy Resources Corporation Evans 7-26 Pad 123/9F21 SWNE SEC 26 T5N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 - TK-16 001 16 400 -barrel fixed -roof storage vessels used to store condensate Enclosed Flares This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Divimon Page 1 of 8 3. his per ;t s;�re if the er or ., �.r of th ource for which this permit was issued: on or eration of this source within 18 months ssua of's construcn permit or the date on which such s sch ` led commenc as set forth in the permit application ociated w" is". i (ii) sc:n 1'u -s const u .n for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TK-1 - TK-16 001 -- 4.4 44.7 19.9 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-1 - TK-16 001 Enclosed Flares VOC and HAP COLORADO Air Pollution Control Division IT Page 2 of 8 8. e to Process Limits ximum''rocessing rates as listed below. Monthly I be maint.' ed by the owner or operator and made equest-s lation Number 3, Part B, II.A.4.) Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-1 - TK-16 001 Condensate throughput 2,521,785 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The source is subject to Regulation Number 7, Section XII.G. The operator shall comply with all applicable requirements of Section XII. 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If COLORADO Air Pollution Control Division Page 3 of 8 14 he .d.a ivision u is use• ust h. where bust hall Row ¢ e ins' in r cords •:. he i • esign n vice ha ction requi .ections fo requ�"°• is c:"'"' • ' -quirement u the storage tank commences operation. struction efficiency of at least 98% for een authorized by permit prior to May ents of Regulation Number 7, Section eriod of two years, made available to e met within 90 days of the date that 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OI:'tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.O.7. ) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) 18. A source initial compliance test shall be conducted to measure the emission rate for volatile organic compounds (VOC) in order to demonstrate compliance with a minimum destruction efficiency of 98% for VOCs. The test shall determine the mass emission rates of volatile organic compounds at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. (Regulation Number 3, Part B., Section III.G.3) Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or COLORADO Air Pollution Control Division Page 4 of 8 per year, whichever is less, above the ivision. • • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal Whenever there is a change in the owner or operator of any facility, process, or activity; or COLORADO Air Pollution Control Division Page 5 of 8 By: ment), -121 (injunctions), -122 (civil Betsy Gillard Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation COLORADO Air Pollution Control Division Page 6 of 8 1) Th +ermit de =. r lred t• • : p •cessin ime for this permit. An invoice for these fe ill b='sue• :fte due p mit is ued he permit cyder shall pay the invoice within 30 days of R of ; re invoic-= t result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) 001 Benzene 71432 12,987 260 Toluene 108883 19,846 397 Ethylbenzene 100414 522 10 Xylenes 1330207 7,767 155 n -Hexane 110543 109,237 2,185 2,2,4- Trimethylpentane 540841 567 11 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0035 0.0035 AP 42 Table 1.4-1 CO 0.0158 0.0158 VOC 1.771 0.0354 ProMax simulation based on site - specific pressurized liquid sample 71432 Benzene 5.15E-03 1.03E-04 108883 Toluene 7.87E-03 1.57E-04 100414 Ethylbenzene 2.07E-04 4.14E-06 1330207 Xylene 3.08E-03 6.15E-05 110543 n -Hexane 4.33E-02 8.66E-04 540841 2'2'4 Trimethylpentane 2.25E-04 4.50E-06 Note: The controlled emissions factors for this point are based on the flare control efficiency of 98%. COLORADO Air Pollution Control Division Page 7 of 8 6) In thi AP th a i: ed with at (303)-692-3150. 7) This permit fulfills the requirement control device per the Colorado applicable. 8) This facility is classified as follows: tha ice to any utant E, 'ssion Notice (APEN) associated with date i as received by the Division. A revised efore the e -year term expires. Please refer to e the APEN iration date for each emissions point io r-garding ."•-cific expiration date call the Division to hold a valid permit reflecting the storage tank and associated Oil and Gas Conservation Commission rule 805b(2)(A) when Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, total HAPs, n -Hexane, Toluene NANSR Synthetic Minor Source of: VOC, NOx MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 8 of 8 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0396 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Synergy Resources Corporation Evans 7-26 Pad 123/9F21 SWNE SEC 26 T5N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LDG-1 002 Truck loadout of condensate during temporary periods when sales oil pipeline is inaccessible None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/ pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division Page 1 of 7 3. his p y mi „"expir y;he o - •r optor of the source for which this permit was issued: modif;::',.tion or operation of this source within 18 months e of thi construction permit or the date on which such duled to ommence as set forth in the permit application ociat h" `• r °` conti ki ''construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO LDG-1 002 -- -- 13.9 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LDG-1 002 Condensate Loaded 252,167 barrels The owner or operator shall calculate monthly process rates based on the calendar month. COLORADO Air Pollution Control Division Page 2 of 7 shall be determined on a rolling twelve (12) month e -month total is calculated based on the previous all calculate throughput each month and keep a ffice with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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 XVI1.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Ft 4.) 9. 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) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 12. 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. OPERATING & MAINTENANCE REQUIREMENTS 13. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: COLORADO Air Pollution Control Diviswon Page 3 of 7 ns per year, a change in actual emissions of five level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 17. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 18. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 19. 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. 20. 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. 21. 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 COLORADO Air Pollution Control Division Page 4 of 7 olora. Air Quality Control Act and regulations of the Air nclud failure to meet any express term or condition of permit, onditions imposed upon a permit are contested by on revo s a permit, the owner or operator of a source may or re.f the Division's action. 22. 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. 23. 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: Betsy Gillard Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation COLORADO Air Pollution Control Division Page 5 of 7 Notes Per H ® :, the of th . mit i ance: 1) Th ` o rr requ'--pays a or th rocessing time for this permit. An invoice for these fe will „ is d er e p _ it I issued. T permit holder shall pay the invoice within 30 days pay t voice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) 002 n -Hexane 110543 619 N/A Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.110 N/A AP 42 110543 n -Hexane 2.45E-03 N/A The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 4.21 psia M (vapor molecular weight) = 44.14 lb/lb-mol T (temperature of liquid loaded) = 528 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the WEtB stream from ProMax by the VOC emission factor. 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 COLORADO Air Pollution Control Division Page 6 of 7 as at 7) Th co a 8) This facility is classified as follows: arding a specific expiration date call the Division permit reflecting the storage tank and associated Conservation Commission rule 805b(2)(A) when Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, total HAPs, n -Hexane, Toluene NANSR Synthetic Minor Source of: VOC, NOx MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 7 of 7 [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] H Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01— Administrative Information E L. a c A C. • ❑ ❑ ❑ L O O. W H d W a) o A^° O '-a c O z d Q . L wd ° A u L L — SO W F� G' h v, V u a) u cr or O O O czz❑ c3.4) ❑❑ Change company name Transfer of ownership ® ❑ ❑ 'O 3 Change process or equipment a) w CT N r 7 Change permit limit O N DD APEN Submittal for Permit Exempt/Grandfathered source APEN Submittal for update only (Please note blank APEN's will not be accepted) ❑ ❑ Section 03 — General Information N N r. r I® a) y 0 0 O • ca,.C 'O x _o YRIL u N •O a) O a) Y U cA c O co to C. ro -o Y a) Cl.. a. co r v; O .•�.x U U a) O 0 . co y oO. c .O 'O w O a''‘o .a''‘ N co W v x ..O O R cci y c... L.T. %, O O 'Q� � z cn 0 zz DO O O Ca W -o o y o a) ®® U CL 0 w A O O a`• a) a) cc a? v, O C) 9 .° E F3 U 6-• U a`• cC `� C ��U o L O \ co .0 C O �O .0 A 1 0 00 OL 0 0. o G a. O .O O o O 00 y O a) cep 2U 9 ) o .. C' ..o o a c WO w C c N >, E' c: co O v, O [z aE C o te) .O .D cal C C �... ° ® °,0 ° a., A I E .1 O V. 'd 03 00 .P' R tl a..� r,.c mF" a) w W :0 a) C 0 a) C .C+ W O 6.0 A o Pr '≥ o A C o a) L E " i C U R y O A .C 'C 7 R O a Ud C R O. y �• .� Q ,�T �`' - 2 'U^ O L 1- W f' Ii C as ow W ��^ 69 —W o f c oio Q A 8...'-'2, a) c.--j. 0 EE R 'x 0 E O aa Z W cn °s es ear i u _ Z . . to a R a) U �^ L .O O N ¢, O. R C 7 O Ci) O. 0 O v " y A, E •y 4.".. o N a); °°o. g �M o > 7 -9 .9 toOw.4 W C; A ,��.i A N i 1r 0 E• c R L 3 0 = 0o a) o o „ o y .. y C R E 4. 6 L. N CO ¢ N 3 _ od.��Cli sU 'a•o o cal O E +'C.. E v y (� U d E pP:i rat Ea=a �.N`6UO'o 04 a 7.'1 O. .'.R„>,00,awrp,.,d 0....E a a c� "w 4.. L d"rA w v� Q A O R E 0 L C C L' Y ' / 1l, co � 0 O L C. C. / HZ o a) 0.., o {i aci eO L* 1 LN S =,‘..., or, Er,CV C. Oyp C, 4 y d .�-I 6.e W L' cXII ::-.% ni ermitstatus a) _O .O 0 -- 4e -e; O a) 0 O O O U• cat a) d N O a) a' a) ell C N L. bl O vi . 0 C O L C U X [ > a) `' O O 7 0 E R ( p p. C/1 O H .0.g >, ' �, I bl O C O i a vui. 7 a) .. E C 0 Q¢ Op C C C. •X C L O O N 00 y.,° id ... V ) a) "CI O L) ua) Requested Permit Limit: RVP of Sales Oil ❑ External Floating Roo nal Floating Roof: Fixed Roof: N O O N 0 ://www.colorado AP Form-APCD-205-Condensate-Tanks-APEN.doc N w O a) 0 FORM APCD-205 Permit Number: C) 0 r rn D 0 N V) M z L 00 V O °i -r4 O1 C (Qs mow, C) t O Width (inches) = 0 Vertical O Vertical with obstructing raincap ❑ Circular: Inner Diameter (inches) = Exhaust Opening Shape & Size (check one): Section 07 — Control Device Information E&P Sites Onl Information aration Technolo L C) 7 O C) C7 L C ea R C. u R s C. .ti 0 R R C. aJ h R L C ee C 0 Cc r O b0 pi . C) R C. d C) s O C• N 1 M 'C d a, 0 o ect cn O a) 0 W cel • 'fl 0 0 a. C) rn C) a) 0 cn a. v d cd CID 0 ti 7 w 0 t0. 7 a) a. C) Section 08 — Gas/Li Please describe the separation process between the well and the storage tanks: C O Ca E W C) L C O U C O C, E Ll C O end C- W C O C C) C C O .C, E C O u a) '7 .2 0 C d C A L C) GC. C O S El Emission Factor Data Source AP -42 ProMax I AP -42 ProMax - ProMax ProMax ProMax ProMax [ ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions T Controlled (Tons/Year) 2 M R 44.66 01 00 rte„ M •'• co O N 0 .C. O 0 00 O 0.—, O1 O .. O co Uncontrolled (Tons/Year) N/A 2,232.93 Q Z O V') s.0 9.92 VD N 0 Li 00 00 ei:47 eI i', .s.6' 11 CO N O Actual Calendar Year Emission Controlled (Tons/Year) 3.64 37.22 in ., O 0.17 © O © O ON O O O Uncontrolled (Tons/Year) N/A N N so oO .. V/AI R kA 8.27 0.22 en N M 45.52 N O Emission Factor Units Ib/MMBtu L CC 7 ieii .D O 22 L .0 O O z L O .0 O CD Uncontrolled Basis Co O O ..= ^'^ eninN O M 0 .. vi M o W N of c N O e-i M c CO O en N a M M v 7 4 In N ri Pollutant xOIsl VOC O U Benzene Toluene U u y N s C W Xylenes n -Hexane a C C U a s 0 H N N L W e O L CL cn R • E To 6 a: d u C. 1. L u C d R O 7 0 C U G d R G u E '° °u w C C .y u C 0 — V C. s R u cl 4 aJ 3 3 c a, E O U 7 E'° L . C C O R L Y ^O s e .= 6al u C L O 7 C.+ o con O t E wo `" .E R as a) L W L u`" 00 O L L r o 1 •• Director of HSE Brian Macke 7 C) H El O 0 L • 0 O a U O T C) C) a 0 J C) 7 v c U a ° A G G 0 A C- N C) 0 C U C) a c 0 7 C) 0 0 C) E 0 'O Cd E d O S a) 0. c 0 Y A H s C) C) N 0 an 0 C C Y 3 15O' U 0 S C) 0 C) w C c 0 N S z H W t C) C) Q El El AP Form-APCD-205-Condensate-Tanks-APEN.doc N O N a) FORM APCD-205 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Synergy Resources Corporation Source Name: Evans 7-26 Pad Emissions Source AIRS ID2: i 2 3 /1;74 / 00 I Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 41463 Evans ION -14C -L 05 - 123 - 41464 Evans 24C -14-L .1 05 - 123 - 41465 Evans 24N -14B -L , 05 - 123 - 41466 Evans 29C-14-XR 05 - 123 - 41467 Evans 24N -14A -L 05 - 123 - 41468 Evans 4N-14C-XR 05 - 123 - 41469 Evans 9C -14-L /1 05 -123 - 41470 Evans 29N-14C-XR 05 - 123 - 41471 Evans 4N-14B-XR .1 05 - 123 - 41472 Evans 10N -14A -L .4 05 - 123 - 41473 Evans 25C -14-L �5 05 - 123 - 41474 Evans 4C-14-XR •4 05 - 123 - 41475 Evans 24N -14C -L .1 05 - 123 - 41476 Evans 11N -14C -L @ 05 - 123 - 41477 Evans 29N-14A-XR •1 05 - 123 - 41478 Evans ION -14B -L 4 05 - 123 - 41479 Evans 30N-14B-XR •4 - - ❑ - - ❑ - - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If tL. is is a newly report source that has not been assigned an AIRS ID by the APCD, enter Ii a: tiJ h .b N/A Form APCD-212 AP FormAPCD-212-EP-StorageTank-APEN-Addendum.docx Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I 1 WEG 361AIRS ID Number: 123 /61 Fat / OO Z [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Synergy Resources Corporation Site Name: Evans 7-26 Pad Site Location: SWNE Sec. 26 T5N R66W Mailing Address: (Include Zip Code) 1675 Broadway, Suite 2600 Deriver, CO 80202 E -Mail Address': brrkacke@srcenergy.com Gz Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Brian Macke Phone Number: (720) 616-4300 Use the full, legal compay name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 12/2016 Departuicnt COLORADO N+.,.6 Frv�Pmnt O1, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action E NEW permit OR newly -reported emission source Request coverage under traditional construction permit -OR - ❑ Request coverage under General Permit GP073 ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ill Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 In addition to the APEN filing fee ($152.90), a General Permit fee of $250.00 will be assessed. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Contingency truck load out of condensate from storage tanks. Facility equipment Identification: For existing sources, oration began on: For new or reconstructel sources, the projected start-up date is: z LDG-1 / / 1 /23 / 2017 Will this equipment b6dperated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? c Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 D Yes ❑ No ❑ Yes No ❑ Yes [] No ✓❑ Yes ❑ No ❑ Yes ✓❑ No ❑ Yes ❑✓ No ❑ Yes ✓❑ No ®V COLORADO 2 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: Condensate ❑ Crude Oil D Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: 66 Requested Volume Loaded5: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth 25216-4 Bbl/yr Actual Volume Loaded: This product is loaded from tanks at this facility into: tank trucks (eg, "rail tank cars" or "tank trucks") 210, HG Bbl/yr If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0 6 Average temperature of bulk liquid loading: G Q Q 6 V 8 ° F True Vapor Pressure: 4.21 Psia @ 60 ° F Molecular weight of displaced vapors: ^ ^ , 44 15 Lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth Bbl/yr Actual Volume Loaded: Bbl/yr Product Density: Lb/ft3 Load Line Volume: d ft3/truckload Vapor Recovery Line Volume: ft3/truckload i,i t'i Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 ®V COLORA00 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit /4 and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.372646, -104.745635 3x Operator, Stack ID,No `" Discharge Height AboYe Gft 'd L`e elf (Feet).. t a F Temp x F) v ' Flow„... ai ACFM) �x �r # Velocity � (ft/secj Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: Rating: Type: Requested Control Efficiency: MMBtu/hr Make/Model: )Ni)Onufacturer Guaranteed Control Efficiency: EMinimum Temperature: t' �a Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating: Waste Gas Heat Content: Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: 0/0 Form APCD-208 Hydrocarbon Liquid Loading APEN - Rev 12/2016 ®® COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes E No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO,, CO VOC HAPs Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate 0.236 Lbs/BBL ❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2017 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emission ` F,_t'1- Requested Annual Permit Emission Ltmit�s) Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX ;i NO„ CO Pa e VOC F 11.10E-01 Ibs/bbl ProMax 11.61 11.61 13.93 13.93 Benzene `t .06E-04 Ibs/bbl ProMax 0.02 0.02 0.03 0.03 Toluene ; r ;)3.30E-04 lbs/bbl ProMax 0.03 0.03 0.03 0.03 Ethylbenzene P '9.24E-06 Ibs/bbl ProMax 0.00 0.00 0.00 0.00 Xylenes 1.29E-04 Ibs/bbl ProMax 0.01 0.01 0.02 0.02 n -Hexane 2.45E-03 Ibs/bbl ProMax 0.26 0.26 0.31 0.31 2,2,4-1.25E-05 Trimethylpentane ylp Ibs/bbl ProMax 0.00 0.00 0.00 0.00 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O8 Hydrocarbon Liquid Loading APEN - Rev 12/2016 i AV COLORADO 5 H..Pi�bbisr7=„ Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 4/21/17 Signature of Legally Authorized Person (not a vendor or consultant) Date Brian Macke Director of HSE Name (print) Title Check the appropriate box to request a copy of the: Ej Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along witlil$152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 6 I AVCOLORADO '=,%'17,� a :�, Hello