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Home My WebLink About20173984.tiffCOLORADO Department of Public Health Et Environment Dedicated to protecting andimproving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 November 17, 2017 Dear Sir or Madam: RECEIVED NOV 2 2 2017 WELD COUNTY COMMISSIONERS On November 30, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Longs Peak Resources, LLC - Motu 28-21-16-1CH. 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 A300 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 Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer vreW ea' PLCYYIM(TP), HLC-a—r). (NA) a /C H /Sr() 3 tttea/ I7 2017-3984 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Longs Peak Resources, LLC - Motu 28-21-16-1 CH - Weld County Notice Period Begins: November 30, 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: Longs Peak Resources, LLC Facility: Motu 28-21-16-1 CH Well production facility SESE Section 28 T12N R65W Weld County The proposed project or activity is as follows: Well production facility in the ozone attainment area in Weld County. Permitted points are a generator engine, crude oil storage, crude oil loadout, separator venting, and produced water storage. 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 IILC.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permits 17WE0741, 17WE0742, 17WE0743, 17WE0806 and 17WE1075 have been filed with the Weld County Clerk's office. A copy of the draft permits and the Division's analyses are available on the Division's website at https: / /www.colorado.gov/ pacific/ cdpheJair-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: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Colorado Air Permitting Project fenttng Project Details Review Engineer: Package 8: Received Date: Review Start Date: Section 01- Facility Information Company Name:• County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? L3EI_&_ivattr ai: s Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? carbon Monoxide (CO) wholesale revision rec'd 10/11/17 SESE quadrant of Section 28, Township 12N, Range 6 Explarat an 8t!?rtxlu W, in Weld County, Colorado Section 02 - Emissions Units In Permit Application Weld Quadrant ( Section 28 Township Range articulate Matter (PM) [Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Required? Self Cart Action Engineering Remarks s;:ss #ttGl 15 / \ 17WEQ74I,:. issuanl 17W10743 17WE074:4 1 Section 03 - Description of Project Section 04- Public Comment Requirements Is Public Comment Required? 4" ,f* If yes, why? ,eater tt a Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes; for what pollutants? "` If yes; attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is thisstationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes; explain•what programs and which pollutants here: - 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 O O ❑ ❑ ❑ ❑: O. L7 0 ❑ SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ O O ❑ ❑ O Of ❑ Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID Longs Peaks Resources, LLC Motu 28-21-16-1CH SESE Section 28 T12N R65W GEN1 Permit No. AIRS Review Date Permit Engineer 17WE0741 123/9F4A/001 08/22/2017 Andy Gruel Requested Action Issuance No. New permit/newly reported emission 1 Emission Point Description One (1) PSI, Model 11.1L, Serial Number TBD, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 302 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for power generation. Natural Gas Consumption Requested (mmscf/yr) 18.52 Requested (mmscf/m) 1.57 Fuel Heat Value (btu/scf) 1476 BSCF (Btu/hp-hr) 10334 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 8760 Uncontrolled Controlled NOx AP -42; Table 3.2-3 (7/2000); Natural Gas Specified by Applicant VOC Manufacturer's Spec No VOC Control CO AP -42; Table 3.2-3 (7/2000); Natural Gas Specified by Applicant Formaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Formaldehyde Control SOX AP -42; Table 3.2-3 (7/2000); Natural Gas No Control TSP AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM10 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control Other Pollutants AP -42; Table 3.2-3 (7/2000); Natural Gas No Control Point Summary of Criteria Emissions (t Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 30.21 2.92 30.21 90.3% VOC 2.04 2.04 2.04 0.0% CO 50.85 5.83 50.85 88.5% SOx 0.01 0.01 0.01 0.0% TSP 0.27 0.27 0.27 0.0% PM10 0.27 0.27 0.27 0.0% PM2.5 0.27 0.27 0.27 0.0% Total HAPs* 0.44 0.0% `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 (l6/yr HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 560 560 560 0.0% Methanol * * 84 0.0% Acetaldehyde * * 76 0.0% Acrolein * * 72 0.0% Benzene * * 43 0.0% 1,3 -Butadiene * * 18 0.0% Toluene * * 15 0.0% *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 New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source Reg 7 XVII.E Standards (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg 7XV1.B (Ozone NAA requirements) applies? No MACT ZZZZ (area source) Is this engine subject to b1ACT 7777 area Yes source requirements? NSPS JJJJ Is this engine subject to ASPS JJJJ? Yes Note: JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes Applicant did not provide manufacture/construction date, so for purposes of NSPS/MACT applicability I will assume the date of operation at this site as reported on APEN. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Longs Peak Resources, LLC 123 9F4A Motu 28-21-16-1CH History File Edit Date Ozone Status 1 0/2712 01 7 Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H28 SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 • 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 O.0 001 17WE0741 PSI, 11.1L, sn: TED. 302hp 0.3 0.3 30.2 2.0 50.9 0.4 2.9 2.0 5.8 0.4 "GEN1" 002 17WE0742 Crude oil loadout to tank trucks 7.8 0.1 7.8 0.1 Default EFs for crude; not controlled 003 17WE0743 Crude oil storage tanks, 1600bb1 1.9 1,225.5 8.8 48.7 1.9 61.3 8.8 2.4 SSEFs accepted 004 17WE0606 Separator venting 6.0 1,883.5 27.5 70.1 6.0 94.2 27.5 3.5 SSEFs accepted 005 17WE1075 Produced water storage 29.8 3.3 29.8 - 0.2 Initially requested GP08, then shifted to CP per revisions reed 10/11/17. Default EFs. APEN-Exempt / Insignificants: Heater -Treater 0.2 0.01 0.1 0.0 0.2 0.01 0.1 0.0 Fugitives 0.1 0.0 0.1 0.D Condensate tank "FLR TANK" 0.7 0.0 0.7 0.0 Collects condensate from secondary separator; XA when applying default EFs for condensate Condensate loadout "LOAD2" 0.01 0.0 - 0.01 0.0 Using default EF for condensate loadout Pump engine - PSI 11.1L 1.7 0.1 2.9 0.0 1.7 0.1 2.9 0.0 "GEN2" — max runtime 250 hr/yr; used only during startup of pump FACILITY TOTAL 0.3 0.3 0.0 0.0 40.0 3,149.4 0.1 90.2 122.7 0.0 0.0 0.0 0.0 12.8 195.9 0.1 45.1 6.7 VOC: Major (OP), Syn Minor (PSD) NOx: Minor (P6O and OP) CO: Minor (PSD and OP) HAPS: Syn Minor- benzene, toluene, n -hexane and total HH: Syn Minor ZZZZ: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 38.2 3,148.6 0.0 87.1 122.7 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 6.7 Excludes units exempt from pemrits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 Pubcom required because of new major source, and VOC emissions increase over 50 tpy Note 1 Total VOC Facility Emissions (point and fugitive (A) Change in Total Permitted VOC emissions (point and fugit ve) 196.0 Facility is NOT eligible for GP02 195.1 Revised APENs were rec'd Oct 11, 2017, which replaced the revisions from Aug 31, 2017 and the original application from July 14, 2017. Note 2 Page 1 of 2 Printed 10/30/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - I-IAPs Company Name Longs Peak Resources, LLC County AIRS ID 123 Plant AIRS ID 9F4A Facility Name Motu 28-21-16-1CH Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S ''a"�-a TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 13139 3241 324 771 72797 7095 48.7 004 17WE0806 Separator venting 8886.2 22862.24 7670.79 9824.18 86024.03 4995 70.1 005 17WE1075 Produced water storage 1591 4999 3.3 APEN-xempt I lnsianificapts: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTAL f tpy) 0.3 0.0 0.0 11.8 13.1 4.0 5.3 82.0 0 6.0 0.0 0.0 122.7 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S '"" — TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil Ioadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bbl 657 162 16 39 3640 355 2.4 004 17WE0806 Separator venting 444 1143 384 491 4301 249.75 3.5 005 17WE1075 Produced water storage 80 250 0.2 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTALiitpy) 0.3 0.0 0.0 0.6 0.7 0.2 0.3 4.2 0.0 0.3 0.0 0.0 6.7 2 1239F4A.xlsx 10/30/2017 Colorado Air Permitting Project Section 05 - Ambient Air Impact Analysis Requirements Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: wholesale revision rec'd 10/11/17 SESE quadrant of Section 28, Township 12N, Range 65W, in Weld Coun Type of Facility:. Exploratipn St_Prtuirzctiorr? What industry segment? Citl VissiD as ductton Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? carbon Monoxide (CO) Section. 02 - Emissions Units In Permit Application articulate Matter (PM) Quadrant, Section Township Range ,Colorado 00zone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks \V 10E ,TENS Ve 17WE0741 CPI Yes Y� YeS \� al IN 002;;;- ;',,:,*:&4&-,:-,,,,r � ` 14,0C-dm-boni r oadlrg LOAD1..; lug S74ifF0742 CP1 a: rrtiltt ttti f son O03 i 44 � . TA it S .. fires 17WE0743 CPI � 11 ,11j3110Q ,. Separa c/%TJ� 51=r�AR/ TOR Yes YW I7A I P2 : Aqr t € ,', 05 33 3111 %j/ r. `1 7 d V�ater //•;"„// P (QD �t l R 1' 1tii`''�T�� i s/ l 37 E Q?5' 3 �•: ] 113 3 11 ... 3 C b 31311111 3> v �� Yes ,, / \\ i ; i$aU t'StY.�u O Perm+t exemtrt ar R BI E3ui but re#)Up$ting 17eC1Tl it for f �.k eEt#ALC£8kll@)JCfli ,.� � Section 03 - Description of Project ai-s,:water, pipeline avail Section 04 - Public Comment Requirements • ,Is. Public Comment Required? If yes, why? Was a quantitative modeling analysis required? . If yes, for what pollutants? If yes, attach a copy of Technical -Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? . . Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) - Non -Attainment New Source Review (NANSR) Is this stationary source a major source? - If yes, explain what programs and which pollutants here: 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 0 0 0 0 0 ❑` ❑ ❑ - ❑ ❑ 0 ❑, ❑ © 0 SO2 NOx CO VOC PM2.5 • PM10 TSP HAPs ❑ ❑ ❑. U ❑ O ❑ ❑ O 2 .❑ ❑: 0 Hydrocarbon Loadout Emissions Inventory Section 01- Administrative Information 1FasilkyArts ID: County Plant Point Section 02 -Equipment Descrption Details Detailed Erifissions Unit Description. Emission Control Device _. Description: Is the loadout controlled? Requested Overall VOC & HAP Control Efficiency %: 0.00 Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadaut' Actual Volume Loaded= Requested Permit LimitThroughput= Potential to Emit (PTE) Volume Loaded= Secondary Emissions -Combustion Devices) Heat content of waste gas= Volume of waste gas emitted per year= Actual heat content of waste gas routed to combustion device= Requested heat content of waste gas routed to combustion device = Barrels (bhp per Rear Barrels (bbi) per year Raring (bhl) peryear :'.':..Btu/scf- scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device= Section 04 -Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged flli? Section 05- Emissions Inventory 17WE0742 Actual Volume Loaded While Emissions Controls Operating= NOT CONTROLLED MMBTU per year MMBTU per year MMBTU per year The state default emissions factors may be used to estimate stuns. ' Criteria Pollutants Potential to Emit Uncontrolled Irons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/rear) Item/year) PM10 PM25 SOx NOx VOC CO 7.80 0.00 0.00 Aso 7.80 Hazardous Air Pollutants Potentialto Emit Uncontrolled (Ibs/yearl Actual Emissions Uncontrolled Controlled (Ibs/rasnl - (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lhs/year) Ilbs/yearl Benzene Toluenw Ethylbenzene Xylene n -Hexane 224 TMP 27 0 0 27 27 240 0 0 240 240 loft K:\PA\2017\17WEO742.XP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 06 -Regulatory Summary Analvsls Regulation 3, Parts A, B Source requires a permit RACT-Regulation 3, Part B, Section II.D.2.a Ste is in attainment and not subjectto PACT (See regulatory applicability worksieet far detailed analysis) Section 07 -lni4al and Periodic Sampling and Testina Requirements You have Indicated above the soursx is not controlled. The following question does not require an answer.. Section 09-lnventorySCC Coding and Emissions Factors AIRS Point# 002 Proeoss# SCC Code 01 4-06-001,52 Crude Oil: Submerged Loading Normal Service (5--0.6) Uncontrolled Emissions Pollutant Factor Control% trolls VOC 2.4762 0 lb/1,000 gallons transferred Benzene 0.0043 0 lb/1,000 gallons transferred n -Hexane 0.0301 ,G lb/1,000 gallons transferred 2 of 2 K:\PA\2017\ 17WE0742XPlxlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Longs Peak Resources, LLC 123 9F4A Motu 28-21-16-1CH History File Edit Date Ozone Status 10/27/2017 Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO. Total HAPs PM10 PM2.5 H2S SO2 - NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL _ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.D New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 171A/E0741 PSI, 11.1L, sn: TED. 302hp 0.3 0.3 30.2 2.0 50.9 0.4 2.9 2.0 5.8 0.4 "GEN1" 002 17WE0742 Crude oil loadout to tank trucks 7.8 0.1 7.8 0.1 Default EFs for crude; not controlled 003 17WE0743 Crude oil storage tanks, 16OObbl 1.9 1,225.5 8.8 48.7 1.9 61.3 8.8 2.4 SSEFs accepted 004 17WE0806 Separator venting 6.0 1,883.5 27.5 70.1 6.0 94.2 27.5 3.5 SSEFs accepted 005 17W01075 Produced water storage 29.8 3.3 29 8 0.2 Initially requested GP08, then shifted to CP per revisions recd 10111/17. Default EFs. APEN-Exempt / Insignecants: Heater -Treater 0.2 0.01 0.1 0.0 0.2 0.01 0.1 0.0 Fugitives 0.1 0.0 0.1 0.0 Condensate tank "FLR TANK" 0.7 0.0 0.7 0.0 Collects condensate from secondary separator; XA when applying default EFs for condensate Condensate loadout "LOAD2" 0.01 0.0 0.01 0.0 Using default EF for condensate loadout Pump engine - PSI 11.1L 1.7 0.1 2.9 0.0 1.7 0.1 2.9 0.0 "GEN2" — max runtime 250 hr/yr; used only during startup of pump FACILITY TOTAL 0.3 0.3 0.0 0.0 40.0 3,149.4 0.1 90.2 122.7 0.0 0.0 0.0 0.0 12.8 195.9 0.1 45.1 6.7 VOC: Major (OP), Syn Minor (PSD) NOx: Minor (PSD and OP) CO; Minor (PSD and OP) HAPS: Syn Minor- benzene, toluene, n -hexane and total NH: Syn Minor ZZZZ: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 38.2 3,148.6 0.0 87.1 122.7 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 6.7 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 Pubcom required because of new major source, and VOC emissions increase over 50 ipy Note 1 - Total VOC Facility Emissions (point and fugitive (A) Change in Total Permitted VOC emissions (poin and fugi ive) 196.0 Facility is NOT eligible for GP02 195.1 Revised APENs were rec'd Oct 11, 2017, which replaced the revisions from Aug 31, 2017 and the original application from July 14, 2017. Note 2 Page I of2 Printed 10/30/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Longs Peak Resources, LLC 123 9F4A Motu 28-21-16-1CH Emissions.- uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2$ ""p1etlk ` TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 . 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 13139 3241 324 771 72797 7095 48.7 004 17WE0806 Separator venting 8886.2 22862.24 7670.79 9824.18 86024.03 4995 70.1 005 17WE1075 Produced water storage 1591 4999 3.3 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTAL f tpy) 0.3 0.0 0.0 11.8 13.1 4.0 5.3 82.0 0 6.0 0.0 0.0 122.7 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S '"''°'°^° TOTAL (tpy) "Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 657 162 16 39 3640 , 355 2.4 004 17WE0806 Separator venting 444 1143 384 491 4301 249.75 3.5 005 17WE1075 Produced water storage 80 250 0.2 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTAL f tpy) 0.3 0.0 0.0 0.6 0.7 0.2 0.3 4.2 0.0 0.3 0.0 0.0 6.7 2 1239F4A.xlsx 10/30/2017 Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? 0arbon Monoxide (Co) wholesale revision rec'd 10/11/17 Section 02 - Emissions Units In Permit Application Weld Quadrant Section Township Range SESE quadrant of Section 28, Township 12N, Range 65W, in Weld County, Colorado articulate Matter (PM) [Drone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? „ r,;H y, i3,,333:3»,gk inig ..�...,,,, 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 ❑ ❑ ❑ ❑� O O ❑ ❑ ❑ ❑ O ❑ ❑ o ❑ ❑ Is this stationary source a major source? a„ m;._.,.,r: If yes, explain what programs and which pollutants here: 5O2 NOx • CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) ❑ ❑ ❑ ❑ O O ❑ ❑ ❑ o O O ❑ ❑ ❑ ❑ Crude Oil Storage Tank(s) Emissions Inventory Section 01- Administrative Information Facility AIRs ID: - County Plant. Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information far Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput= Secondary Emissions- Combustion Device(s) Heat content of waste gas= € r X2948. Btu/scf Volume of waste gas emitted per BBL of liquids produced = 228,° scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating = Barrels (bbl) per year Barrels (bbl) per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? 0 MMBTU per year 56,718 MMBTU per year 56,718 MMBTU per. year Pollutant Control Device Pollutant ®' Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Crude Oil Throughput). (Crude Oil Throughput) Uncontrolled Uncontrolled (1b/MMBtu) (waste heat combusted) (Ib/bbl) (Crude Oil Throughput) 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 PM2.5 NOx. CO 1225.69 1225.69 61.28 0.21 0.21 0.21 0.21- 0.21 0.21 1.93 1.93 1.93 8.79 8.79 8.79 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 13139 13139 657 3241 3241 162 324 324 16 771 771 39 72797 72797 3640 7095 7095 355 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, e, 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, NIPS Subpart Kb Storage Tank is not subject to NSPSKb Regulation 6, Part A, NSPS Subpart 0000a Storage tankis subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MAR HR (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements 1 oft K:\PA\2017\17 W E0743.CP1.xism Crude Oil Storage Tank(s) Emissions Inventory 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 20 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 14-03 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 samplesaf crude oil drawn at the;"�� facility being permitted? If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. 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 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # Process # SCC Code 003 Dl Uncontrolled Emissions Pollutant Factor Control % Units NOx 0.612 0 lb/1,000 gallons crude oil throughput VOC 389.109 95 lb/1,000 gallons crude oil throughput CO 2.791 0 lb/1,000 gallons crude oil throughput Benzene 2.086 95 lb/1,000 gallons crude oil throughput Toluene 0.514 95 Ib/1,000 gallons crude oil throughput Ethylbenzene 0.051 95 Ib/1,000 gallons crude oil throughput 2 of 2 K:\PA\2017\ 17WE0743.CP1.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Longs Peak Resources, LLC 123 9F4A Motu 28-21-16-1CH History File Edit Date Ozone Status 10/27/2017 Attainment EMISSIONS - Uncontrolled (tons oer year EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 - H2S SO2 NOx VOC Fug V0C CO - Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 17WE0741 PSI, 11.1L, sn: TED. 302hp 0.3 0.3 30.2 2.0 50.9 0.4 2.9 2.0 5.8 0.4 "GEN1" 002 17WE0742 Crude oil loadout to tank trucks 7.8 0.1 7.8 0.1 Default EFs for crude; not controlled 003 17WE0743 Crude oil storage tanks, 1600bbl 1.9 1,225.5 8.8 48.7 1.9 61.3 8.8 2.4 SSEFs accepted 004 17WE0806 Separator venting 6.0 1,883.5 27.5 70.1 - 6.0 94.2 27.5 3.5 SSEFs accepted 005 17W61075 Produced water storage 29.8 3.3 29.8 0.2 Initially requested GP0B, then shifted to CP per revisions recd 10/11/17. Default EFs. APEN-Exempt / Insignificants: Healer -Treater 0.2 0.01 0.1 0.0 0.2 0.01 0.1 0.0 Fugitives 0.1 0.0 0.1 0.0 Condensate tank "FLR TANK" 0.7 0.0 0.7 0.0 Collects condensate from secondary separator; XA when applying default EFs for condensate Condensate loadout "LOAD2" 0.01 0.0 0.01 0.0 Using default EF for condensate Idadout Pump engine - PSI 11.1L 1.7 0.1 2.9 0.0 1.7 0.1 2.9 0.0 "GEN2" -- max runtime 250 hr/yr, used only during startup of pump FACILITY TOTAL 0.3 0.3 0.0 0.0 40.0 3,149.4 0.1 90.2 122.7 0.0 0.0 0.0 0.0 12.8 195.9 0.1 45.1 6.7 VOC: Major (OP), Syn Minor (PSD) NOx: Minor (PSD and OP) CO: Minor (PSD and OP) HAPS: Syn Minor- benzene, toluene, n -hexane and total HH: Syn Minor 7777: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 38.2 3,148.6 0.0 87.1 122.7 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 6.7 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 • 0.0 0.0 10.9 195.1 0.0 42.1 Pubcom required because of new major source, and VOC emissions increase over 50 toy Note 1 Total VOC Facility (A) Change in Total Permitted VOC Emissions (point and fugitive emissions (point and fugitive) 196.0 Facility is NOT eligible for OP02 195.1 • Revised APENs were rec'd Oct 11, 2017, which replaced the revisions from Aug 31, 2017 and the original application from July 14,-2017. Note 2 Page 1 of Printed 10/30/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Longs Peak Resources, LLC County AIRS ID 123 Plant AIRS ID 9F4A Facility Name Motu 28-21-16-1CH Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S '"""e TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 13139 3241 324 771 72797 7095 48.7 004 17WE0806 Separator venting 8886.2 22862.24 7670.79 9824.18 86024.03 4995 70.1 005 17WE1075 Produced water storage 1591 4999 3.3 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1 L 32 0.0 TOTAL f tpy) 0.3 0.0 0.0 11.8 13.1 4.0 5.3 82.0 0 6.0 0.0 0.0 122.7 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S '''8N"1ne TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 657 162 16 39 3640 355 2.4 004 17WE0806 Separator venting 444 1143 384 491 4301 249.75 3.5 005 17WE1075 Produced water storage 80 250 0.2 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTALftpy) , 0.3 0.0 0.0 0.6 0.7 0.2 0.3 4.2 0.0 0.3 0.0 0.0 6.7 2 1239F4A.xlsx 10/30/2017 Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? [carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application 74 /21 wholesale revision rec'd 10/11/17 Quadrant Section Township Range SESE quadrant of Section 28, Township 12N, Range 65W, in Weld County, Colorado Dacticulate Matter (PM) ❑)zone (NOx & VOC) AIRS Point tt Emissions Source Type Equipment Emissions Name Control? Permit ft Issuance Self Cert Required? Action Engineering Remarks Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ O ❑ 0 O O ❑ ❑ ❑ ❑ O ❑ O a O O 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ O O ❑ ❑ O O O O ❑ ❑ O ❑ 1parat }5', 9pss it tl6bat weii, be 123-9F4A-004 17WE0806 CP1 based on revised APEN rec'd 10/11/17 Equipment Description This source vents natural gas from: Emissions from this source are: one (1) secondary separator routed to a flare piaoi Natural gas venting from one (1) secondary separator. Emissions from this source are routed to a flare. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xi( = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Throughput (Q) MW 120.1 26.79 MMscf/yr Ib/Ib-mol 13710.04566 0.329041096 scf/hr MMscf/d mole % MW Ibx/Ibmol mass fraction lb/hr lb/yr tpy Helium -'.'/h00'. 4.0026 0.000 0.000E+00 0.00 0.00 0.00 C02 :. "2.76! 44.01 1.215 4.534E-02 43.94 384914.48 192.46 N2 ': '.1:32 28.013 0.370 1.380E-02 13.38 117175.64 58.59 methane -.. . ' .6529921 16.041 10.473 3.909E-01 378.86 3318816.46 1659.41 ethane -,-t9°46931 30.063 2.853 1.065E-01 103.20 904003.87 452.00 propane , ,38,31,9'.. 44.092 - 4.776 1.783E-01 172.77 1513436.59 756.72 isobutane 3111 133269.. 58.118 0.771 2.877E-02 27.88 244206.93 122.10 n -butane ::4569 58.118 2.590 9.667E-02 93.68 820634.73 410.32 isopentane .14t91 72.114 0.823 3.074E-02 29.79 260923.64 130.46 n -pentane ;;;;'E'.2tit6 72.114 0.879 3.280E-02 31.79 278473.94 139.24 cyclopentane 3 1 z�0:0875 70.13 0.061 2.285E-03 2.21 19400.90 9.70 n -Hexane 1 ? 9.i1i 86.18 0.271 . 0.0101331 9.82 86024.24 43.01 cyclohexane , . ..;;U}0 ' 84.16 0.049 1.819E-03 1.76 15441.45 7.72 Other hexanes ' ' ' '0A529 86.18 0.390 1.457E-02 14.12 123683.74 61.84 heptanes7752 100.21 0.777 2.900E-02 28.10 246166.31 123.08 methylcyclohexane 9.124$ 98.19 0.122 4.563E-03 4.42 38738.29 19.37 224-TMP - 4 dt38 114.23 0.016 0.0005884 0.57 4995.32 2.50 Benzene T0359 78.12 0.028 0.0010468 1.01 8887.11 4.44 Toluene '-'-i ?0:07 92.15 0.072 0.0026933 2.61 22864.46 11.43 Ethylbenzene .ice :0228 106.17 0.024 0.0009036 0.88 7670.80 - 3.84 Xylenes a'+t5`7= /iti292 106.17 0.031 0.0011572 1.12 9824.00 4.91 C8+ Heavies 1sa31v c,.` F):1724 114.23 0.197 7.351E-03 7.12 62405.27 31.20 99.9988 VOC mass fraction: 26.79 0.4434 Total VOC (Uncontrolled) I 1881.89 Notes Mole % from site -specific separator gas analysis collected on 8/1/2017. Applicant states maximum vent rate of 21000 scf/hr, but requests a lower permit limit of 120.1 MMscf/yr. This is about 5179 hours per year at the claimed maximum vent rate of 21000 scf/hr. 17WE0806.CP1.xlsm separatorgas.for flat well Flaring Information Equipment Description Flare to combust low-pressure separator, heater treater, and vapor recovery tower as. Manufacturer Crimson Energy Model CE 1000 Serial Number TBD Gas Heating Value 1475.62 Btu/scf Throughput 177221.962 MMBtWyr Overall Control 95.00% Combustion emission factor source: 0.068 alb NOX/MMBtu AP -42: Chapter 13.5 0.31 Ilb CO/MMBtu 123-9F4A-004 17WE0806 CP1 Below is a table summarizing the emission factors and resulting emissions calculated by the operator and used in the permit. As described in the additional Notes section below, the difference is likely due to rounding. This difference is small enough to be considered insignificant and thus acceptable for permitting purposes. Emissions Summary Table (Values used in Permit) Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC ;`141B44Ib/MMscf 1568.27 liz/MMscf 1883.49 tpy 94.17 tpy Gas Analysis NOx 1368 lb/MMBTU 0.068 IIT/MMBTU 6.03 tpy 6.03 tpy AP -42 CO ., ' 0.'31!, lb/MMBTU 0.31 Ito/MMBTU 27.47 tpy 27.47 tpy AP -42 Benzene ,,.73'.99.. lb/MMscf 3.700 lia/MMscf 8886.20 lb/yr - 444.31 lb/yr Gas Analysis Toluene :' 190.,311 Ib/MMscf 9.518 Ibr'MMscf 22862.24 lb/yr 1143.11 lb/yr Gas Analysis Ethylbenzene 63.8'{. Ib/MMscf 3.194 Ibt'MMscf 7670.79 lb/yr 383.54 lb/yr Gas Analysis Xylenes : ; -; .8 Ib/MMscf 4.090 Ib{MMscf 9824.18 lb/yr 491.21 lb/yr Gas Analysis n -Hexane ::,71627 Ib/MMscf 35.814 Ibr'MMscf 86024.03 lb/yr 4301.20 lb/yr Gas Analysis 2,2,4-TMP .. � ': -4t1.5 lb/MMscf 2.080 lb/MMscf 4994.96 lb/yr 249.75 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompletedlon or after August 1, 2014? Yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2 Additional Notes: The emission factors calculated in this preliminary analysis are not identical to the emission factors reported by the operator on the APB'l. However, the difference between the values is small enough as to be considered insignificant. The difference between these values is most likely due to rounding in the calculations. As such, the emission factors reported by the operator in the application will be used for permitting purposes. 1 The permit will require a flow meter to monitor and record the volumetricflowrate of natural gas vented from the separator. SCC CODING SCC Code: 31000205 Emission Factors for Permit: Uncontrolled (lb/MMscf vented) Controlled (lb/MMscf vented) Control Eff. NOx CO VOC Benzene 73.99 Toluene 190.36 Ethylbenzene 63.87 Xylenes 81.80 n -Hexane 716.27 2,2,4-TMP 41.59 100.34 100.34 0% 457.44 457.44 0% 1568.27 95% 31365.36 3.70 95% 9.52 95% 3.19 95% 4.09 i 95% 35.81 95% 2.08 95% 17WE0806.CP1.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Longs Peak Resources, LLC 123 9F4A Motu 28-21-16-1CH History File Edit Date Ozone Status 10/27/2017 Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug • VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 - 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0- 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 0.3 0.3 30.2 2.0 50.9 0.4 2.9 2.0 5.8 0.4 "GEN1" 002 17WE0742 Crude oil loadout to tank trucks 7.8 0.1 7.8 0.1 Default EFs for crude; not controlled 003 17WE0743 Crude oil storage tanks, 1600bb1 1.9 1,225.5 8.8 48.7 1.9 61.3 8.8 2.4 SSEFs accepted 004 17WE0806 Separator venting 6.0 1,883.5 27.5 70.1 6.0 94.2 27.5 3.5 SSEFs accepted 005 17WE1075 Produced water storage 29.8 3.3 29.8 0.2 Initially requested GPO8, then shifted to CP per revisions reed 10111117. Default,EF5. APEN-Exempt / Insignificants; Heater -Treater 0.2 0.01 0.1 0.0 0.2 0.01 0.1 0.0 Fugitives 0.1 0.0 0.1 0.0 Condensate tank "FLR TANK" 0.7 0.0 0.7 Q 0 Collects condensate from secondary separator, XA when applying default EFs for condensate Condensate loadout "LOAD2" 0.01 0.0 0.01 0.0 Using default EF for condensate loadout Pump engine - PSI 91.1 L - _ 1.7 0.1 2.9 0.0 1.7 0.1 2.9 0.0 "GEN2" - max runtime 250 hrfyr; used only du/ing startup of pump FACILITY TOTAL 0.3 0.3 0.0 0.0 40.0 3,149.4 0.1 90.2 122.7 . 0.0 0.0 0.0 0.0 12.8 195.9 0.1 45.1 6.7 VOC: Major(OP), Syn Minor (PSD) NOx: Minor (PSD and OP) CO: Minor (PSD and OP) HAPS: Syn Minor- benzene, toluene, n -hexane and total . HH: Syn Minor ZZZZ: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 38.2 3,148.6 0.0 87.1 122.7 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 6.7 Excludes units exempt from permits/APENs (11) Change in Permitted Emissions 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 Pubcom required because of new major source, and VOC emissions increase over 50 tpy Note 1 • Total VOC Facility Emissions (point and fugitive (A) Change in Total Permitted VOC emissions (point and fugitive) 196.0 Facility is NOT eligible for GP02 195.1 Revised APENs were rec'd Oct 11, 2017, which replaced the revisions from Aug 31, 2017 and the original application from July 14, 2017. Note 2 Page 1 of2 Printed 10/30/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name . Longs Peak Resources, LLC County AIRS ID 123 Plant AIRS ID 9F4A Facility Name Motu 28-21-16-1CH Emissions - uncontrolled (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP l {2$ ''�a1e°" "e TOTAL (tpy) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 13139 3241 324 771 72797 7095 48.7 004 17WE0806 Separator venting 8886.2 22862.24 7670.79 9824.18 86024.03 4995 70.1 005 17WE1075 Produced water storage 1591 4999 3.3 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTAL (tpy) 0.3 0.0 0.0 11.8 13.1 4.0 5.3 82.0 0 6.0 0.0 0.0 122.7 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H28 '''''-""e TOTAL (tpy) "Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 657 162 16 39 3640 355 2.4 004 17WE0806 Separator venting 444 1143 384 491 4301 249.75 3.5 005 17WE1075 Produced water storage 80 250 0.2 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTAL jtpy) 0.3 0.0 0.0 0.6 0.7 0.2 0.3 4.2 0.0 0.3 0.0 0.0 6.7 2 1239F4A.xlsx 1.0/30/2017 Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? [xarbon Monoxide (CO) wholesale revision rec'd 10/11/17 Section 02 - Emissions Units In Permit Application Weld Quadrant Section Township Range SESE quadrant of Section 28, Township 12N, Range 65W, in Weld County, Colorado culate Matter (PM) ❑Jaone (NOx & VOC) Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ 0 2 0 0 ❑ ❑ ❑ ❑ 0 ❑ ❑ a ❑ ❑ Is this stationary source a major source? If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) 0 0 0 0 0 0 Title V Operating Permits (OP) 0 0 0 0 0 0 ❑ ❑ Non -Attainment New Source Review (NANSR) ❑ 0 Produced Water Storage Tank(s) Emissions Inventory Section 01- Administrative Information Facility AIRS ID: Plan Poin Section 02 - Eauipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = SecondaryEmissions - Combustion Device(s), Heat content of waste gas Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Btu/scf scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Actual Produced Water Throughput While Emissions Controls Operating= 0 MMBTU per year 0 MMBTU per year - 0 MMBTU per year Pollutant vLEN Produced Water Tank Uncontrolled Controlled (lb/bbl) (Ib/bbl) (Produced Water Throughput) Pollutant (Produced Water Throughput) Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) 0.0000 0.0000 0.0000 0.0000 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 PM2.5 NOx CO 29.8 0.0 0.0 29.77 1.49 0.0 0.0 0.0 0.00 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1591 0 0 1591 80 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 4999 0 0 4999 250 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit 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, NIPS Subpart OOOOa Storage Tank is not subject to NSPS OOOOa (See regulatory applicability worksheet for detailed analysis) 1 of 2 K:\PA\2017\17WE1075.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements 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 water sample drawn at the facility being permitted and analyzed using flash liberation analysis? 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 maybe appropriate to use an older site -specific sample. Does the company request a control device efficiency greater than 95% for a flare or combustion device? ,. If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 005 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+Flashing losses Uncontrolled Emissions Pollutant Factor Control % Units VOC 6.2 95 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput n -Hexane 0.52 95 lb/1,000 gallons liquid throughput 2 oft K:\PA\2017\17 W E1075.CP1.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Longs Peak Resources, LLC 123 9F4A Motu 28-21-16-1CH History File Edit Date Ozone Status 10/27/2017 Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS. ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10. PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 17WE0741 PSI, 11.1L, so: TBD. 302hp 0.3 0.3 30.2 2.0 50.9 0.4 2.9 2.0 5.8 0.4 "GEN1" 002 17WE0742 Crude oil loadout to tank trucks 7.8 0.1 7.8 0.1 Default EFs for crude; not controlled 003 17WE0743 Crude oil storage tanks, 1600bbl 1.9 1,225.5 9.8 48.7 1.9 61.3 8.8 2.4 SSEFs accepted 004 17W50806 Separator venting 6.0 1,883.5 27.5 70.1 6.0 94.2 27.5 3.5 SSEFs accepted 005 17WE1075 Produced water storage 29.8 3.3 29.8 0.2 Initially requested GP08, then shifted to CP per revisions rec'd 10/11/17. Default EFs. APEN-Exempt / Insignificants: Heater -Treater 0.2 0.01 0.1 0.0 - 0.2 0.01 0.1 0.0 Fugitives 0.1 0.0 0.1 0.0 Condensate tank "FLR TANK" 0.7 0.0 0.7 0.0 Collects condensate from secondary separator; XA when applying default EFs for condensate Condensate loadout "LOAD2" 0.01 0.0 0.01 0.0 Using default EF for condensate loadout Pump engine - PSI 11.1L 1.7 0.1 2.9 0.0 1.7 0.1 2.9 0.0 "GEN2" -- max runtime 250 hrfyr; used only during startup of pump FACILITY TOTAL 0.3 0.3 0.0 0.0 40.0 3,149.4 0.1 90,2 122.7 0.0 0.0 0.0 0.0 12.8 195.9 0.1 45.1 6.7 VOC: Major(OP), Syn Minor (PSD) NOx: Minor (PSD and OP) CO: Minor (PSD and OP) HAPS: Syn Minor- benzene, toluene, n -hexane and total HH: Syn Minor ZZZZ: Syn Minor Permitted Facility Total 0.3 0.3 0.0 0.0 38.2 3,148.6 0.0 87.1 122.7 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 6.7 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 10.9 195.1 0.0 42.1 Pubcom required because of new major source, and VOC emissions increase over 50 tpy Note 1 Total VOC Facility Emissions (point and fugitive (A) Change in Total Permitted VOC emissions (point and fugitive) 196.0 Facility is NOT eligible for GPM 195.1 Revised APENs were rec'd Oct 11, 2017, which replaced the revisions from Aug 31, 2017 and the original application from July 14, 2017. Note 2 Page 1 of 2 Printed 10/30/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY HAPs Company Name Longs Peak Resources, LLC County AIRS ID 123 Plant AIRS ID 9F4A Facility Name Motu 28-21-16-1CH Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S ' ' ""e TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001, 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 13139 3241 324 771 72797 7095 48.7 004 17WE0806 Separator venting 8886.2 22862.24 7670.79 9824.18 86024.03 4995 70.1 005 17WE1075 Produced water storage 1591 4999 3.3 APFN-€xenant I InsianificantaL Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTAL ftpy) 0.3 0.0 0.0 11.8 _ 13.1 4.0 5.3 82.0 0 6.0 0.0 0.0 122.7 "Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S ''""'-' TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0741 PSI, 11.1L, sn: TBD. 302hp 560 76 72 43 15 84 18 0.4 002 17WE0742 Crude oil loadout to tank trucks 27 240 0.1 003 17WE0743 Crude oil storage tanks, 1600bb1 657 162 16 39 3640 355 2.4 004 17WE0806 Separator venting 444 1143 384 491 4301 249.75 3.5 005 17WE1075 Produced water storage 80 250 0.2 APEN-Exempt / Insignificants: Heater -Treater 0.0 Fugitives 0.0 Condensate tank "FLR TANK" 0.0 Condensate loadout "LOAD2" 0.0 Pump engine - PSI 11.1L 32 0.0 TOTAL (tpy) 0.3 0.0 0.0 0.6 0.7 0.2 0.3 4.2 0.0 0.3 0.0 0.0 6.7 2 1239F4A.xlsx 10/30/2017 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 17WE0741 Issuance 1 DATE ISSUED: ISSUED TO: Longs Peak Resources, LLC THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Mbtu 28-21-16-1 CH, located in SESE Section 28 T12N R65W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description GEN1 001 One (1) PSI, Model 11.1L, Serial Number TBD, natural gas - tired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 302 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for power generation. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another PSI 11.1L engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et sea), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.00v/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 No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9F4A Page 1 of 15 NGEngine Version 2014-1 Public Health and Environment Air Pollution Control Division 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This- permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type NO. VOC CO GEN1 001 496 - 347 991 Point (Note: Monthly limits are based on a 31 -day month.) The owner or operator shall calculate monthly emissions based on the calendar month. AIRS ID: 123/9F4A Page 2 of 15 Public Health and Environment Air Pollution Control Division Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO. VOC CO GEN1 001 3.0 2.1 5.9 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 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 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 emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. 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 GEN1 001 Non -selective catalytic reduction (NSCR) system and air/fuel ratio controller NOx and CO PROCESS LIMITATIONS AND RECORDS 9. 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) GEN1 001 Consumption of natural gas as a fuel 18.53 MMscf/yr 1.574 MMscf/month AIRS ID: 123/9F4A Page 3 of 15 Public Health and Environment Air Pollution Control Division Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours, of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each 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 10. The permit number and AIRS ID point number (e.g. 123//9F4A/xxx) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testinq,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 engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. AIRS ID: 123/9F4A Page 4 of 15 Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 17. This source is subject to the provisions of Regulation No. 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 18. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS AIRS ID: 123/9F4A Page 5 of 15 Public Health and Environment Air Pollution Control Division 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the. Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/9F4A Page 6 of 15 By: o Public Health and Environment Air Pollution Control Division Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Longs Peak Resources, LLC. AIRS ID: 123/9F4A Page 7 of 15 Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reqs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 001 Formaldehyde 50000 560 Yes 560 Methanol . 67561 84 No 84 Acetaldehyde 75070 76 No 76 Acrolein 107028 72 No 72 Benzene 71432 -43 No 43 Toluene 108883 15 No 15 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 Controlled lb/MMBtu Factors — . g/bhp-hr NOx 2.21 10.8 0.213 1.0 CO 3.72 18.2 0.427 2.0 VOC 0.149 0.7 0.149 0.70 50000 Formaldehyde 0.0205 0.10 0.0205 0.10 67561 Methanol 0.00306 0.01495 0.00306 0.01495 75070 Acetaldehyde 0.00279 0.01217 0.00279 0.01217 107028 Acrolein 0.00263 0.01285 0.00263 0.01285 71432 Benzene 0.00158 0.00772 0.00158 0.00772 108883 Toluene 0.000558 0.00273 0.000558 0.00273 AIRS ID: 123/9F4A • Page 8of15 Public Health and Environment Air Pollution Control Division Emission factors are based on a Brake -Specific Fuel Consumption Factor of 10334 Btu/hp-hr, a site -rated horsepower value of302, and a fuel heat value of 1476 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx AP -42; Table 3.2-3 (7/2000); Natural Gas Specified by Applicant CO AP -42; Table 3.2-3 (7/2000); Natural Gas Specified by Applicant VOC Manufacturer's Spec No Control 50000 Formaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 67561 Methanol AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 75070 Acetaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 71432 Benzene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 108883 Toluene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 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 ADEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.aov/ttn1atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www. epa. qov/ttn/atw/area/arearu les. htm I 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Major Source of: VOC Synthetic Minor Source of: HAPs (benzene, toluene, n -hexane, and total) PSD Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: Applicable AIRS ID: 123/9F4A Page 9 of 15 Public Health and Environment Air Pollution Control Division 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A— Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9F4A Page 10 of 15 Public Health and Environment Air Pollution Control Division 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 perfom such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement 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 orMACT 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 ame replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement AIRS ID: 123/9F4A Page 11 of 15 Public Health and Environment Air Pollution Control Division 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 foundat https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos- reporting-forms. 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: https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf 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. 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. AIRS ID: 123/9F4A Page 12 of 15 Public Health and Environment Air Pollution Control Division 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 untilthe engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that' is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as picursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 10J 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 requrements 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 AIRS ID: 123/9F4A Page 13 of 15 Public Health and Environment Air Pollution Control Division 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 0.7 500<Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 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, § I.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 AIRS ID: 123/9F4A Page 14 of 15 Public Health and Environment Air Pollution Control Division The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9F4A Page 15 of 15 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 4 7WE0742 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Longs Peak Resources, LLC Motu 28-21-16-1CH 123/9F4A SESE Section 28 T12N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LOAD1 002 Truck loadout of crude oil by submerged fill. 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 eightydays (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit Was issued: (i) does not commence construction/modification or operation of this source within 18 months. COLORADO Air Pollution Control. Division Page 1 of 7 after either, the date of i ante t c truct it o a th date E which such construction or activity wa v the• d tco nc as se ort n the per t application associated with this permi scont co I"" `on : . - .. of ei • - _ ' months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit atone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO LOAD1 002 --- --- 7.8 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for 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 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD1 002 Crude Oil Loaded 150,000 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. COLORADO Pollution Control Division Page 2 of 7 7. Crude oil loading to truck t Number 3, Part B, III.E) Regulation 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 XVII.B.1.c shall have no visible emissions. (Reference: Regulation Number 1, Section II.A.1. Et 4.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. 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. 11. The owner or operator shall fallow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment during loading operations to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least quarterly. Each inspection shall be documented in a log available to the Division on request. b. Alt 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. OPERATING ft MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 14. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 15. 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 COLORADO Air Pollution Control Division change in an whichever is five percent, For sources emitting 100 tons per year or more, a change in actual emissions of, five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 16. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 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 (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 COLORADO Air Pollution Control Division the permit. If the Division d 'es a p mi o lions ` • • upo p'' rmit a contested by the owner or operator, or th �ivis' revs s a rm the : ner operator . a source may request a hearing before t for r -' of " sion 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Longs. Peak Resources, LLC. !COLORADO Air Pollution Control Division ErNir6' Y,Y ert Page 5 of 7 Notes to Permit Holder at the time o 1) The permit holder is required tit. An e for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. • 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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 (Ib/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 27 27 n -Hexane 110543 240 240 Note: All non -criteria reportable pot utants 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: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.104 N/A State EFs for Crude Oil Benzene 71432 0.00018 N/A n -Hexane 110543 0.0016 N/A 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Major Source of: VOC COLORADO IAir Polltion Control Division 4. rtl£b 1t 04. ttiiAc t-C3t'E.s ., _rT«Y33te Page 6 of 7 Synt = tic Mi So c • HA ". tota ene, lure, n -h ane, and PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: 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 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0743 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Longs Peak Resources, LLC Motu 28-21-16-1CH 123/9F4A SESE Section 28 T12N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TANKS 003 Four (4) 400 barrel fixed _ roof storage vessels used to store crude oil Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of. Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty.days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) p 3. �� .� expi �-" er or oper or . a source =� ��_ this perms � ..s issued: tion/modif, �, . eration is source withi 8 months ce of t.': constr��on pe or the date on ich such uled commen .s set ° th in the permit ..lication ed with thi e " (ii) i i con inu -s cons uc is • - • - od of eigh een . the 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.) s permit s does not c er either, stru • Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO TANKS 003 --- 2.0 61.3 8.9 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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 shalt 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 TANKS 003 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) COLORADO t Air PoBitatort Control. Division Page 2 of 7 cess Limi Facility Equipm A P cess Par '" eter Cru • e • i t roughput Annua: ' mit arrels 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 cigit 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. 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 property. 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. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Sectio. XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. 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 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements COLORADO } Air Pollution Control Division O p art S d Pub c k eahil a E„:rrnrviert Page 3 of 7 15. pera emonstrat co ance wit standards sing EPA d 22,E Part 60, A to deter e presence o a bsence of "Vi i- Em ns" me w obsery ns of s for any period t'j periods of er tha r equ • one inute in fift - inute period d • normal on. (Regulation u `•er e i I.C, X.-n�., .16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) owner erence Me ible emiss',z ati • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization COLORADO Aar Pollution Control Division Page 4 of 7 not be gra conformin nts has be h fin d un tion or actmences a • en verified the APCD all •e� ith the co the perm;, •n self-certifi ion of all evie and �' roved by e Divisr it will pide written docu tation of ornzati•' Detail obta ng final a • rizati o operate are lo ed in the irements to 5 - fy fo ` orizat 10 permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed -denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Longs Peak Resources, LLC COLORADO Air Pollution Control Division et of Pubilc t et h t e aysnment Page 5 of 7 Notes t=` rmit Hold 1) The rmit holde'requi fee = 11 be iss fter t e invure (Regulation Number 3, Part A, Section VI.B.) time for s pe it. An invo for these e permi lder sh ay the invoice w„5 n 30 days invoi evocation ermit. 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) operateat the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 13139 657 Toluene 108883 3241 162 Ethylbenzene 100414 324 16 Xylenes 1330207 771. 39 n -Hexane 110543 72797 3640 2,2,4- Trimethylpentane 540841 7095 355 Note: All non -criteria reportable pot utants 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 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0257 0.0257 AP -42 Ch. 13.5 CO 0.1172 0.1172 AP -42 Ch. 13.5 V0C 16.34260 0.81713 EFtP TANKS based on a site specific pressurized liquid sample collected 08/01/2017 71432 Benzene 0.08759 0.00438 108883 Toluene 0.02161 0.00108 100414 Ethylbenzene 0.00216 0.00011 1330207 Xylene 0.00514 0.00026 110543 n -Hexane 0.48531 0.02427 5408410.04730 2,2,4- Trimethylpentane 0.00236 OLORADO ttion Control Division tfrs8!d F _ c fs '-wir6nrnert Page 6 of 7 Nom: The cont d emi�;g` for this poi ' ed on the f con of efficiency w•5%. 6) Thi urce is sub t to 3 F `rt 60, Su•" •'h'' �' E - Stan • ;° '• s o erforman « or Crude Oil Natur Gas litiesVr whi ' Constr on, M,ication, " or Restruction r Sep � �� 8, � � ��, . °�_a�:- 3, 2 �... � ,��< �? :� �> .��"r posting - ��w<.�' ugust 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https: //www.federalreRister.gov/documents/2016/06/03/2016-11971 /oil-and-naturat- Ras-sector-emission-standards-for-new- reconstructed -and-modified-sources 7) 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. 8) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Major Source of: VOC Synthetic Minor Source of: HAPS (benzene, toluene, n -hexane, and total PSD Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable NSPS 0000a Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website: https://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix 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 )0000 0( COLORADO Air Pollution Control Division apartment Pt.67 Fof `t:< EY^rir_r:rierp Page 7 of 7 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0806 Issuance: 1 Longs Peak Resources, LLC Facility Name: Motu 28-21-16-1CH Plant AIRS ID: 123/9F4A Physical Location: SESE Section 28 T12N R65W County: Weld County General Well Production Facility Description: Equipment or activity subject to this. permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description SEPARATOR 004 Produced gas from a 2 -phase vertical separator. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this 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 fir 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 eightydays (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-setf- certification. (Regulation Number 3, Part B, Section III.G.2. ) OLORADO I Air Pollution Control Division lep,ejrkft L.iar eenee;C Page 1 of 8 3. 4 expi er or oper i or .r e source . i this permi as issued: tion/modlfperation is ;source withil 8 months ce of t ' constrLr ;on per or the date on ich such f^ va Wed , commen . s set h in the perms ••lication ; (ii). . r -s cons rr • - od of eigh -: the 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: s permit s does not c er either, stru a:, Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO SEPARATOR 004 --- 6.1 94.2 27.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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 SEPARATOR 004 Emissions from the Separator are routed to an Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) !COLORADO Air Pollution Control Division PV)i C b S k u £7,i'SOrinIVIAL Page 2 of 8 4 ' a Ural Gas Tenting 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. 9. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator using a flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten -digit AIRS ID number assigned by the Division (e.g. 123/9F4A/xxx) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III. E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device coveried 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. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this [COLORADO Air Pollution Control Division spirt=x tt,t PubL,He th v'erp7rrnegt Page 3 of 8 mit, whic 'fy the V0 d to calc is of f the natu - ented fro s issions um order to- ntenraction) of ,g .n strea esu of the Ana s shall be e site ssion f Fors for polluta referenced in th ermit (' m scf gas led) Divis approve • -thods esults of the Ana s shall be e• to the D ��,e d. par - = "'`-certi demonstratissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site - specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; 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 COLORADO Air Pollution Control. Division n Depzxirzne He, '+ E,r,rcoru'rte:t Page 4 of 8 uipment i •, or whe xisting tyPaar equipm it be rnodif • No later than 30 days before the existing APEN expires. 19. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean kir Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. 20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of tie source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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 front 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. Detais 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 Pollutionfmission Notice (APEN) must pay an amual fee to cover the costs of inspections and administration. If a ifferent ty.f •f control rce or acts E; is t. nued the • st notify ancellatio the ' " •on notific. � . �, �. l fee bill ,z 27. lation of term 4 a pe or of /provisio1f the Act orlat.' CC enforcement actions under Sections 25-7-115 (enforcement), penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History on in writin,: •-questing erminate. rado Air Pollutio revention istrative, ,�.. .6._'minal -121 (injunctions), -122 (civil Issuance Date Description Issuance 1 This Issuance Issued to Longs Peak Resources, LLC. COLORADO Air Pollution Control Division =Y=� Page 6 of 8 Notes tpermit iss 1) The rmit holde ` equi, to ees for the ..:'' = time fo s p- it. An invo r for these fee fter t .error ssued e permi lder sh ay the invoice w n 30 days e invuse,.,<, invoi eevocation ermit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested In the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) SEPARATOR 004 Benzene 71432 8886.2 444.3 Toluene 108883 22862.2 1143.1 Ethylbenzene 100414 7670.8 383.5 Xylenes 1330207 9824.2 491.2 n -Hexane 110543 86024.0 4301.2 2,2,4- Trimethylpentane 540841 4995.0 249.8 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 100.34 100.34 AP -42, Ch. 13.5 CO 457.44 457.44 AP -42, Ch. 13.5 VOC 31365.36 1568.27 Displacement Equation based on a site specific separator gas analysis collected 8/1/17 71432 Benzene 73.99 3.70 108883 Toluene 190.36 9.52 100414 Ethylbenzene 63.87 3.19 1330207 Xylene 81.80 4.09 110543 n -Hexane 716.27 35.81 COLORADO Air Pollution Control Division rr t�tV €i yet rt!<e:,amnment Page 7 of 8 S # Uncontr• Emission (lb/ ed - cf) Contr • Emission , c o (lb/ f) S • e ollut Trimethy pen ane Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Major Source of: VOC Synthetic Minor Source of: HAPS (benzene, toluene, n -hexane, and total PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: 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 i "d PubV;_ 4iey Yt a ethfprJ nt Page 8 of 8 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1075 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Longs Peak Resources, LLC Motu 28-21-16-1CH 123/9F4A SESE Section 28 T12N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description PROD_WTR 005 Two (2) 400 barrel fixed roof storage vessels used to store produced water. Enclosed Flare _ This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1 This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) 2. 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. 3. 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 COLORADO Air:PoUUUtion Control Division Page 1 of 7 co ado.gov/pacific/cdphe/air-permit-self- ction III.2.) y� 4. his p- its l e £ a if e ow or o rator of th ource for which this permit was issued: notruc ation o tion of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 5. 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.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO PROD_WTR 005 --- --- 1.5 ---- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 8. 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 PROD_WTR 005 Enclosed Flare (Crimson Energy, CE 1000) VOC and HAP COLORADO I Air Pollution Control Division tx,putmer,id :`Jkid acv, h.Fj ,mm a=te: Page 2 of 7 9. Process Limits ximum rocessing rates as listed below. Monthly I be maint ed by the owner or operator and made equest lation Number 3, Part B, II.A.4.) Facility Equipment ID AIRS Point Process Parameter Annual Limit PROD_WTR 005 Produced Water throughput 227,234 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 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/9F4A/xxx) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the 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. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to COLORADO n Control Division Page 3 of 7 mplementation. (Regulation Number 3, n "al Testing equi"remen s 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • 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. 19. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The application for the Operating Permit is due within one year of the earliest commencement of operation of any piece of equipment covered by this permit. GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. COLORADO Air Pollution Control Division `. p t c t t `tz r� t 3r .n E G rrz9t?rt r Page 4 of 7 21. this p it '"ally st. at fin orizati ""? has been granted, then the remainder the issu ce of this construction permit does not nal a ut 'ty fo„ this ivity operation this source. Final authorization of the ust se -d f .m th PCD writing in ccordance with the provisions of 25-7- (12)(a a • `�ir`C R u. is "umber 3, 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. Detais for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance, with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth i■ the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Longs Peak Resources, LLC. COLORADO Air Pollution Control Division p '•cessin 'me for this permit. An invoice for these mit is sued the permit der shall pay the invoice within 30 days o of t oi..1..re invoic,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 (Ib/yr) Controlled Emissions (lb/yr) 005 Benzene 71432 1591 80 n -Hexane 110543 4999 250 Note: All non -criteria reportable poi utants 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 005: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.262 0.0131 State EFs for Produced Water (Weld Co.) 71432 Benzene 0.007 0.00035 110543 n -Hexane 0.022 0.0011 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 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. COLORADO Air Pollution Control Division "y.mit.,, t Pub#iC 't L? r',`:gGYJ'tE.tt Page 6 of 7 ent St us Operating Permit Major Source of: VOC Synthetic Minor Source of: HAPs (benzene, toluene, n -hexane, and total) PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: 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 Reciprocating Internal Combustion Engine APEN - Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AR 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 cnd requires re -submittal. This APEN 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 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 wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: l7RIEO7q-i AIRS ID Number: / 23 /'FL/A/ 66)/ [Leave blank untess APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Longs Peak Resources, LLC Site Name: Motu 28-21-16-1 CH Site Location: SESE Sec. 28, T12N, R65W • Mailing Address: (Include Zip Code) 1O01 Melody Dr., Suite 515 Northglenn, CO 80234 Portable Source Home Base: Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: David Clarkson Phone Number: 303-997-5558 E -Mail Address2: dclarkson@vrtxep.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 366182 COL OP ADC 1 I Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) ❑ STATIONARY source O PORTABLE source ❑✓ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,500.00 must be submitted along with the APEN Filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 D Other (describe below) - OR - • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit-exemptlgrandfathered source ❑ Notification of Alternate Operating Scenario (AOS) permanent replacements Additional Info Et Notes: 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-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. (e.g. ENG-1, Engine 3, etc)? Yes If yes, provides:the Company Equipment Identification No. GEN1 General description ofEequipment and purpose: Natural gas fired generator For existing sources, operation began on: 04/16/2017 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http: / /www. coloredo. gov /cdphe /attainment) Normal Hours of Source Operation: 24 Seasonal use percentage: Dec -Feb: 25 ❑ Yes ❑✓ No hours/day 7 days/week 52 weeks/year Mar -May: 25 June -Aug: 25 Sept -Nov: 25 77 COLORADO Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 2 I Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking 0 Pump ❑ Water Pump ❑ Emergency Back-up ❑ Other: 0 Compression What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: PSI Engine Model: 11.1L Serial Number6: TBD hours/year What is the maximum designed horsepower rating? 302 hp What is the engine displacement? 1.85 l/cyl What is the maximum manufacturer's site -rating? 302 hp 182 kW What is the engine Brake Specific Fuel Consumption at 100% Load? 10 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Ignition Source: ❑✓ Spark ❑ Compression (0314 Combustion: ❑ Lean Burn Aspiration: 0 Natural Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑ Yes 0 No If yes, what type of AFRC is in use? 0 O2 Sensor (mV) ❑NOX Sensor (ppm) Is this engine equipped with a Low-NOr design? ❑ Yes ✓❑ No Engine Dates: What is the manufactured date of this engine? TBD What date was this engine ordered? NA ❑✓ Turbocharged ❑ Other: What is the date this engine was first located to Colorado? NA What is the date this engine was first placed in service/operation? NA What is the date this engine commenced construction? NA What is the date this engine was last reconstructed or modified? NA Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must besubmitted if coverage under GP02 is requested. Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.97168/-104.65852 Operator Stack ID No. Discharge _ Height Above Ground Level (Feet) Temp C'F) Flow Rate (ACFM) Velocity (ft/sec GEN1 7 1350 1487 71 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Circular Square/Rectangle Other (describe): Interior stack diameter (inches): 8 ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100% Load-. (SCF/hour) Actual Annual Fuel Use (MMSCF/ear) Requested Annual Permit Limit' (MMSCF/ear 2115 18.53 2017 From what year is the actual annual amount? Indicate the type of fuetbsed8: ❑ Pipeline Natural Gast (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas , Heating value: 1 8 (93.6 BTU/scf 'CI3 O Propane l' ;.' (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas 0 Other (describe): Heating Value: BTU/scf k6 Q(8 ill Cr Heating Value (give units): 7 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 8 If fuel heating value is different than the listed assumed value, provide this information in the 'Other" field. COLORADO Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) PM10 PM2.5 SOX NOx NSCR 9y r4 90 .3 b voc - CO NSCR �0 r, / e 3 . S 2- Other: 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? 2017 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions 9 Requested Annual Permit Emission Limit(s)7 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) TSP (PM) 1.94E-2 Ib/MMBtu AP -42 9,K O -2.7. 0,28-.0.2.7. PM10 1.94E-2 Ib/MMBtu AP -42 O-Z.7 9.,f J •Z7 PM2.5 1.94E-2 Ib/MMBtu AP -42 o •2 7 0943'V . 2.7 SOX 5.88E-4 Ib/MMBtu AP -42 0.008 0.008 NOx 2.21 Ib/MMBtu AP -42 3 . 9 3O -1,1 2.92 VOC 0.70 g/hp-hr Manufacturer 2.04 2.04 CO 3.72 Ib/MMBtu AP -42 7 ty 760 O. 5 5.83 e Does the emissions source have any uncontrolled actual emissions of non -criteria ❑✓ Yes ❑ No pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, please use the fallowing table to report the non -criteria pollutant (HAP) emissions from source: :, y Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name r ;,I Chemical ' Abstract " S'` Service (CAS) Number Emission Factor Actual Annual Emissions' Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions (Pounds/year) ' Formaldehyde 50000 2.05E-2 Ib/MMBtu AP -42 714 $6o.46 560.116 Acetaldehyde 75070 Acrolein 107028 Benzene 71432 Other: 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 1/2017 5 I& , COLORADO 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. If this is a registration for coverage under general permit GP02, I further certify that this source is and will be operated in full compliance with each condition of general permit GP02. 1•/V•/ -L Signature of Legally Authorized Person (not a vendor or consultant) Date David Clarkson COO Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with: $152.90 and the General Permit registration fee of $1,5001;` if applicable to: Colorado DepaI-Krnent of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For more information or assistance call: 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 COLORADO Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 6 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: II -WE 03'4 2- AIRS ID Number: 123 /'jF 414/ 002 -- [! eave blank unless APCD has already assigned a permit d and AIRS lDI Company equipment Identification: LOAD1 [Provide `acihty Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Longs Peak Resources, LLC Site Name: Motu 28-21-16-1CH Site Location: SESE Sec. 28, T12N, R65W Mailing Address: (Include Zip Code) 10701 Melody Dr., Suite 515 Northglenn, CO 80234 E -Mail Address2: dclarkson@vrtxep.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: David Clarkson Phone Number: 303-997-5558 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 Hydrocarbon Liquid Loading APEN - Rev 02/2017 370100 ®� COLORADO 1 I Hul5'6Fs�nnnmenl Permit Number: AIRS ID Number: [Leave blank. unless APCD has already assigned a permit .A and AIRS .D Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Crude oil truck loadout For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 04/ 16 /2017 / / Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? ❑ Yes ❑✓ No ❑ Yes El No ❑ Yes D No ❑✓ Yes O No ❑ Yes ❑✓ No ❑ Yes ❑✓ No ❑ Yes ❑✓ No Form APCD-208 Hydrocarbon LIqu d Loading APEN Rev 02/2017 2 I �V{DORADO H.��I�Fs&w�renmm�i AIRS ID Number: Permit Number: [Leave blank .in! ens APED has alteadv assigned a permit and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑ Condensate ❑� Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 150,000 Bbl/yr Actual Volume Loaded: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") tank trucks If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: °F True Vapor Pressure Asia 60 °F Molecular weight of displaced vapors Lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Bbl/yr Bbl/yr Actual Volume Loaded: Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 Hydrocarbon Liquid LoadingIAPEI'• Rev 02'2017 //y�� COLORADO 3 I a W on�x+n<n�da�au< H�aI�M6F uuamm�n� Permit Number: AIRS ID Number: [Leave blank unless APCD has already asseyned a permit k and AIRS ID[ Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.97168/-104.65852 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. r F) Flow Rate (ACFM) Velocity'. (ft/sec) LOAD 12 70 neg. neg. Indicate the direction of the stack outlet: (check one) Q Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter (inches): ❑ Other (describe): El 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: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr Make/Model: % % Waste Gas Heat Content Constant Pilot Light: ❑ Yes O No Pilot burner Rating Btu /scf MMBtu /hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form .APCD-208 Hydrocarbon Liquid Loading APEN Rev 02/2017 4 I H.y �vr COLORADO �moiwau� 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? 0 Yes 0 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: 0 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 Emissions Requested Annual Permit 5 Emission Limits) Uncontrolled (Tons/year) Controlled' (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO. VOC 0.104 Ib/bbl State 7.80 7.80 CO Benzene Toluene Ethylbenzene Xylenes n -Hexane 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. AAnnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 Hydrocarbon Liquid Loading, APEd Re' 02/7017 5 I AVCOLORADO Permit Number: AIRS ID Number: (Leave blank unless APCD has already assigned a permit § and 4LRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. /U -S /7 - Signature of Legally Authorized Person (not a vendor or consultant) Date David Clarkson COO Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 Hydrocarbon Liquid Loading APEN Rev 02/2017 COLORADO 6 I AV UevvhnW: Pr: H.•aIN 6 Envnonmeni Crude Oil Storage Tank(s) APEN - Form APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits.. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: ,ed aram: y ,rui4IR5 12-3 9Fi A / Oo3 Section 1'- Administrative Information Company Name': Longs Peak Resources, LLC Site Name: Motu 28-21-16-1 CH Site Location: SESE Sec. 28, T12N, R65W lu Address: p Code) 10701 Melody Dr., Suite 515 (Include Zip Code) Northglenn, CO 80234 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Phone Number: E -Mail Address2: David Clarkson 303-997-5558 dclarkson@vrtxep.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form ARCD-_ 10 Crude CPI - i in1>=- APT- . _ idun . _0I / 370107 AV COLORADO Department e/Pi UC cnw.en.nent Permit Number: AIRS ID Number: Section 4 - Storage Tank(s) Information Actual Annual Amount (tal/year) Requested Annual Permit Limit4 (bbl/year) Crude Oil Throughput: 150,000 From what year is the actual annual amount? Average API gravity of sales oil: 34.9 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date, of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TANKS 4 1600 1/17 4/17 Wells Serviced by this Storage Tank or Tank Battery5 (EaP Sites On y) API Number Name of Well Newly Reported Well 05 - 123 - 406 Motu 28-21-16-1 CH 0 ■ ■ ■ - • 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.97168/-104.65852 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Combustor 35 1000 Indicate the direction of the stack outlet: (check ene) 0 Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter (inches): 96 ❑ Square/rectangle ❑ Other (describe): or Interior stack width (inches): Interior stack depth (inches): 31 ANV COLORADO ,E Permit Number: AIRS ID Number: Section 2 - Requested Action El NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name O Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Noe blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 4-400 bbl Crude Oil Tanks hours/day 4/16/2017 7 Storage tank(s) located at: (] Exploration & Production (EEtP) site days/week 52 weeks/year 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? ■ Yes SI No Are Flash Emissions anticipated from these storage tanks? • Yes • No Are these storage tanks subject to Colorada Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ig Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual• emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ ucle 2 I AYCOLORADO ' i' Stmtt'e`u Permit Number: AIRS ID Number: .1r_a \!.JS Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: 1000 mscfd MMBtu/hr Type: Enclosed Make/Model: Crimson Energy/CE 1000 Requested Control Efficiency: 95 % Manufacturer Guara.teed Control Efficiency: 98 Minimum Temperature: NA Waste Gas Heat Content: 2946 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.02 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (MP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 51 psig Describe the separation process between the well and the storage tanks: gas and liquids from the well are routed to a 2 phase vertical separator, gas is sent to an additional separator and then to he combustor, liquids from the 1st separator are sent to a heater treater, water is sent to water tanks and oil is sent to oil tanks. Liquids from the 2nd separator are sent to the condensate tank. F I1"I I_' 4 j AVCOLORADO T I 112g sEnfev". Permit Number: AIRS ID Number: ,aPC , -, ._._! , _ ;ned - ,and Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Combustor 95 NOx CO HAPs Combustor 95 Other: From what year is the following reported actual annual emissions data? 2017 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled' Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year)'' Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/war) (T y ) Controlled Emissions (Tons/ year y ) VOC 16.34 Ibibbl ESP Tanks 1225.50 61.28 NOx 0.068 lb/MMBtu AP -42 1.93 1.93 CO 0.31 Ib/MMBtu AP -42 8.82 8.82 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service CAS ( ) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions 7 (Pounds/year) Benzene 71432 0.0876 lb/bbl E&P Tanks 13138.5 656.9 Toluene 108883 0.0216 lb/bbl E&P Tanks 3241.5 162.1 Ethylbenzene 100414 0.00215 lb/bbl E&P Tanks 322.5 16.1 Xylene 1330207 .0.00514 lb/bbl E&P Tanks 771.0 38.6 n -Hexane 110543 0.485 lb/bbl E&P Tanks 72795.0 3639.8p 2,2,4 Trimethylpentane 540841 0.0473 Ib/bbl E&P Tanks 7095.0 354.8 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 51 AV COLORADO Department of Public x..umtr r,..e.:.mn. Permit Number: AIRS ID Number: Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. /41A'f;6 Signature of Legally Authorized Person (not a vendor or consultant) Date `1174 - as. 0 David Clarkson COO Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 6I AV COLORADO P=11=, Natural Gas Venting APEN - Form APCD-211 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 Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. 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 w5.v r©6 (23 1Fy4 do`t AIRS ID Number: / / Company equipment Identification: SEPARATOR , •1, ,I. . Section 1 - Administrative Information Company Name': Longs Peak Resources, LLC Site Name: Motu 28-21-16-1 CH Site Location: SESE Sec. 28, T12N, R65W Mailing Address: (Include Zip Code) 10701 Melody Dr., Suite 515 Northglenn, CO 80234 E -Mail Address: dclarkson@vrtxep.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: David Clarkson Phone Number: 303-997-5558 Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 370108 m ANT ? `12,C rat. V,-2 IiniiAPEN - -. v3 1 I AY COLORADO nre..nmenentA.huc Nc.4hG Envl•n.unen� Permit Number: AIRS ID Number: / / Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name 0 Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: no gathering pipeline in place Flaring of separator gas for wildcat well, For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 04 /16/ 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: hours/day Will this equipment be operated in any NAeAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year 0 Yes ❑✓ No ❑ Yes ❑✓ No i7 2 I AY COLORADO DcwtmentolPublIc HaUUTtrEnv4ansnan Permit Number: AIRS ID Number: Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? E Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 21000 SCF/hr Vent Gas Heating Value: 1475.6 BTU/SCF Requested: 120.1 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 21.14 VOC (Weight %) Benzene (mole %) 0.0359 Benzene (Weight %) Toluene (mole %) 0.0783 Toluene (Weight %) Ethylbenzene (mole %) 0.0228 Ethylbenzene (Weight %) Xylene (mole %) 0.0292 Xylene (Weight %) n -Hexane (mole %) 0.3150 n -Hexane (Weight %) 2,2,4-Trimethylpentane (mole %) 0 0138 2,2,4-Trimethylpentane (Weight %) Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Erjrm iCOLORADO Permit Number: AIRS ID Number: Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.97168/-104.65852 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) COMBUSTOR 35 1000 variable variable Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Q Upward ❑ Horizontal Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 96 Section 6 - Control Device Information ❑✓ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, HAPs, H2S Rating: 1000 mscfd MMBtu/hr Type: Enclosed Make/Model: Crimson Energy, CE 1000 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency Minimum Temperature: NA 98 % Waste Gas Heat Content 1475.6 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating 0.02 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 4, AY COLORADO Dcputmant ofPueu. Health b FM F11..m.iu Permit Number: AIRS ID Number: In' 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? 0 Yes ❑ No If es lease describe the control equipment AND state the overall control efficiency 1% reduction): Y ,P Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. VOC Combustor 95 CO HAPs Combustor 95 Other: H2S conversion to SO2 - Combustor 100% Conversion From what year is the following reported actual annual emissions data? 2017 Use the following table to report the criteria pollutant emissions from source: Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Emission Limit(s)6 Permit Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX 5.72E-4 Ib/MMBtu Mass Balance 0.05 0.05 NO. 0.068 IbMIMBtu AP -42 6.03 6.03 VOC 21.25 IbtMMBtu Mass Balance 1883.49 94.17 CO 0.31 Ib/MMBtu AP -42 27.48 27.48 Benzene 73.99 Ib/MMscf Mass Balance 4.44 0.22 Toluene 190.36 lb/MMscf Mass Balance 11.44 0.57 Ethylbenzene 63.87 lb/MMscf Mass Balance 3.84 0.19 Xylenes 81.80 lb/MMscf Mass Balance 4.91 0.25 n -Hexane 716.27 lb/MMscf Mass Balance 43.03 2.15 2,2,4 Trimethylpentane 41.59 Ib/MMscf Mass Balance 2.50 0.12 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. uas [G;97 I He dT6 Fnvi ovvenf Permit Number: AIRS ID Number: �.D oct-2:dv Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. /O- 06- /7 - Signature of Legally Authorized Person (not a vendor or consultant) Date David Clarkson COO Name (please print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) 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 roan d-Cn-7 AF'Fi,l _ r !_):•_;11 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 6,AV COLORADO x'�.ssu o- l lFoPmUm Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ( v/t (O1 -S -dank APCD J. AIRS ID Number: I Z3 / ?Pm/ dos Section 1 - Administrative Information Company Name1: Site Name: Longs Peak Resources, LLC Motu 28-21-16-1CH Site Location: SESE Sec. 28, T12N, R65W Mailing Address: (include Zip Code) 10701 Melody Dr., Suite 515 Northglenn, CO 80234 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: David Clarkson Phone Number: 303-997-5558 E -Mail Address2: dclarkson@vrtxep.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form AP :D-'07 P -educed ankh y' _Pi Revision OZ/ 1_017 370105 COLORADO Oe f.b ER,tPubi.ertl Permit Number: AIRS ID Number: d :;I$rn9d a DC;rinit r jod Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑Q APEN submittal for permit exempt/grandfathered source Additional Info a Notes: Permit Exempt - Reg. 3, Part B.II.E.3.uu, however requesting federally enforceable limits 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: 2-400 bbl produced water tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: 04/16/2017 hours/day 7 days/week 52 I] Exploration Et Production (E&P) site weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? • Yes • No Are Flash Emissions anticipated from these storage tanks? 0 Yes • No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • 4 Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? PS Yes ■ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 • Form 4PC iD•' • 2'07 • Pi"," iuC A.P HI • R.',H;inri 02 201 7 2I AY COLORADO ➢epeemeneef?+Llic Permit Number: AIRS ID Number: Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Produced Water Throughput: From what year is the actual annual amount? Tank design: ❑✓ Fixed roof 2017 O Internal floating roof Requested Annual Permit Limit4 (bb!/year) 227234 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year)' PROD WTR 2 800 1/17 4/17 Wells Serviced by this Storage Tank or Tank Battery5 (ERP Sites On y) API Number . Name of Well Newly Reported Well 05 - 123- 404Ei Motu 28-21-16-1CH Ig ■ _ ■ ■ ■ 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.97168/-104.65852 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level (feet) (°F) (ACFM) (ft/sec) COMBUSTOR 35 1000 Indicate the direction of the stack outlet: (check one) ❑✓ Upward 0 Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑� Circular 0 Square/rectangle ❑ Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): 96 Interior stack width (inches): Interior stack depth (inches): son l7 , 3 I AVCOLORADO I N° Na. VUovnbeN Permit Number: AIRS ID Number: Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 1000 MSCfd MMBtu/hr Make/Model: Crimson Energy/CE 1000 Type: Enclosed Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 2946 0.02 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Q Section 7 -Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 51 psig Describe the separation process between the well and the storage tanks: gas and liquids from the well are routed to a 2 phase vertical separator, gas is sent to an additional separator and then to the combustor, liquids from the 1st separator are sent to a heater treater, water is sent to water tanks and oil is sent to oil tanks. Liquids from the 2nd separator are sent to the condensate tank. 41 AY COLORADO Ocpmementaf Public xessutrEsw.mnem Permit Number: bl,, i J.'_. "SD ri- AIRS ID Number: Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Combustor 95 NOx CO HAPs Combustor 95 Other: From what year is the following reported actual annual emissions data? 201 7 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/ ear) ) Controlled Emissions7 (Tons/year) Uncontrolled Emissions (Tons/year) (T Yr) Controlled Emissions (Tons/y ). VOC 0.262 lb/bbl State 29.77 1.49 NOx CO Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions 7 (Pounds/year) Benzene 71432 0.007 lb/bbl State 1590.6 79.5 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 lb/bbl State 4999.2 250.0 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. rcr rn APCD il_D i�= ApEN p i;ior„D 20 - 51 AY COLORADO Department of Public Hvt111.h EnvltonmeN Permit Number: AIRS ID Number: Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date David Clarkson COO Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 ! Dim ,11,CD-'IJ7 - tii, Si Small Business Assistance Program (303) 692-3175 or (303) 692-3148 //y�!� COLORADO 6 Y I l=E;wzat Hello