The URL can be used to link to this page

Browse Search

Home My WebLink About20170967.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 March 30, 2017 Dear Sir or Madam: RECEIVED APR 0 3 2017 WELD COUNTY COMMISSIONERS On April 6, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Synergy Resources Corporation - Wind Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health 8 Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Public CZA, Cut) (---41 1O/ 1'1 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc : PLCrnm l Tp), 1-1 L C Pt), PC -A) CF,RICH/CAS! 3MJ (-tt3/t7 2017-0967 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Synergy Resources Corporation - Wind Pad - Weld County Notice Period Begins: April 6, 2017 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Synergy Resources Corporation Facility: Wind Pad Oil and Gas Well Production Facility SESW of Section 17, Township 4N, Range 67W Weld County The proposed project or activity is as follows: Operator is requesting permit coverage for two (2) reciprocating internal combustion engines, ten (10) 400 barrel fixed roof condensate storage vessels and condensate loadout at a new synthetic minor oil and gas well production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and drafts of Construction Permits 16WE0567, 16WE0568, 16WE1049, and 16WE1050 have been filed with the Weld County Clerk's office. A copy of the draft permits and the Division's analysis are available on the Division's website at https://www.colorado.gov/ pacific/cdphe/ air- permit- public- notices The Division hereby solicits submission of public comment from any interested person concerning the 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: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us AtILW Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Harrison Slaughter 345697 3/21/2016 6/21/2016 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? Ye' ❑ Particulate Matter (PM) Synergy Resources Corporation 123 9E76 Wind Pad SESW of Section 17, Township 4N, Range 67W Exploration & Production Well`. Pad Oil & Natural Gas Production & Processln If yes, for what pollutant? LI Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application E Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Natural Gas RICE Yes 16WE0567 1 Yes Permit Initial Issuance Section 03 - Description of Project Synergy Resources Corporation submitted an application requesting permit coverage for a Caterpillar G3306NA natural gas fired reciprocating internal combustion engine. A permit will be issued for this engine because uncontrolled NOx emissions are greater than 1 tpy and uncontrolled facility wide NOx emissions are greater than 5 tpy. This facility will also include one additional natural gas fired reciprocating internal combustion engine, hydrocarbon loadout; condensate storage vessels and produced water storage vessels. The operator is requesting traditional permit coverage for the other engine, condensate storage vessels and loadout source. The operator is also requesting GP08 coverage for the produced water storage vessels. This facility is classified as a synthetic minor stationary source. Public comment will be required because the change in permitted emissions is greater than 25 tpy. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?' Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 No.•. If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Title V Operating Permits (OP): VOC, n - Hexane, Non -Attainment New Source Review (NANSR): VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Stationary source is classified as synthetic minor as described above. No Yes Section 01- Adminstrative Information Facility AIRS ID: 123 9678 001 Plant Point Section 02 - Equipment Description Details One (1) Caterpillar Model: G3306NA SNt 66804775 natural gas fired, naturally aspirated, 45RB reciprocating internal combustion engine, site rared at 145 HP and 1800 RPM. This engine will be equipped with anon-seleatve atdytk red ion INSdt) system and air -fuel Detailed Emissions Unit ratio control. This emission unit is used for natural gas compression Description: Emission Control This engine is equipped with a non -selective catalytic reduction (NSCR)'system and air -fuel Device Description: ratio control. Requested VOC Control Efficiency %: 0.00% Requested CO Control Efficiency %: 96.20% Requested HCHO Control Efficiency %: Requested NOx Control Efficiency %: Caterpillar Engine Manufacture Date: Manufacturer: Model Number: Serial Number: 66X04775 RPM: Site -rated RPM: Engine Function 1800 1800....... _........ Mfg's Max. Rated Horsepower @ sea level: berating Horsepower used for calcuations: 145 BSCF @ 100% Load (btu/hp-hr): 7471 Site - Rated BSCF @ 100% load (btu/hp-hr): 7471 Other Parameters i Engine Type a �.rr s _ Aspiration E : ,/3ys�'y� Electrical Generator Max Site Rating (kw) 0 Max hrs/yr of Operation ! 8760 Section 03 - Processing Rate Information for Emissions Estimates Fuel Use Rate @ 100% Load 833.3333333 scf/hr ACTUAL Annual Fuel Consumption 0 MMscf/yr MAX POTENTIAL Annual Fuel Consumption 7189 MMscf/yr REQUESTED Annual Fuel Consumption 7,300'? MMscf/yr Fuel Heating Value 1302 btu/scf Section 04 - Emissions Factors & Methodologies Since this is a new facility, actual fuel consumption data is not available. Requested fuel consumption rounded up. Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions NOx CO VOC 24.110 13.100 0300 PMas PM,a SO2 1.941E-02 1.941E-02 5.880E-04 0.482 0.498 g/hp-hr g/hp-hr g/hp-hr 33.76 tpy 18.34 tpy 0.70 tpy 0.68 tpy 0.70 tpy ManufaCturer 0.70 tpy Manufacturer Source Manufacturer 1.941E-02 Ib/MMBTU 0.09 Ib/MMBTU 0.09 tpy 5.880E-04 Ib/MMBTU 0.00 tpy 0.09 0.00 tpy tpy tpy AP -42 Chapter 3 Table 3.2-3 AP -42 Chapter'. 3 Table 3.2-3 AP -42 Chapter; 3 Table 3.2-3. Formaldehyde 2.300E-01 g/hp-hr 644.07 lb/yr 644.07 Ib/yr Manufacturer Acetaldehyde 2.790E-03 2.790E-03 lb/MMBTU 26.52 lb/yr 26.52 lb/yr AP -42 Chapter 3 Table 3.2.3' Emission Factor Uncontrollei Controlled Ib/MMBtu lb/MMBty 7.115E+00 1.423E-01 3.866E+00 1.469E-01 1.475E-01 1.475E-01 6.787E-02 Ib/MMBtu 9.455E-03 g/hp-hr 16WE0567.CP1.xlsm Acrolein 2.630E-03 & 2.630E-03 Ib/MMBTU 25.00 lb/yr 25.00 lb/yr AP -42 Chapter 3Table 3.2.3s Methanol 3.060E-03 3.060E-03 lb/MMBTU 29.08 lb/yr 29.08 lb/yr AP -42 Chapter 3 Table 3.2-3 Benzene 1.580E-03 1.580E-03 Ib/MMBTU 15.02 lb/yr 15.02 lb/yr AP-42Chapter'' 3 Table 3.2-3 Toluene 5.580E-04 xb 5.580E-04 Ib/MMBTU 5.30 lb/yr 5.30 lb/yr AP -42 Chapter. 3 Table -:3.2.3 Ethylbenzene 2.480E-05 2.480E-05 Ib/MMBTU 0.24 lb/yr 0.24 lb/yr AP -42 Chapter' 3 Table 3.2-3 Xylene 1.950E-04 1.950E-04 l SUS Ib/MMBTU 1.85 lb/yr 1.85 lb/yr AP -42 Chapter 3 Table 3.2-3 n -Hexane 0.000E+00 0.000E+00 Ib/MMBTU 0.00 lb/yr 0.00 lb/yr AP -42 chapter 3Table .3s23 2,2,4-TMP 0.000E+00 , ::�a = 0.000E+00 Ib/MMBTU 0.00 lb/yr 0.00 lb/yr AP -42 Chapter.. 3 Table 3.2-3 1,3 -Butadiene 6.630E-04 g s�£ 6630E-04 ord Ib/MMBTU 6.30 lb/yr 6.30 lb/yr AP -42 Chapter 3 Table 3.2.3 16WE0567.CP1.xlam 8.913E-03 g/hp-hr 1.037E-02 g/hp-r Regulatory Requirements Regulation 1 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Regulation 2 Section LA - 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. Regulation 3 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. Applicant is required to file an APEN since emissions exceed 1 ton per year NOx. Part B — Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled NOx emissions from this facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.0.2.a) Regulation 7 Section XVI.B: This engine has a design rate less than 500HP (reported as 145HP) and is located in the ozone non -attainment area. As a result, the engine is not subject to the air pollution control technology requirements of Section XVI.B.1 for rich burn engines. Section %VILE: According to Regulation 7 Section XVII.B.5: "internal combustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Best Available Control Technology ("BAR") limit, or a New Source Performance Standard ("NSPS") under 40 CFR Part 60 are not subject to Section XVII., except for the leak detection and repair requirements in Section XVII.F." This engine does not have emission control requirements per MACT ZZZZ and is not subject to NSPS JJJJ. As a result, it is subject to the emission control requirements of Regulation 7 Section XVII.E. MACT 7777 The engine at this facility is subject to MACT ZZZZ. The facility is an area source of HAPs, so engine is not subject to major source requirements. Since this engine is located at an area source of HAP emissions and commenced construction after June 12, 2006, it is classified as a "New Stationary Rice." According to §63.6590(c): "An affected source that meets any of the criteria in paragraphs (c)(1) through (7) of this section must meet the requirements of this part by meeting the requirements of 40 CFR part 60 subpart IIII, for compression ignition engines or 40 CFR part 60 subpart JJJJ, for spark ignition engines. No further requirements apply for such engines under this part. This engine meets the criteria of §63.6590(c((1) "A new or reconstructed stationary RICE located at an area source." As such, it will meet the requirements of MACT ZZZZ by meeting the requirements of NSPS JJJJ. NSPS JJJJ Is this engine subject to NSPS JJJJ? I I,2,"�a�'' Based on the information provided on the APEN, the engine commenced construction (was ordered by the operator) after June 12, 2006 but was manufactured prior to July 1, 2008 (See 40 CFR §60.4230 (a)(4) and §60.4230 (a)(4)(iii)). As a result, this engine is not subject to NSPS JJJJ, Additionally, it is likely that this engine was installed at a different facility prior to July 1, 2010 (See 40 CFR §60.4236 (a)). This further supports the determination that this engine is not subject to NSPS JJJJ. Since this engine is not subject to emission control requirements under NSPS JJJJ or MACT ZZZZ, it is subject to the emission control requirements of Colorado Regulation 7 Section XVII.E (See the determination above). Additional Notes: - - 1. The emission data provided by the operator for this engine is based on a manufacturer specification sheet and a catalyst data sheet. Since the emission factors for the engine differed between the -data sheets, I requested that theoperator use the most conservative emission factor for each pollutant based on the data: provided. This method was proposed for the following reasons: (i) Based on the data provided, it is not clear which data set is a more accurate representation of actual emissions. (it) By selecting the most conservative value for each pollutant theresulting calculations are conservative based on the information provided with the application. The operator a greed with this request and updated their calculations accordingly..;- - --- - 2. The operator calculated VOC emissions assuming an emission factor of 0.5 g(hp-hr. This emission factor is based on the catalyst specification sheet which indicates post catalyst emissions to be achieved; by the control equipment is <0.5 g/bhp-hr for VOC. It was determined that this emission factor was conservative because the emission factor provided by the manufacturer for VOC is 0.16 g/bhp-hr. Since the value used for calculations is conservative and in compliance with the standard in CO reguia tion 7 Section XVII.E,.it was determined to be acceptable for - permitting purposes. 3. As described above, this engine is subject to CO: Regulation 7 Section XVII.E since it does not have an emission standard ore mission control requirement perMACI' 2722andisnotsubject to NSPS MIL .The emission standards this engine is subject to per Regulation 7 Section XVII.E.2.b are as follow: (i) NOx: 1.0 gfhp-hr (ii) CO::20 Op -brand (iji) VOC. 0,7 g/hp-hr (requirements for engines 100<HP<S00 construction date after January1, 2011). The operator has indicated the controlled emission factor fo r NOx, CO andVOCis0.5g/hp-hr. This assertion isbased on the EMIT Technologiescatalyst specification sheet submitted with the application which states "Post Catalyst Emissions to be Achieved by Emission Control Equipment" is <0.5 g/hp-hr for NOx, CO and VOC. These emission factors are in compliance with Regulation 7 Section XVR.E.2.b standards and thus were determ fined to be acceptable for permitting puposes, 4. The operator provided the following informational dates on the APEN:(i)- Engine Order Date: 11/30/2015, (ii) Date engine comm enced construction: 12/17/2015, (iii)Date engine was -. relocated into Colorado:: 12/17/2015, and (iv) Date of any reconstruction/modification: If/A - - - 5. The operator originally calculated formaldehyde (HCHO)emissions using the AP-42emission factor. However, the manufacturer specification sheet submitted with the application provided an engine specific emission factor for HCHO, I expressed to the operator that engine specific emissions factors, whe n available, should be utilized instead of AP -42. The operator agreed with this assertion and requested that HCHO be updated on the APEN be updated to reflect the use of the manufacturer p ed- emission factor. 6. Condition#6 in. the RICE permit template requiresthatthe following information be provided with the notice of startup (NOS) i manufacture date, construction date, order date, date of relocation into CO, manufacturer, model number,and serial number. Since thisinformation was already provided on the APEN su bmitted, this condition was removed from the permit. 16WE0567.CP1.xlsm 7. Even though this engine has a site rated horsepowergreater than 500,. it was determined initial compliance testing would notbe required because the facility is, classified as a true source of NO; CO, and formaldehyde. This determination is consistent with the initial testing requirements for general perm! t 02 registrations. 8. The operator reviewed the draft permit and APEN redlines prior to public comment. The operator expressed they did not have any comments on either document.' 16WE0567.CP1.xlsm AIRS (County/Plant) 123/9E7B Permit No. 16WE0567 Date 6/21/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)' PTE (tpy)* Ctrl. Eff% NCRP = reportable ? 001 20200253 NOx 7.1100E+00 Ib/MMBTU Manufacturer 0.70 33.76 - 98% Yes 001 20200253 CO 3.8600E+00 Ib/MMBTU Manufacturer 0.70 18.34 96.2% Yes 001 20200253 VOC 1.4700E-01 lb/MMBTL Manufacturer 0.70 0.70 0% No 001 20200253 PM2.5 1.9410E-02 Ib/MMBTL AP -42 0.09 0.09 0% No 001 20200253 PM,o 1.9410E-02 Ib/MMBTL AP -42 0.09 0.09 0% No 001 20200253 SO2 5.8800E-04 Ib/MMBTU AP -42 0.00 0.00 0% No 001 20200253 Formaldehyde 6.7800E-02 Ib/MMBTU Manufacturer 644.00 644.00 0% Yes 001 20200253 Acetaldehyde 2.7900E-03Ib/MMBTUAP-42 27.00 27.00 0% No 001 20200253 Acrolein 2.6300E-03 Ib/MMBTL AP -42 25.00 25.00 0% No 001 20200253 Methanol 3.0600E-03 Ib/MMBTU AP -42 29.00 29.00 0% No 001 20200253 Benzene 1.5800E-03Ib/MMBTL AP -42 15.00 15.00 0% No 001 20200253 Toluene 5.5800E-04Ib/MMBTLAP-42 6.00 6.00 0% No 001 20200253 Ethylbenzene 2.4800E-05 Ib/MMBTU AP -42 1.00 1.00 0% No 001 20200253 Xylene 1.9500E-04Ib/MMBTUAP-42 2.00 2.00 0% No 001 20200253 n -Hexane 0.0000E+00Ib/MMBTUAP-42 0.00 0.00 0% No 001 20200253 2,2,4-TMP 0.0000E+00 lb/MMBTL AP -42 0.00 0.00 0% No 001 20200253 1,3 -Butadiene 6.6300E-04 Ib/MMBTL AP -42 7.00 7.00 0% No **HAP emissions have units of lbs/year. Permit number: Date issued: Issued to: DO on : ~ trot Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE0567 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Synergy Resources Corporation Wind Pad 123/9E7B SESW SEC 17 T4N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description ENG-1 001 One (1) Caterpillar Model: G3306NA SN: G6X04775 natural gas fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 145 HP and 1800 RPM. This emission unit is used for natural gas compression Non -Selective Catalytic Reduction (NSCR) System and Air -Fuel Ratio Controller This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3306NA 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 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. COLORADO Air Pollution Control Division iert--� atl�--lt c: wcxm�:�.rc Page 1 of 14 ghty d. x. (180) of the latter of commencement of operation or ssuan - •f •e "` plia - `with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO ENG-1 001 --- 0.7 --- 0.7 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled COLORADO Air Pollution Control Division ct PubL, Iles'h El'Act,1731,n. Page 2 of 14 Non -ctive catalytic reduction (NSCR) system and Air -Fuel Ratio Controller NOx and CO PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit ENG-1 001 Consumption of natural gas as a fuel 7.3 MMscf The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. 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. (Reference: Regulation Number 1, Section II.A.1. Et 4.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ≥500HP July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 COLORADO Air Pollution Control Division Page 3 of 14 nameplate rating of the engine and does not account for OPERATING Et MAINTENANCE REQUIREMENTS 13. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OEtM) 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 OEM 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 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 (OErM) plan as approved by the Division. Revisions to your OEM 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. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: 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 fivepercent, 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. COLORADO Air Pollution Control Division Uep r ni i i : ut7- t ivE,Ivironrrint Page 4 of 14 cal £ da:hays of mmencing operation of a permanent replacement engine under .__.,e al erns ive opera mg 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. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 18. 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. 19. 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. 20. 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. 21. 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. 22. 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. 23. 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. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal COLORADO Air Poilutiort Control Division Page 5 of 14 By: 25-7-115 (enforcement), -121 (injunctions), -122 (civil C.R.S. Harrison Slaughter Permit Engineer it Histo Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation Permit for one (1) natural gas reciprocating internal combustion engine at a new synthetic well production facility located in the ozone non - attainment area. COLORADO Air Pollution Control Division }kith&'1.v0t:a,te Page 6 of 14 No this it 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Formaldehyde 50000 644 644 Acetaldehyde 75070 27 27 Acrolein 107028 25 25 Methanol 67561 29 29 Benzene 71432 15 15 Toluene 108883 6 6 Ethylbenzene 100414 1 1 Xylenes 1330207 2 2 1,3 -Butadiene 106990 7 7 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 7.11 24.11 1.47x10-1 0.5 CO 3.86 13.1 1.47x101 0.5 VOC 1.47x10-1 0.5 1.47x10 -t 0.5 50000 Formaldehyde 6.78X10-` 0.23 6.78X1O` 0.23 COLORADO Air Pollution Control Division Page 7 of 14 n a Br 'e -Specific Fuel Consumption Factor of 7,471 Btu/hp-hr, a f 14 , • d a fuel heat value of 1,302 Btu/scf. y CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) 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.Rov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, and Total HAPs NANSR Synthetic Minor Source of: VOC MACT ZZZZ Major Source Requirements: Not Applicable Area Source Requirements: Applicable NSPS JJJJ Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP COLORADO Air Pollution Control Division Page 8 of 14 ��_•3.a•3 • � S _art 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 9 of 14 ACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests. and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so COLORADO Air Pollution Control Division Pub t lc. €'vas t a. uK,,rt Page 10 of 14 long +er ant r .la e ' engine mplies with all permit limitations and other requirements app :: a to - e "" - wel . `any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: 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 COLORADO Air Pollution Control Division Page 11 of 14 repl e.' m.wllrbe •7e to, th results of the test shall be converted to the appropriate uni - •escr _. in .bo' - oned able 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. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B S 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 precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and'XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. COLORADO Air Pollution Control Division SJ�w r t �atP,ablictieaith Page 12 of 14 The •� ��o on .ol eip nt shall=� e appropriately sized for the engine and shall be operated an." ain `:. c• : to .` lure : -cifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E - State -only requirements 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, § 1.8 (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 COLORADO Air Pollution Control Division Page 13 of 14 Appl - Re or red= ire• nd > Condit n 2.1.2. Any testing required by the MACT is in addition to tha -• fired • h • •=t the ial test required by the MACT can serve as the testing required by this A0S under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The A0S is therefore essentially an advanced construction permit review. The A0S 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. COLORADO Air Pollution Control Division PACc He '1 F&t Lo.rr,,n,, Page 14 of 14 Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Package It: Received Date: Review Start Date: Section 01- Facility Information Harrison Slaughter 345697 3/21/2016 6/21/2016 - 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 Synergy Resources Corporation 123 9E76' Wind Pad SESW of Section 17, Township 4N, Range 67W Exploration & ProductionWelt Pad Oil & Natural Gas Production & Processing ;. Yes ❑ Particulate Matter (PM) O Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 002 :? Natural Gas RICE Yes _ 16WE0568 1 Yes lrrnrt Irkitral ! Is€d zCe Section 03 - Description of Project Synergy Resources Corporation submitted an application requesting permit coverage for a Caterpillar G3516TALE natural gas fired reciprocating internal combustion engine. A permit will be issued for this engine because uncontrolled NOx emissions are greater than 1-tpy and uncontrolled facility wide NOx emissions are greater than 5 tpy. This facility will also include one additional natural gas fired reciprocating internal combustion engine, hydrocarbon loadout, condensate storage vessels and produced water storage vessels. The operator is requesting traditional permit coverage for the other engine, condensate storage vessels and loadout source. The operator is also requesting GP08 coverage for the produced water storage vessels. This facility is classified as a synthetic minor stationary source. Public comment will be required because the change in permitted emissions is greater than 25 tpy. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?' Yes Greater than 25 tons per year in Non Attainment Area Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?' No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: : Title V Operating Permits (OP) : VOC, n -Hexane, and Total HAPs Non -Attainment New Source Review (NANSR}: VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Stationary source is classified as synthetic minor as described above. Section 01- Adminstrative Information Facility AIRs ID: 123 9E76 002 County Plant Point Section 02 - Equipment Description Details One (1) Caterpillar Model: 133516TALE5N: WPW02668 natural gas fired, turbocharged, 431.9 reciprocating internal combustion engine, site rated at 1,340 HP and 1400RPM. This engine will be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit Detailed Emissions Unit used for natural gas compression. Description: Emission Control Device Description: Requested VOC Control Efficiency %: Requested CO Control Efficiency %: Requested HCHO Control Efficiency %: Requested NOx Control Efficiency %: engine is equipped with an oxidation catalyst and air -fuel ratio control. /16/2008 ?. Engine Manufacture Date: Manufacturer: Model Number: Serial Number: RPM: Site -rated RPM: Engine Function Caterpillar 3516TALE WPW02668 '.'. 1400`. 1400 Mfg's Max. Rated Horsepower @ sea level: 1340 _ berating Horsepower used for calcuations: 1340 BSCF @ 100% Load (btu/hp-hr): '' 8369 Site - Rated BSCF @ 100% load (btu/hp-hr): 8369 Other Parameters Engine Type Aspiration Max Site Rating (kw) 0 Electrical Generator Max hrs/yr of Operation 8760. Section 03 - Processing Rate Information for Emissions Estimates Fuel Use Rate @ 100% Load 8618.721461 scf/hr ACTUAL Annual Fuel Consumption 0 MMscf/yr MAX POTENTIAL Annual Fuel Consumption 75.452 MMscf/yr REQUESTED Annual Fuel Consumption 75.500 MMscf/yr Fuel Heating Value ': 1302 btu/scf Ion 04 - Emissions Factors & Methodologies Since this is a new facility, actual fuel consumption data is not available. Requested fuel consumption rounded up. Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 1.500 ;3 1.500 g/hp-hr 19.37 tpy 19.37 tpy ' Manufad ureri CO 1.890 '�" 0.189 g/hp-hr 24.46 tpy 2.45 tpy Manufacturer VOC '0:611 0.128 g/hp-hr 7.91 tpy 1.66 tpy Manufacturer PM, 9.987E-03 9.987E-03 lb/MMBTU 0.49 tpy 0.49 tpy AP -42 Chapter 3 Table 3.2-2 PM,,,, 9.987E-03 ; 9.987E-03 lb/MMBTU 0.49 tpy 0.49 tpy AP -42 Chapter. 3 Table 3.2-2 502 5.880E-04 ;; 5.880E-04 lb/MMBTU 0.03 tpy 0.03 tpy AP -42 Chapter 3 Table 3.2-2 Formaldehyde 2.590E-01 - 2.500E-01 g/hp-hr 6469.68 lb/yr 6469.68 lb/yr Manufacturer Acetaldehyde 8.360E-03 8.360E-03 lb/MMBTU 821.80 lb/yr 821.80 lb/yr AP -42 Chapter 3 Table 3.2-2 Emission Factors Uncontrolled Controlled Ib/MMBtu Ib/MMBtu 3.951E-01 3.951E-01 4.979E-01 4.979E-02 1.610E-01 3.381E-02 6.586E-02 Ib/MMBtu 3.174E-02 g/hp-hr 16WE0568.CP1.xlsm Acrolein 5.140E-03 5.140E-03 Ib/MMBTU 505.27 lb/yr 505.27 lb/yr AP-a2Chapter 3 Table 3.2-2 Methanol 2.500E-03 2.500E-03 Ib/MMBTU 245.75 lb/yr 245.75 lb/yr -42 Chapter �' 3Table 3.22 Benzene 4.400E-04 4.400E-04 Ib/MMBTU 43.25 lb/yr 43.25 lb/yr ��' 3 Table 3.2-2 Toluene 4.080E-04 4.080E-04 Ib/MMBTU 40.11 lb/yr 40.11 lb/yr �-42 � 3 Table 3.2-2 Ethylbenzene 3.970E-05 3,970E-05 Ib/MMBTU 3.90 lb/yr 3.90 lb/yr AP -42 Chapter 3Table 3.2-2 Xylene 1.840E-04 1.840E-04 Ib/MMBTU 18.09 lb/yr 18.09 lb/yr AP -42 Chapter' 3Table 3.2-2 n -Hexane 1.110E-03 1.110E-03 Ib/MMBTU 109.11 lb/yr 109.11 lb/yr AP-42Owptery 3 Table 32-2 2,2,4-TMP 2.500E-04 2.500E-04 Ib/MMBTU 24.58 lb/yr 24.58 lb/yr AP -42 Chapter' 3 Table 3.2-2 1,3 -Butadiene 2.670E-04 2.670E-04 Ib/MMBTU 26.25 lb/yr 26.25 lb/yr AP -42 3 Table 3.2-2 16WE0568.CP1.xlsm 1.951E-02 g/hp-hr 9.490E-03 g/hp-hr Regulation 1 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Regulation 2 Section I.A - 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. Regulation 3 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. Applicant is required to file an APEN since emissions exceed 1 ton per year NOx and VOC. Part B — Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled NOx emissions from this facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.0.2.a) Regulation 7 Section XVI.B: This engine has a design rate greater than 500HP (reported as 1,340HP) and is located in the ozone non -attainment area. As a result, the engine is subject to the air pollution control technology requirements of Section XVI.B.2 for lean burn engines. Section XVII.E: According to Regulation 7 Section XVII.B.5: "internal combustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Best Available Control Technology ("BACT') limit, or a New Source Performance Standard ("NSPS") under 40 CFR Part 60 are not subject to Section XVII., except for the leak detection and repair requirements in Section XVII.F." This engine is subject to emission control requirements per NSPS Jill and is thus not subject to Regulation 7 Section XVII.E. MACT 7777 The engine at this facility is subject to MAR ZZZZ. The facility is an area source of HAPs, so engine is not subject to major source requirements. Since this engine is located at an area source of HAP emissions and commenced construction after June 12, 2006, it is classified as a "New Stationary Rice." According to §63.6590(c(: "An affected source that meets any of the criteria in paragraphs (c)(1) through (7) of this section must meet the requirements of this part by meeting the requirements of40 CFR part 60 subpart 1111, for compression ignition engines or 40 CFR part 60 subpart JJJJ, for spark ignition engines. No further requirements apply for such engines under this part." This engine meets the criteria of §63.6590(c)(1) "A new or reconstructed stationary RICE located at an area source." As such, it will meet the requirements of MAR ZZZZ by meeting the requirements of NSPS JJJJ. NSPS JJJJ Is this engine subject to NSPS JJJJ? I I Based on the information provided on the APEN, the engine commenced construction (was ordered by the operator) after June 12, 2006 and was manufactured after to January 1, 2008 (See 40 CFR §60.4230 (a)(4) and §60.4230 (a)(4)(ii)). As a result, this engine is subject to NSPS JJJJ. Note: JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Additional Notes: - - - - - - -- - 1. As described above, this engine is subject to NSPSJJJJ. The emission standards this engine is subjectto per NSPS .1.01 Table l are as follow: (i)NOJt:. 2.0 g/lip-hr(ii) CO: 4.0g/hp-hr and (iii) VOC. 1.0 g/hp-hr-(requirements for non -emergency lean burn natural gas engines 500<HP<1350 with, manufacture date after January 1, 2008 but, before June 1, 2030). The operator has Indicated the controlled emission factors for NOx, CO and VOC are 1.5 g/hp•hr, 1.89x10°g/hp-hr and 1.2Bx1Qi g/hp-hr respectively. These values are in compliance with the NSPS AU emission standards indicated above. These controlled emission factors are based on the MIRATECH Emissions. Control Equipment Specification Summary provided with the application. This. specification sheet provides warranted converter outputs that correspond toe 90% control efficiencyfor CO and an 80% control efficiency for formaldehyde. Even though the catalystsheet provides a controlefficiency for formaldehyde, the operator is not taking credit for the control: This a conservative estimate and therefore acceptable. The specification sheet also provides a warranted converter output of 0.13 g/hp•hr for VOC which corresponds to a control efficiency of 79%. These control percentage values are within the expected control range for a- properly operated and maintained oxidation catalyst and therefore acceptable for permitting purposes. - - - 2. The operator provided the following informationaldates on the APEN: (i) Engine Order Date: 11/2008, (ii) Date engine commenced construction: 11/2009, ji1)Date engine was relocated into Colorado:. 03/2016, and (iv) Date of any reconstruction/modification: N/A. 3. The VOC emission factor reported on page 1 of the manufacturer data sheet is 0.31 g/hp-hr. Note 8 o page three of the data sheet indicates this emission factor does not include aldehydes. As a result the manufacturer provided emission factor for formaldehyde and AP -42 emission factors for acrolein and acetaldehyde were added to the emission factor in order to include aldehydes. By adding these emission factors, the total VOC emission factor was determined to be 0.61125 g/hp-hr. The operator was informed of this and agreed to use the updated VOC emission factor for calculations_ 4. Condition R6 in the RICE permit template requires that the following information be provided with the notice of startup (NOS$ manufacture date, construction date, order date, date of, relocation into CO, manufacturer, model number, and serial number. Since this information was already provided on the APEN submitted, this condition wasremoved. from the permit 5. The APEN submitted for this source indicated it is equipped with art air/fuel ratio controller.. As a result, I requested the operator to update the O&M plan for this source to include monitoring requirements for the air/fuel ratio controlled. Theoperator agreed andprovided an updated O&M plan for this source on February 2017. 6. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they did not have any. comments: 16WE0568.CP1.xism AIRS (County/Plant) 123/9E7B Permit No. 16WE0568 Date 6/21/2016 Point 8 SCC Pollutant or CAS Uncontrolled Emission Factor Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable ? 002 20200254 NOx 3.9514E-01 Ib/MMBTL Manufacturer 19.40 19.40 0% Yes 002 20200254 CO 4.9788E-01 Ib/MMBTL Manufacturer 2.50 24.46 90% Yes 002 20200254 VOC 1.6102E-01 Ib/MMBTU Manufacturer 1.70 7.91 79% Yes 002 20200254 PM, 9.9871E-03Ib/MMBTLAP-42 0.49 0.49 0% No 002 20200254 PM10 9.9871E-03Ib/MMBTLAP-42 0.49 0.49 0% No 002 20200254 SO2 5.8800E-04 lb/MMBTLAP-42 0.03 0.03 0% No 002 20200254 Formaldehyde 6.5857E-02Ib/MMBTL Manufacturer 6470.00 6470.00 0% Yes 002 20200254 Acetaldehyde 8.3600E-03Ib/MMBTLAP-42 822.00 822.00 0% Yes 002 20200254 Acrolein 5.1400E-03 Ib/MMBTL AP -42 506.00 506.00 0% Yes 002 20200254 Methanol 2.5000E-03 Ib/MMBTL AP -42 246.00 246.00 0% No 002 20200254 Benzene 4.4000E-04Ib/MMBTLAP-42 44.00 44.00 0% No 002 20200254 Toluene 4.0800E-04 lb/MMBTLAP-42 41.00 41.00 0% No 002 20200254 Ethylbenzene 3.9700E-05 Ib/MMBTU AP -42 4.00 4.00 0% No 002 20200254 Xylene 1.8400E-04Ib/MMBTU AP -42 18.00 18.00 0% No 002 20200254 n -Hexane 1.1100E-03 lb/MMBTLAP-42 110.00 110.00 0% No 002 20200254 2,2,4-TMP 2.5000E-04 lb/MMBTLAP-42 25.00 25.00 0% No 002 20200254 1,3 -Butadiene 2.6700E-04Ib/MMBTLAP-42 27.00 27.00 0% No **HAP emissions have units of lbs/year. Permit number: Date issued: Issued to: D© on trot Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE0568 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Synergy Resources Corporation Wind Pad 123/9E7B SESW SEC 17 T4N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description ENG-2 002 One (1) Caterpillar Model: G3516TALE SN: WPW02668 natural gas fired, turbocharged, 4SLB reciprocating internal combustion engine, site rated at 1,340 HP and 1400 RPM. This emission unit is used for natural gas compression. Oxidation catalyst and Air -Fuel Ratio Controller This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3516TALE 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 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. COLORADO Air Pollution Control Division Page 1 of 14 2. in n un` ed d ghty d. (180) of the latter of commencement of operation or ssuan - if ` ` .e "`" •' plia with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO ENG-2 002 --- 19.4 1.7 2.5 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 COLORADO Air Pollution Control Division nrrci?Jr Pakd�:_ tieait'+b S.�avur�e +iti Page 2 of 14 O ion Catalyst and Air -Fuel Ratio Controller VOC and CO PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit ENG-2 002 Consumption of natural gas as a fuel 75.5 MMscf The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. 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. (Reference: Regulation Number 1, Section II.A.1. it 4.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. OPERATING Et MAINTENANCE REQUIREMENTS 13. Upon startup of this point, 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 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 (OEtM) plan as approved by the Division. Revisions to your O&M plan are subject to COLORADO Air Pollution Control Division ]'-tied• sErWV0£17,nt. Page 3 of 14 ents of is unit completed as Alternative Operating Scenarios may g re•''-ments as specified in Attachment A. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: 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. • 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. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). 18. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation Number 8, Part E) .COLORADO Air Pollution Control Division ;:epartTrx,^.<<;f PubUc 7.1eaith 6 ,?,aonrr, nc Page 4 of 14 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History COLORADO Air Pollution Control Division Page 5 of 14 . a ate Description Issuance 1 This Issuance Issued to Synergy Resources Corporation Permit for one (1) natural gas reciprocating internal combustion engine at a new synthetic minor well production facility located in the ozone non - attainment area. COLORADO Air Pollution Control Division Page 6 of 14 No this a it 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 002 Formaldehyde 50000 6,470 6,470 Acetaldehyde 75070 822 822 Acrolein 107028 506 506 Methanol 67561 246 246 Benzene 71432 44 44 Toluene 108883 41 41 Ethylbenzene 100414 4 4 Xylenes 1330207 18 18 n -Hexane 110543 110 110 2,2,4- Trimethylpentane 540841 25 25 1,3 -Butadiene 106990 27 27 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr N0x 3.95x10-1 1.5 3.95x10-1 1.5 CO 4.97x10-1 1.89 4.97x10-2 1.89x10-1 'COLORADO Air Pollution Control Division Page 7 of 14 A Emission Uncontrolled Factors - Emission Factors - Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr 1.28x10"1 VOC 1.61x10-1 6.11x10-1 3.38x10-1 50000 Formaldehyde 6.58x10-` 2.5X10-1 6.58x10"1 2.5X1O1 75070 Acetaldehyde 8.36x1O' 3.17x10-` 8.36x1O' 3.17x10-` 107028 Acrolein 5.14x10-3 1.95x1O` 5.14x1O3 1.95x10-` 67561 Methanol 2.5x1O" 9.49x103 2.5x10-3 9.49x1O' Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8,369 Btu/hp-hr, a site -rated horsepower value of 1,340, and a fuel heat value of 1,302 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer 75070 Acetaldehyde AP -42 Chapter 3 Table 3.2-2 AP -42 Chapter 3 Table 3.2-2 107028 Acrolein AP -42 Chapter 3 Table 3.2-2 AP -42 Chapter 3 Table 3.2-2 67561 Methanol AP -42 Chapter 3 Table 3.2-2 AP -42 Chapter 3 Table 3.2-2 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 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.Rov/ttn/atw/area/fr18ja08.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.gov/ttn/atw/area/fr181a08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, and Total HAPs NANSR Synthetic Minor Source of: VOC MACT ZZZZ Major Source Requirements: Not Applicable Area Source Requirements: Applicable NSPS JJJJ Applicable COLORADO Air Pollution Control Division Page 8 of 14 10) vironment Electronic Code of Federal Regulations can be 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 9 of 14 ACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so COLORADO Air Pollution Control Division epuI**len5.O Public f'{P_%i°.!': J ^,C JiR',01C Page 10 of 14 long - ".er ah �t r .la a engine .mplies with all permit limitations and other requirements app . e to e`er " '"• - " '- ':' wel .' any new applicable requirements for the replacement Y�� PP q P engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: 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 COLORADO Air Pollution Control Division DepunrrIer, r ubL .f eE ^�curti-..:.rxc Page 11 of 14 repl uni ° . .esc to, th results of the test shalt be converted to the appropriate in " ` .bo''-- - ` oned • able 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. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B S 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 precursors to PM10, if the potential to emit of NOX or S02 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 (S 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. :COLORADO Air Pollution Control Division ,A Pull- 7.11,er, Page 12 of 14 The nt shalle appropriately sized for the engine and shall be operated an. "' ain .: c• to T ture .=cifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E - State -only requirements 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, 5 1.8 (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 COLORADO Air Pollution Control Division ;rri, �;t �==at:1: Fled°": `• ^<u �irr;e?ic Page 13 of 14 Appl : • R }o re• ire• nd Condit n 2.1.2. Any testing required by the MACT is in addition to than =• lred •+ h• t the ial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. COLORADO Air Pollution Control Division D4.%:;s'tit eni 0f P-atd.; !-.:`ikTonr^ 'lt Page 14 of 14 Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Harrison Slaughter-: 345697 9/20/2016 11/8/2016 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Synergy Resources Corporation 123 9E7B Wind Pad SESW of Section 17, Township 4N, Range 67V Exploration & Production Well Pad Oll;& Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) Section 02 - Emissions Units In Permit Application ❑� Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 004 Hydrocarbon Liquid Loading;; - No 16WE1049 1 Y Permit Initial. itsuance Section 03 - Description of Project Synergy Resources Corporation submitted an application requesting permit coverage for hydrocarbon liquid loading from condensate storage vessels to tank trucks. A permit will be issued for this engine because uncontrolled VOC emissions are greater than 1 tpy and uncontrolled facility wide VOC emissions are greater than 2 tpy. This facility will also include two natural gas fired reciprocating internal combustion engines, condensate storage vessels and produced water storage vessels. The operator is requesting traditional permit coverage for the engines and condensate storage vessels. The operator is also requesting GP0& coverage for the produced water storage vessels. This facility is classified as a synthetic minor stationary source. Public comment will be required because the change in permitted emissions is greater than 25 tpy. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?1 Yes Greater than 25 tons per year in Non -A Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Area Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs and which pollutants here: Title V Operating Permits (OP) : VOC, n -Hexane, and Total HAPs Non -Attainment New Source Review (NANSR): VOC No Is this stationary source a major source? If yes, explain what programs and which pollutants here: Stationary source is classified as synthetic minor as described above. Yes Section 01- Adminstrative Information Facility AIRs ID: 123 County 9E7B 004 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Condensate loadoutto tank trucks. Description: Emission Control Device Emissions from this source are not controlled. Description: Requested Overall VOC & HAP Control Efficiency 0 Section 03 - Processing Rate Information for Emissions Estimates Actual Throughput = Annual requested Throughput = Section 04 - Emissions Factors & Methodologies L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded 64106 Barrels (bbl) per year 76928 Barrels (bbl) per year 3230976 gal/yr Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 Table 5.2-1: Submerged Loading - Dedicated normal service P True Vapor Pressure 5.2 psia AP -42 Table 7.1-2 (Gasoline RVP 10 @ 50° F) M Molecular Weight of Vapors 46.69 lb/lb-mole ProMax - Working and Breathing Emission Stream T Liquid Temperature 511 deg. R Annual Average Temperature for Denver, CO L NCRPs Component 3.55 lb/10^3 gal 1.49E-01 lb/bbl Mass Fraction Benzene 0:0021 Toluene 0.0019 Ethylbenzene 0. Xylenes 0.006 n -Hexane 0.0237 2,2,4 -TM P 00001 Source: Weight % values calculated from ProMax simulation - See additional notes section for additional details. Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1492 lb/bbl 5.738 tpy 5.74 tpy AP -42 Benzene 3.148E-04 lb/bbl 24.22 lb/yr 24.22 lb/yr Mass Balance Toluene 2.849E-04 lb/bbl 21.92 lb/yr 21.92 lb/yr Mass Balance Ethylbenzene 1.238E-05 lb/bbl 0.95 lb/yr 0.95 lb/yr Mass Balance Xylene 8.220E-05 lb/bbl 6.32 lb/yr 6.32 lb/yr Mass Balance n -Hexane 3.536E-03 lb/bbl 271.99 lb/yr 271.99 lb/yr Mass Balance 2,2,4-TMP 2.178E-05 lb/bbl 1.68 lb/yr 1.68 lb/yr Mass Balance Actual Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1492 lb/bbl 4.78 tpy 4.78 tpy AP -42 Benzene 3.148E-04 lb/bbl 20.18 lb/yr 20.18 lb/yr Mass Balance Toluene 2.849E-04 lb/bbl 18.27 lb/yr 18.27 lb/yr Mass Balance Ethylbenzene 1.238E-05 lb/bbl 0.79 lb/yr 0.79 lb/yr Mass Balance Xylene 8.220E-05 lb/bbl 5.27 lb/yr 5.27 lb/yr Mass Balance n -Hexane 3.536E-03 lb/bbl 226.66 lb/yr 226.66 lb/yr Mass Balance 2,2,4-TMP 2.178E-05 lb/bbl 1.40 lb/yr 1.40 lb/yr Mass Balance Regulatory Review 'Regulation 1- Particulate, Smoke, Carbon Monoxide, and Sulfur Dioxide 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. (Reference: Regulation No. 1, Section II.A.1. & 4.) 'Regulation 2 - Odor Section I.A - 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. Regulation 3 -APEN and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Yes Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? No If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.l Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? No If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.l Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B — Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.2.a) Part B, III.D.2 - RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8 -hour ozone nonattainment area, but not the 1 -hour ozone area. The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8 -hour ozone NA area designation). Since the tank battery from which loadout is occurring came into service after the date above (reported operation began December 2015), this source is considered "new or modified." Operator is using submerged fill (0.6 saturation factor), therefore, RACT requirements are satisfied. Regulation 6 - New Source Performance Standards No applicable subpart. This facility is not a bulk gasoline terminal. Regulation 7 - Volatile Organic Compounds No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that has a daily average throughput of more than 76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport vehicles. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Regulation 8 - Hazardous Air Pollutants MACT EEEE: Not subject because facility is classified as a synthetic minor source of HAPs. It should also be noted that the loadout operation is located at a production field facility and thus would be exempt per 40CFR 63.2334(c)(1). Additional Notes: 1. The operator obtained the true vapor pressure from Table 7.1-2 in AP -42. The operator assumed an RVP of 10 and. temperature of 60'F. Based on data reported to COGCC for the wells at this facility, the average API gravity of the condensate is 47.25. Using this value along with equation 2 in PS Memo 05-01 (RVP = [0:179*Safes Oil API Gravity] - 1.699), the RVP of the sales oil was determined to be 6.76. With this value in mind, it was determined that using the RVP of gasoline with RVP 10 from AP -42 was a conservative estimate. 2. The mass fractions used to calculate HAP emissions in this analysis were calculated based upon the ratio of the individual HAP mass flow rate to the total VOC mass flow rate predicted by the ProMax simulation for the condensate storage vessels. The calculations are as follow: (i) Benzene: (0.126 ton Benzene/year)/(59.66 ton VOC/year) = 0.00211 (ii) Toluene: (0.114 ton Toluene/year)/(59.66 ton VOC/year) = 0.00191 (iii) Ethylbenzene: (0.00495ton Ethylbenzene/year)/(59.66 ton VOC/year) = 0.000083 (iv) Xylene: (0.0328 ton Xylene/year)/(59.66 ton VOC/year) = 0.00055 (v) n -Hexane: (1.412 ton n-Hexane/year)/(59.66 ton VOC/year) = 0.0237 (vi) 2,2,4-TMP: (0.00873 ton 2,2,4-TMP/year)/(59.66 ton VOC/year) = 0.000146 Typically, the operator will use the weight % values from the working and breathing stream calculated by ProMax to estimate the loadout HAP emissions. In this instance, the weight percent values calculated by ProMax are less conservative compared to the method described above. As a result, the method described above was considered acceptable for permitting purposes. 3. The molecular weight used to calculate the VOC emission factor is based onthe weighted average of the molecular weight values calculated by ProMax for the flash gas and working and breathing streams. The calculation is as follows: ((0.0611351MMscf/day}/(0.06403178M M scf/day)] *46;6821 I b/lb-mol )+ ([(0.00289668MMscf/day)/(0.06403178MMscf/day)]*46.8693 Ib/Ib-mol} = 46.69 lbit bmol 4. Based on the application, condensate from the storage vessels is typically transferred down stream via pipeline using a lease automated custody transfer (LACT)unit.` In instances when the LACT unit is unavailble or must be shut down, the condensate may be loaded out from the storage vessels using tank trucks. Since loading out condensate using tank trucks is not the typical operation, the operator has estimated the annual condensate throughput loaded out using tank trucks based on 95 days of maximum condensate production. 5. The operator was provided with a draft permit and APEN redline to review prior to public comment. The op reviewed both documents and expressed that they did not have any comments. erator AIRS (County/Plant) 123/9E7B Permit No. 16WE1049 Date 11/8/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor Emisison Factor Source Controlled Actual Emissions (tpy)` Controlled Requested Emissions (tpy)' PTE (tpy)* Ctrl. Eff% NCRP = reportable ? 008 40600132 VOC 3.552 Ib/1000gallons AP -42 4.8 5.8 5.8 0% Yes 008 40600132 Benzene 7.495E-03 Ib/1000gallons Mass Balance 21 25 25 0% No 008 40600132 Toluene 6.784E-03 Ib/1000gallons Mass Balance 19 22 22 0%• No 008 40600132 Ethylbenzene 2.948E-04 lb/1000gallons Mass Balance 1 1 1 0% No 008 40600132 Xylene 1.957E-03 lb/1000gallons Mass Balance 6 7 7 0% No 008 40600132 n -Hexane 8.418E-02 Ib/1000gallons Mass Balance 227 272 272 0% Yes 008 40600132 2,2,4-TMP 5.186E-04 lb/1000gallons Mass Balance 2 2 2 0% No *HAP emissions are in units of Ibs/year. Permit number: Date issued: Issued to: DO on - trol Division Department of Public Health & Environment CONSTRUCTION PERMIT 1 6W 1049 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Synergy Resources Corporation Wind Pad 123/9E7B SESW SEC 17 T4N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Hydrocarbon Liquid Loading 004 Truck loadout of condensate. None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III .G.2.) COLORADO .Air Pollution Control Division Pubt, feattrrxv?'�-*rig Page 1 of 7 3. 1 al_"ex if e owner°•r operator of the source for which this permit was issued: PP 1 do- ` •t en - • " ructi•" odification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section I I I. F.4. ) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Hydrocarbon Liquid Loading 004 --- --- 5.8 --- 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 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Hydrocarbon Liquid Loading 004 Condensate Loading 76,928 barrels The owner or operator shall monitor monthly process rates based on the calendar month. COLORADO Air Pollution Control Division 'vk,:nr'sr�e•.si.,�1 uk�i;�: }Untth'r> ENixonrrInt Page 2 of 7 l throu ' put limits shall be determined on a rolling twelve (12) ont ' •"al. he _ :":' "each `"'th a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 9. 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. (Reference: Regulation Number 1, Section II.A.1. a 4.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): • Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. • All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. • The owner or operator shall inspect loading equipment and operations onsite at the time of inspections to monitor compliance with this condition. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 13. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING £t MAINTENANCE REQUIREMENTS 14. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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. COLORADO Air Pollution Control Division 'h."H:uirnrct ;;t :�ukL::� klcrx€'r': isr^rcrzvrrat Page 3 of 7 ADDI 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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. 18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). 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 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. COLORADO Air Pollution Control Division Di≥pirmer,i.sf Public Health Sll,mronrr,nt Page 4 of 7 21. ance u• the accuracy and completeness of information supplied y th- n- "`op d is • ditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation Permit for condensate loadout at a new well production facility located in the ozone non - attainment area. 'COLORADO Air Pollution Control Division Page 5 of 7 No ththis it 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 004 Benzene 71432 25 25 Toluene 108883 22 22 Ethylbenzene 100414 1 1 Xylenes 1330207 7 7 n -Hexane 110543 272 272 2,2,4- Trimethylpentane 540841 2 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled 250 emission rates above pc per year ( b/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/bbl Source VOC 1.5x10-1 AP -42 110543 n -Hexane 3.53x10' Mass Balance The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.2 psia M (vapor molecular weight) = 46.69 lb/lb-mol 'COLORADO Air Pollution Control Division Page 6 of 7 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors (EF) were calculated by multiplying the ratio of the mass emission rate of each NCRP in the condensate tank vapors to the total mass emission rate of VOC in the condensate tank vapors by the VOC emission factor. The calculation is as follows: NCRP Mass Rate, tons lb l _ (0.15 lb) year EFNCRP, (bbl/ — . bbl ) * VOC Mass Rate, tons year 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, and Total HAPs NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division 01 RJttc}kzft Page 7 of 7 Colorado Air Permitting Project Version No. 1.00 Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Harrison Slaughter 345697 9/20/2016 11/4/2016 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: Exploration &;Produ What industry segment? Oil & Natural Gas Produ 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 Synergy Resources C©rpor'ation. 123.. 9E7B Wind Pad SESW of Section 17, Township 4N, Range 67W ell Pad & Processing Yes ❑ Particulate Matter (PM) O Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 005 Condensate Storage Tank Yes 16WE1050 1 Yes , . Permit Initial ,,; Iss once Section 03 - Description of Project Synergy Resources Corporation submitted an application requesting permit coverage for ten (10) 400 bbl condensate storage vessels at a new oil and gas exploration and production well pad located in the ozone non -attainment area. A permit will be issued for the condensate storage vessels because uncontrolled VOC emissions are greater than 1 tpy and facility wide VOC emissions are greater than 2 tpy. This facility will also include two natural gas fired reciprocating internal combustion engines, hydrocarbon loadout and produced water storage vessels. The operator is requesting traditional permit coverage for the engines and loadout source. The operator is also requesting GP08 coverage for the produced water storage vessels. This facility is classified as a synthetic minor stationary source. Public comment will be required because the source is requesting synthetic minor limits to avoid other requirements and the change in permitted emissions is greater than 25 tpy. Section 04 - Public Comment Requirments Is Public Comment Required? Vi If yes, why?' Requesting Synthetic Minor Pere Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?' No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain whatprorams and which pollutants here: Title V Operating Permits(OP) VOC, n -Hexane, Total HAPs Non -Attainment New Source Review (NANSR):VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Stationary source is classified as synthetic minor as described above. Condensate Storage Tank(s) Emissions Inventory Section 01- Ad minstrative Information Facility AIRS ID: 123 9879 005 County Plant Point Section 02- Eauioment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processine Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2630'. Btu/scf Volume of waste gas emitted per BBL of liquids produced = 94.89', scf/bbl Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = 246,302 295,563.. Barrels (bbl) per year Barrels (bbl) per year 295,563 Barrels (bbl) per year Ten (10).400barrel fixed roof condensate storage vessels connected via liquid mani Six (6) Enclosed Combustors (Two.- Project Consultant High Capacity; Four- t9masron 48" High Capacity) Actual Condensate Throughput While Emissions Controls Operating = ?246,307!. Barrels (bbl) per year 61,467 MMBTU per year 73,761 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 73,761 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? The site -specific emission factors were developed using a ProMax simulation with inputs from one site specific pressurized condensate samples. This sample was collected from the Synergy Resources Corporation Wind Pad on 08/08/2016. Below is a summary of the emission rates resulting from the simulation. Pollutant ProMax Emission Rate Uncontrolled Emission Factor VOC ` 272.422482 lb/hr 9.68900 lb/bbl Benzene 0:5739548 lb/hr 0.02041 lb/bbl Toluene .. 0:5215971. lb/hr 0.01855 lb/bbl Ethylbenzene .0.022599874 lb/hr 0.00080 lb/bbl Xylene 0.14997387 lb/hr 0.00533 lb/bbl n -Hexane _.._6.449206 lb/hr 0.22937 lb/bbl 224 TMP 0,03984432 lb/hr 0.00142 lb/bbl Pollutant PM2.5 Condensate Storage Tanks Uncontrolled E.F. (Ibs/bbl Condensate Throughput) Controlled E.F. (Ibs/bbl Condensate Throughput) Uncontrolled E.F. (Ibs/MMBtu waste heat combusted) NNN IIEMI 9.68900XXXXX, • \\\\__\ 0.31 2.041E-02 MIEMIZIM..N N.X 111113=IM _'% Control Device 0.0075 0.0075 0.068? Uncontrolled E.F. (Ibs/bbl Condensate Throughput) 0.0019 0.0019 0.0170 Section 05 - Emissions Inventory Emissions Factor Source Citation rf Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 NOx VOC CO 0.27 0.27 0.27 0.23 0.23 0.27 0.27 0.27 0.23 0.23 2.51 2.51 2.51 2.09 2.09 1431.86 1431.86 71.59 1193.21 59.6605 11.43 11.43 11.43 9.53 9.53 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 3.02E+00 3.02E+00 1.51E-01 2.51E+00 1.26E-01 6033.43 301.67 2.74E+00 2.74E+00 1.37E-01 2.28E+00 1.14E-01 5483.04 274.15 1.19E-01 1.19E-01 5.94E-03 9.90E-02 4.95E-03 237.57 11.88 7.88E-01 7.88E-01 3.94E-02 6.57E-01 3.28E-02 1576.53 78.83 3.39E+01 3.390E+01 1.69E+00 2.825E+01 1.41E+00 67794.19 3389.71 2.09E-01 2.09E-01 1.05E-02 1.75E-01 8.73E-03 418.84 20.94 2 of 6 K:\PA\2016\16W E1050.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 06 - Reeulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII, as provided bel Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, a Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2, as provide Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO N5PS 0000a Storage tank is subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 3 of 6 K:\PA\2016\16WE1050.CP1.alsm Condensate Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emisions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. N/A - Operator submitted site specific emission factors to calculate emi: Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08- Technical Analysis Notes 1;. When this application was originally submitted, the source was requesting:GP08 coverage for the source. Since the emission factors they were proposing were developed from a representative sample rather than a site specific sample, I expressed a site specific sample would treed to be provided if they wanted''. GPO& coverage or they would instead request individual permit coverage and the permit would require a site specific sample be pulled. The operator expressed they wished to have individual permit coverage andsubmittedthe necessary information. 2. At this site, the condensate isroutedfrom the inlet separators to gas busters Ivapor recovery towers) and then to the condensate tanks.. The sitespecific pressurized hydrocarbon liquid sample submitted with the updated application materialswasobtainedfromthe"East Gas Buster" at the Synergy Resource corporation well pad on 08/08/2016: Based on the faciityddagram and the process description included in the application, the gas buster is directly upstream of the condensate tanks. As a result, the. ProMax simulation used to calculate emissions accurately depicts the set up of equipment on location. - 3. The controlled requested VOC permit Unlit for this source is'.71.8thy (see calculation above). Taking this value and dividing it by the total number of storage vessels resultsin a value of 7.6£ tpy VOC per storage vessel: Since this is greater than 6 tpy VOC per storage vessel, the source was determined to.besubjectto NSPS-0000a'. Since NSPS 0000a has not been adopted intoRegulation6, it is addressed in the notes to permit holder sectionofthe permit The operator was informed of this and expressed'. they agreed with the determination. 4. The gas to ail ratioused inthe calculation of the combustion emissions was determined . using the results of the ProMax simulation. The calculation is -as -follows: (0.06£1351MMscf/day + 0.00289668 MMscf/day)•(365:day/year((1,000,000 scf(MMscf);(1 year/246302 bbl) 94,89 sd/bbi. 5. The heat value used In the calculation of the combustion emissions -is based on a' weighted average of the -gross'. ideal gas heating value calculated by ProMax for the flash gas stream and the working and breathing stream. The calculation is as follows: (((0-0611361MMscf/day)/(0.06403778MMscf/day))*2629:25 Btfr/scfl+if(0:00289668MMscf/dav)/(0.06403178NIMscf/day)1"2645.12" Btu/scf)=2630 Btu/scf' _ - - 6. Since the ProMax simulation used to calculate emissions from this source is based on a site specificsample obtained within a year of the application, initial testing requiring a sample be obtained from the site will not be required in this permit. 7. The operator was provided with a draft permit and APEN redlines to review prior to -public comment. The operator reviewed bothdocuments and expressed they did not have any comments. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process ft 01 SCC Code Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.04 0 lb/1,000 gallons condensate throughput PM2.5 0.04 0 lb/1,000 gallons condensate throughput NOx 0.40 0 lb/1,000 gallons condensate throughput VOC 230.7 95 lb/1,000 gallons condensate throughput CO 1.84 0 lb/1,000 gallons condensate throughput Benzene 0.49 95 lb/1,000 gallons condensate throughput Toluene 0.44 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.02 95 lb/1,000 gallons condensate throughput Xylene 0.13 95 lb/1,000 gallons condensate throughput n -Hexane 5.46 95 lb/1,000 gallons condensate throughput 224 TMP 0.03 95 lb/1,000 gallons condensate throughput 4 of 6 K:\PA\2016\16W E1050.CP1.xlsm Condensate Tank Regulatory Analyses Worksheet Woody, aseueeon 3 Parts ♦and B - MEN and Parma aeouimmnes ATTAINMENT 1. Are unconrolled actual emearons from any cote. pollutants from the rvdA dual source greeter men 2TM' Ipeguueon 3. Pert A. Section ifD.lalx Is Me construction m (service detel prbr m 13130/200E a. not modified after 11/31/2001 (See eSMN. 05-01 Deenmom 113 and,,a and .eon 2 roramrtlonel...nee on grananMcapgrcad'13y1x 3. Are toter.mty unconealledwc amnions greater man 6rn.Noevaster man1orpr or C0 emissions greeter Man 10T, Ieewutlpn 3. Part e.sectlon n.D.31x 1. Are tea emissions my ,Regulation 3. Parts, Section 111.1x Is Me construction tote (service date( prorrto 1x/30/2002 and not modeled a2ri2/31/200xlsee',Memo 05-01 Dennemm 1.125.1.14 and senwn 2 for additional guidance on grandfather app¢a3Bty, 3. Are total fmalty uneontml.VOC emssons from me greater man x re, NDs greater man s Tee or co emisawnmgreater man s Tn weed on 3. Part B. Section n.0.21? Ise t mmm+ euuMdon ?.3.aloo 31C 1. is Ns ON fte rank located in the garr ozone control area or anv crone non -attainment area or 32. Is Mis . lame, MN( located at arra and gas expbratIon a. production operation',natural gas toma �� tato o naturalga drip station? (Storage tank wiea, to Regulation Senrve provided baiow Section MIL. -General Requirement for Air Pollution Control Equipment -ere enuon &«adage Section Xl{.0 -Emissions Coned fiernerilen. Seater elms-eerorde.repeva ge tin, ...ado Regulation 7 SectIon 'eta 1. Is Mis storage .1( loca. In Ahr ozone control area or any zone non -attainment area or altanmenvm nten.nrearea? 2. Is this storage tank bca. at a al. processing plant) 3. Dom thee ,e bnicexhilait r,u its.,storing non.stalAlied liquid$eminionsandhaveunconedledaem..mn. greater than oequal to tons ear year VOC7 Section Med.] -General Requirement for Air Pollutbn Control Equelment -Prevention of Leakage Cokeado wMMNI s.tlon gvn at . transmission/storage facility? 2. Is ths condensate storage tan0 located at an oil and gas exploration and product,. operation, vreil production rerun', fateful sae Compressor station or raatuni ga3 nrOCeSS fig Plant. . enaunCOM70..actualemeSiOns'Oftee.ra tar. ual WO, rears`, Own a tons Per oar Or., Yes Yea 1sdume sou sawrmN. co m the next question Go to neat question Source Retitle. a permit 1Go to the next queston Go to Ma next question Source Is sublect .: edn rtor'a; ngnnptap13,.tmgegp33.,?5.tipngl.D Section Wile -General Provisions for Air Pollution Control Equipment and Prevendon of Enessions Section lrell.C1-Enessions Control and o...ng Requirements to room Doc ondensate storage rank contain only ed' agues, (Storage tan,. Is subiect toRegura Sadden Capture a. Monftoring for Storage ranks fitted with Air Pollution Control Equipment CF0. Parr 60 Suborn gla Random. of Performance w Wrote@ Omni; trourci Storms n Im'I r4?w nea uas HMI? z Doc in lsse/dllal1 mete a. Does reeve.. has a design capacit, less Man or epual m1,583.330 00'['10 Ball used for peroleum.or condensate mccsednte stored. p. or vecea prior m va custody ngkT m as defined 60.111, 3. Was Ileson ens.te storage n consruc . reconseruc.. or modified lsee...Mons ao Cr, 60.3) alter yE3.19e4 a. an the tankth de5. Ooes Ile storage vessel finition a -volatile orgarde ogo ono -storage vessel' vin6"21 as defined 1,160.1113? meet anv one of. follow, addl.,. exemptions: 3. Doesa. is rne the storage vessel storage vessel a pressure vessel (kelp. to operate in excess Pal -29.? psi]psi]m and without emissions me annospeere 160.101ldl0Ellx: or O. The desip capacity. r Man or rn'r9soterlaed smD,ca pum.tma 000550T bu.vap0r Pressure'lc1P s man 3.S .1sP.vlDgell?: or capacity is greater manor equal to 75 xA' (-en Mr] 13uliessman 1st m' I'9so Breland stores a ',quid oaths maximum euevawr pressure` its man 15.0 SPal6o.11031c11? lotIttOro, TAIIM nOt.uo,ea to NSPSe, g60.3ss3-eewrtinganf e.oinggequitements 463.1100 -Monitoring Operations p.eons 40CFR eon 60 u3m39339o5.marde of Oedema= for.. OR and !Mural an Production. Trennnk.iso aMOklM. Are potential VOL emissions.' from Me i.iviclual storage vessel greater Man or equal toe tens eon., rforaeoranx,a not sub,. to NSP5 moo .1.3395,111ssmna mneor standards mr vOC 463.3413 , Testing anti Procedures t6o.541g1-Cover equiemenu Go to next quest. Go to ele next question Go to the next puestIon sorts Is subjeCtea parts Of .00105n?sxe005xv .01/.00 to me next q smn 1 mess suW.tma pravnions or . on? secdons0 BC so xge ra. is notwgct NV, SC• The storage vessel capacity is sea. tee 5055153u mmeCm. [Nam Xastomper* lap.vl�I.ate,...Wm, eualatofa.3�odue b.n�lom.eetonap...«rPG<.nM..�i�w.,a.I.m.nationdata,P :w m...teatoNsasC000p~.�3.slallxl.a.n ifpota .VoCmaamWow ow6tompany.er, 40 PPP Part GO slilatort 0000a Standards of laxtrarmama Pm. an and Natural aas Padilla* whim angruaan MMXxatwr a naoaatmmanammaatedAfter seateme.la x013 1. ,s PM tandems... vessel consimucted. reconstruCted. oran eb heeammaons40CM 602)after September 113, 20151 Oom Mb condensate storape vessel meet Me clannlbon of 'storage sets,' per 60.5430a P . 's condenser. stomp vessel brat.ones fa catty m the crude .an natural gas pmbucen segment natural gar poraabysegment ar natural gm aemmi.san and storage segment alMe lMusma a. bre potentlal VOC ernissbne from Me Incirridual storage vessel greater Man or equal to tons per year, 5. Is the star vessel su eat Oa and cantrolled In accordance wart r oiroonanis for stor vessels in 40 CFR Part PO Sub n Kb or 00 UP Part 63 Subpart PPP 40 CP12 Pan Ullman MAT 00 Oil and Gam Pleawelan W+6& I. Is Me tank located ate facility Mat is malo l gas production rattler Mat rm.. either of Me x. bane stora A/xllky ma located an MI auM rades or stores remocaran01000'Ia3.T6ga110)? OR Iroe rw criteria: facility that pormsas,ugrabe or stores natural gas plorta the point at MOO natural gas enan the natural gas manemisaan and storage source mdgcy a IaemvereH ma nnal ee unr' 163.7.Ia11311T 4. [roes Ma rant meet Me delinItIon vmser 3. Ones Me sr. meet Ma defInMon of "stare. vane,' in 63.761,potential far flasb errals.s.' per 3. Is the tank tubixt m control requirements under 40CFR am., Subryrcxe o 3.]61. r Subpart 0000? ISto Subpart" G.,agal provisions per i43.76a (al Table .g3.me- EmissbnsConirol StandardsStandardsµ..7s3-Momtarina µ..7M-Rcomkeepna µ..7s3-Reyorbna PACT Realer, PAR malty a repair* H nary . Pa. not eppy AM X the tank is Mtn., non-attainmentam. II Ow tank man bothahMa ten rootage MR rquinmame Olschinur Ms document asasb opera.. wM Ostemunl70 applicability olcabin re0Wamenlsaf the Goan Air Act, rts imp/emend,' regulator's, and AirOually Control Cpmmssbn regulations. This.xunenl u anaryvst conbms may nolappy to a p.c., seuaton bese0 upon the inOlvtlwl ...xi crcumslarwn. This subs.*kcanybw, dt&00411y binding re0wremenl and is 001 bcol y arbrceede. In the event &any conflict beMear the language dMb [locum. and the language dale Clean Ar Ac(, 04 Al? 0.1WCanlrolCommasion reyub000 M language of the sla4eorrgwblunwI0 corvrO. MeusedMrvmandato language suchas 'rocommeM,"'may." 'should.. and 0.3n., Inreachml to Omni. AMC, interpretations andrecoS77070307s. McMemry lamrvwbpy such as '.must and 1430071.041. Mad 10.6070e 007110bing reauremems under the bans d104 Clean AwAcct and Airduality 0arl.CO MISsbn regulelons, buttub document doesmgt eslabksh legally budim0 reeuvemenls In and ofRas1 a to Me next question Go to Me neat question Go to Ole neat question Go to Ma next question source Is. sugen to xsna000a tot. bank lent subject MALT xX • There are no NWT xx rpuiremenia far tanks at area sources Permit number: Date issued: Issued to: DC..? on trol Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE 1050 Issuance: 1 Synergy Resources Corporation Facility Name: Wind Pad Plant AIRS ID: 123/9E7B Physical Location: SESW SEC 17 T4N R67W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TNK 1 - TNK 10 005 Ten (10) 400 barrel fixed roof condensate storage vessels connected via liquid manifold. Six (6) Enclosed Combustors This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division Page 1 of 9 3. ownez. •r operator of the source for which this permit was issued: 1 do •t •` ` "en • ructi odification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO VOC CO TNK 1 - TNK 10 005 --- 2.6 71.6 11.5 Point Note: See "Notes to Permit Holder" for information on emission factors an limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TNK 1 - TNK 10 005 Six (6) Enclosed Flares (Two - Project Consultant High Capacity; Four - Cimarron 48" High Capacity) VOC and HAP COLORADO Air Pollution Control Division Putt,: Health & EnviTanr,,t Page 2 of 9 PRO S1 I IS �e= D ; CO S 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TNK 1 - TNK 10 005 Condensate throughput 295,563 barrels The owner or operator shall monitor monthly process rates based on the calendar month. The condensate throughput shall be monitored by one of the following options: inlet meters, tank level measurements which take into account all additions and loadout activity, or sales or haul tickets. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the 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. COLORADO Air Pollution Control Division ▪ r ecru<JPublic; }teat 4crvn[ Page 3 of 9 13. y this -rmit is subject to the emission control requirements in egulr - .n X " .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 a 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 the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; 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. COLORADO Air Pollution Control Division ,.,e r ru Pjbti bie_i t:, , L,^<conr,rtt Page 4 of 9 in the owner or operator of any facility, process, or active y; 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. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. COLORADO Air Pollution Control Division Page 5 of 9 26. -tip o he erm.•f•ermit •e of the provisions of the Colorado Air Pollution Prevention nd ." >"' old ation : '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: Harrison Slaughter Permit Engineer Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation Permit for condensate storage vessels at a new synthetic minor oil and gas exploration and production facility. COLORADO Aix Pollution Control Division ukG�k#=a€t+`> ^.i•�^u*:gin: Page 6 of 9 No th this it 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 005 Benzene 71432 6,034 302 Toluene 108883 5,483 275 Ethylbenzene 100414 238 12 Xylenes 1330207 1,577 79 n -Hexane 110543 67,795 3,390 2,2,4- Trimethylpentane 540841 419 21 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/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 NOx 1.70x10-` 1.70x10-2 AP -42 CO 7.74x10"` 7.74x10-2 AP -42 VOC 9.69 4.84x10-1 ProMax 71432 Benzene 2.04x10-` 1.02x10"3 ProMax 108883 Toluene 1.85x10-` 9.27x10-4 ProMax 100414 Ethylbenzene 8.03x10"4 4.01x10-5 ProMax 1330207 Xylene 5.33x10-3 2.66x10"4 ProMax 110543 n -Hexane 2.29x10"' 1.14x10-` ProMax COLORADO Air Pollution Control Division D ar ,.. Publvz le,th Page 7 of 9 controlled Controlled S # . lut •' _ i "ion Factors lb/bbl Emission Factors lb/bbl Source 540841 2,2,4- Trimethylpentane 1.41x10-3 7.08x10-5 ProMax Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. The NOx and CO emissions factors (EF) in the table above are based on the AP -42 Chapter 13.5 emissions factors of 0.068 lb/MMBtu and 0.31 lb/MMBtu respectively. The emissions factors from AP -42 were converted to units of lbs/bbl using a waste gas heating value of 2630 Btu/scf and a gas -to -oil ratio (GOR) of 94.89 scf/bbl. An example of this calculation is as follows: EFNOx (bbllb / �MMBtu) 0.068 lb * /2630 MMscf tu\ * 1MMscf 1 1,000,000 scf) * (94.89 b61 cf 1 _ 0.017 lb bbl 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a —Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: https://www.gpo.gov/fdsys/pkg/FR-2016-06-03/pdf/2016-11971.pdf 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, and Total HAPs NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 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 I COLORADO Air Pollution Control Division Page 8 of 9 FF 3 i• darHazardous 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 hit Pollution Control Division e, nTrwr ! Publ _ tie .-•.r. rr*rrac Page 9 of 9 C Internal Combustion En Emission Source AIRS ID: /23 referenced within your organization.] [Provide Facility Equipment ID to identify how this equipment Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01— Administrative Information H . G C a)U` a 12 a O E y z o ❑ N d a u C U O SI L. O 7 z E a) O C c. d .en E E g r ',:5 w E aJ O P P., G p0 L. =O zin a) W ❑❑ C — C L Z C y 4/ E C d 1. u u C. 0 U 3 cu L w O D..0 O L L Y Y Y C' C' S 6) Cle CU a a a ❑ ❑ Source Name: County: Weld Change company name Change fuel or equipment Elevation: 4833 Transfer of ownership Change permit limit Portable Source Request PORTABLE source permit Home Base: Request APEN Update ZIP Code: 80202 Emissions data must be completed. Blank APENs will not be accepted. Denver, CO (720) 616-4300 Phone Number: Q c NU a ❑ Notification of AOS permanent replacement Section 03 — General Information LU O N 03 For new or reconstructed sources, the projected startup date is: 12 A U N LU a) 3 N C C eet W N o CC N c O •0 o C O a) CC a O R a) O Uvi UN C O o O En o ° z General description of equipment purpose: C E C O Ts a Co _ R ••- d C) A O L c P, o oU u ,o E o L C R 0. d L Q ^O R L O U O a) 4—•73 E R o C. O 0o v WU M M Cr1 Y C bp N Q y N N N ,C v, d L C O Cr, -p U O. a.) 4. ,O �p 4O -' c E O C o 0 o C R C tikin C O ¢ L1 C o -o W _ y E o°'u i.. o ,�� Z > 0 CI 0 w° W -c R L 0.� U y U V y et y v p Ti a) .01 c3 v 3 °c' = ux E o C T C, R - ae.. L.. — O p o v e t y. 7 IA CL, C O O > °' C..... aJ 0.4 C •N U o 5. Npp tC r.° i •L M O C .. Oc. y C C y C) A•— — N C 'o T C ca CC) I 1 d o.• y a) . p0 C 7 .C C y .> W C E Z 'a U O C O R .� o -c, 4O!� O U C U vi En L. U O ,G C C) C FL = C �. ck d c) c •7 a c ,O O N t W F#1 ';� Z L 'C 4. (C C iC y w O �L'_ © U d C O_ z, 0 =•a R :5'U= e 6, p aW •'Ti Ems-, aX)• upsY,,Q A w — v) ¢ Q 14. 7 0 b CC 0 O U O CD C) E CC y U CD O C .n o O � C C a) a) x O CU A ca C O O O z ainment area? c O C o' •0 CC C a) CC 'G W C y CL -6 O C C CO o -C ate) S > O C) E w d C O C O u C) U Engine displacement: te O Engine date of manufacture: LU N N v CD (9 O z .CC C) z O co) M 0 .b O (LEI a, Co U Manufacturer: 1 ❑ ❑ C. 3 a O C. to c ❑ C C) C a o bo C� T O E C w` U O Engine function: U) Manufacturer's maximum rated horsepower @ sea level: Y . Manufacturer's maximum site rating: L. re E C U b C) 3.4 R U C H 0❑ MC w L c CCcu z ❑ E Combustion: C O CC U • • y a CC L. o o O a. a !1, a v o 4. 4. o O 0 0 V CD CD Cr CO' w O O U a❑ C O b CC a) N 0 R. O O o � U 00 u c C N cn C cc ❑ E U a) C. ai u C) n. O • S U m CC CC O What is the maximum number of hours this engine is used for emergency back—up power? Form APCD-201-RICEAPEN-Ver.02.10.2014.docx N O O tOczt CD kt) M FORM APCD-201 r a a Internal Combustion En AIR POLLUT M4 c O t41 cr, 40— g al tsu U "c3 oA r v 0 1n -104.918507 w 0 Z O 1 O et 0 O co C7 z w W U_ EZ 6 O x0 -lion Information Section 06 — Fuel Consum Fr, A n U, N e, A tO O U ctO co' 1302 Btu/SCF Requested Permit Limit 7.29 MMSCF/yr 0 8 832.02 SCF/hr co z s 13 Cu 0 E� R _ W N W Q 8 O E e a 4iz .5 3 a 'g O w;3 v • W I 'a n o C5o C O a, 6 C V d q O. O. N a 0 C Manufacturer sU 1O0 2 et sr a N 0. O. N N Oi 9 W W 1v 1u O ti O n 0 r d CC N LIJ 1n m O w O M 4 w eJ N r w 'f w—} P+, w n 0 0 M 14 ro W an O w vii• csi 9 w 1, C4 7.7 1h cn O Q O Emission Factor Documentation atta Emission Factor m 2 [0 .0 m ID E w q 3 2 4 K) 0 d I¢ z W CO N l0 r m 2 00 2 2 .n LLI cO• C) O W co z Z z z z z Control Device Description 2 3 2 P. a 2 r0 V a cel a U z z 2 O GO 8 C e Q C)09 d h CC • Ca F Form APCD-201-RICEAPEN-Ver.02.10.2014.docx N 0 N a Internal Combustion En 7-1 U E C q V R fY c o i U to a N CC o U = Tito E CC a. a C Q h ZL � W o c >, F.4 L ] � U H u E• CC 0 R. WCA � CA U H a, w W141 E"4 Z FU Z •H o W 7 •v Q a CC Q ° Cla s, a) a .fl a C ZW E. C O CC ?" p. w Q str- Emission Source AIRS ID: /2-3 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] uested Action (check applicable request boxes) Section 02 — Re Section 01— Administrative Information W permit or newly reported emission source c.0. d NC ❑�❑❑ N w Change company name Change fuel or equipment O M >N CO C7 N > • o "Cr�� c ° U 0 C U z vD Source Name: Transfer of ownership Change permit limit Request APEN Update ZIP Code: 80202 Emissions data must be completed. Blank APENs will not be accepted. Denver, CO (720) 616-4300 Phone Number: C 00 d u d CC aa C R E a cA O C O R u z_C 4 "O aO u ❑ -to Section 03 — General Information u� 0 N OD For new or reconstructed sources, the projected startup date is: 12 For existing sources, operation began on N LC) cO 3 a) C m aa O O C C) d d 0 N Normal hours of source operation: General description of equipment purpose: C E C O WU Q s. C a, > xA C C o o dC •o o L C d L C� 0 CC CC O O U o O E ca o p,_ z 000 v, Z • W �� W U M M M PQy C a) = \ N N N ,fl CC.) C) C C� ci� VD ,.D ,.O C — c. > C. E M M M LO. a� > a) a o en en en o00rZ wCD •s N L O z c amp ww� w o> rn . C y ._, a' m .-� y = d C c7 L`a 3 aci s d '�+" s 9 o 0 c,_ E u a. i C)C o OaRit. " i -11 E 6 a ° a °aoay°' .. L.,o,.. a)pC L M O Q LCd > .. �^ LC C C L A `n .-o rd > o dLiiFi+L —:,,a4 o o N x_- -0i• V bD t�. N I C ..‹,,l' n vi >� a EsI Uo o U O O w aa)i aJ -0p^ p; t.: O Q o• c cn C c U C p" C a' d V C t O O Z w LQ''� t L .b C W id a 2 ;4" WI. o w c d �° a P. a H axi v3 i! .c ' A wo Q rn ¢ Q Date the engine was ordered: Date the engine was relocated into Colorado: C O ❑ z CC C-, C a) C CY C 0 C z5 • C C C CC -o a)- -o O C a) .O C C Lea a) - a. C C)- 3:. U Engine displacement: Serial No.: WPW02668 Model: G3516TALE et C) CC Manufacturer: ❑ ❑ U C a a g a a,C ❑ C CC P. o� -to 0 cal CO G E E "C.' U 0 O Manufacturer's maximum rated horsepower @ sea level: Manufacturer's maximum site rating: Engine Brake Specific Fuel Consumption @ 100% Load: 0 E E C C CC z E❑ U a) • ti a O C C 0 0 P.s EPCP. P. ed es -o -o 0 O a a U CU 0 En En c^ 0 00 -o Y Y U U U U CC CC O c• - a) 0 a a U C) CO E L b a) C C CC a) C CO C En C- C O LC 0 C) E C C E E E CC 3 rt N O N a FORM APCD-201 Internal Combustion En .9 Permit Number: evant information in t F W Q P42 z (+) b O 2 C) U) O IO u 0 cn on ,iI] 8" 10 Section 06 — Fuel Consumption Information Seasonal Fuel Use (% of Annual Use) N N A N 1302 Btu/SCF Requested Permit Limit 75.45 MMSCF/yr 75.45 MMSCF/yr e 4U w 8617.37 SCFfhr U O Natural Gas 4" r i J teumation ivlernou or Emission Factor Source AP -42 AO 1,1 AP -42 AO A') V :° U 5 a 1 OE Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to reportpotlutnnts not listen anove. _...._a .._ _aa:.:......i A oriv TA. IF ApRN is niind nit inrnrrretiv nr misting information and requires re -submittal. J Perimtteil sKins Controlled Tons/Year 0.49 • S; OD (�) N D N rn ^ [�O• eft ( s7 N 013 i .,122 R 1.0. N It O 4 -LID N x ^ 'a> 0cn c Fo `'' rn V O ".'.; O . o a0 N of a; O O N el, N; (') y'a 1 r (n 0 O • N a O m N GI r...iiuinn Factor Documentation attached Data year for actual calendar yr. emissions below & fuel use above (e.g. 2007): 12016 I Actual Calendar Year Emissions2 O U ti O O io Z.. 7 d •41'jQQ7 4 O,319 ("4 tV M 00 CV N' ti: 46 V O N O Uncontrolled Tons/Year 0.49 • Cr Q , 0- O (0 N 0) N 0, W- 1/ ' 24.43 • N 1+) a O N O Emission Factor 2 i a _ .o lb/MMBtu lb/MMBtu g/hp-hr r rn c rn c t Ilb/MMBtu O co a Uncontrolled Basis 9.99E-03 :14 O U P A o w 2S! u7 lO[] IC x S co T N O 4O1 W co m O w O V/N YIN (uoilanpau %) iconaiowa lowuo° VIN V/N 3 s° a Q pri' 4 $ d a 3 a 3 Control Device Description Secondary N/A 3 Z zz 22 2 2 3 2 2 a a i a Z V/N V/N N/A Oxidation Catalyst U a z Oxidation Catalyst V/N N/A 4 15 o 7 w r a F° °z x C I T ' 1 v T d :o_ C 'd e a (d COI ▪ N 4,0 sy E O w ¢, O E 4 .y. •O o • U o a Director of EHS F-' 4d ..^. O 0 O g` a g ate= 9 g C O W/ e r ear, e > c U N Tet t-, O z I) eti Form APCD-201-RlCEAPEN-Ver.02.10.2014.doc W W F- 0 z 0 cn LLI F - z F- _1 J 0 0 a W J Ca F- 0 W LU cc V O z 0 rn C E O U C O a) U C (tl 5 a) a) a) a) a) AIRS ID Number: Permit Number: co Co 0 oo Company Name: ai 0 U 0 N a) 0 U SESW Sec. 17 T4N R67W Plant Location: .U) Person to Contact: jbrian@syrginfo.com E-mail Address: Uncontrolled Controlled Actual Actual Emissions Emissions (Ibs/year) (Ibs/year) 9 .9 Emission Factor Emission Factor (Include Units) Source '1 Control Equipment / Reduction (%) Z Chemical Name O 6 v Chemical Abstract Service (CAS) Number �I9 r M U) Director of EHS Title of Person Legally Authorized to Supply Data 4 Q a) a O >, O_ O 0 a) N 0 .C >, tB N J C 0 U7 a) a 4- a) Z Form Revision Date: April 14. 2014 1,4 uid Loadin drocarbon Li O O m N- W O) C (C) Permit Number: equipment is referenced within your organization.] [Provide Facility Equipment ID to identity ho Facility Equipment ID: nested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information General Permit GP07 Individual Permit Action Applies To: Change company name O O Transfer of ownership ❑ ❑ u h y V H V 04 0 ❑❑ O Ur.) Q U z Source Name: SESW Sec. 17 T4N R67W Source Location: Change process or equipment 0 U Mailing Address: 1625 Broadway, 3rd Floor Change permit limit co CO W O U > C 4) O Person To Contact: Jerry Brian z d C Oa CU F E p„ o C u O L E CO 64 c u ,e, L C '4. O C ' d z E eC W Y J w V R z e r O O 7 cs b y o C C CIO jbrian@syrginfo.com E-mail Address: LACT Unit in use for condensate sales, truck loadout on -site for contingency purposes only. Section 03 — General Information Normal Hours of Source Operation: Csi Date operation began or projected startup date: Contingency truck load out of condensate for a maximum of 95 days per year from the pad. General description of equipment and purpose: Don't know Don't know Don't know Don't know Don't know 0 0 222 < < <� 4) rn v C) v v a) >- >- >- >- >- ❑ ❑ E ❑ CU T N v 0 0 U O C: 0 N CO C) 2 N N C) CO CO CO c 0 -OCO a) R C• .^ O 0 C. C) CS "0-0 U O U U ' N C O v, v _ C 'O (4 G) W.) "0 0 0 C U C � c O a .-3. d ) 00 N an O bCIJ a) C7 a -0 C ca O O U .. CO 0 a — C N .D .: v U C) 0 0 r) O U L_ CO - O 0 755 cn 0 4) 0. 2 c r C 0. 0 , Z 0 U 7 0 C 2 v C) 0 CO CO CC. 0 a) U 0 cn A C-• C C a CO CO N v O U a 0 T ro CO O a, c:, _C O O v CO v 00 -C - C A-. N U U 4) c o � N J--• U1 3 0 tment of Public notion Contr 0 • CO• 0_ O) Z CLIJ 0 Q ^ N -o U Q u N h0 v C V) 52 v ^ o o - c L > i C.) • O > "0 O O C Q O CO C z a with a check L L ic 0. c.0 V V L O h O .0 © 'O C L c 0 .7't Gne4 O ,o 0 0 0 0 00 v, kr, =• r / N N N c c,C VD c VD M C7 rn 0 0 0 M '', M < (n CO r) II C.) 0 APEN forms: www.colorado. erm itstatus U O Permit status: wwvv.colorado. 3 Tank Trucks 0 42 iE Up V 6 "O C •Op o CC Ca o r o .S O. itt g O V ca C U u > u R u O h L u w c '7, o E u O V G ro co, C CO . Molecular Weight of Displaced Vapors: O VD N ui G > r 0 U an at C i c 0. F d qrk 0.4 C V > co..; C) e 00 C >- > N CO U CU G Nv 76 0 U c Nj �3 > b L V 0. Q -r � G Cla L. C Y C� U h I CJ (I= U c °) c � Q) z fs7 0. Loads per year: Load Line Volume;: CO CO O1 O, FORM APCD-208 1410 S N w 0) L O a 0 a 0 0 CC C CC s 0 0 a L O CC C/] N .0 V v asa .O p E u 3.1 V e Q v C h 0 C O U as W m _ 4 a- 13 ae o g o O o C� V V U U C7 O U g a co b 0 et 0 'a C 1 2 a6 -104.918507 7. 00 Z 8 4 a aF v t x o ` a. cd CD o II E .0 V 5 � > d � e � a • - .a r4 u c 0 F h � CO a 0 a q w Section 07 — Control Device Information Section 08 — Emissions Inventory_Information a 0 0 0 d x a cQ 'Cr 0 0 a U 0 Ca CC 'CC C O C? 0 0 x co 0 O 0 O al ti C) Q O .10 U m N N eo 0 CC G. ea O Ts m C O. h C w d L CC CC CC C NC .E CC L L Estimation Method or Emission Factor Source Zh -dV; `d/N i N/A See calcs See calcs Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Uncontrolled Controlled (Tons/Year) (Tons/Year) Q Co N/A o.o l T Z lP d 8'S V/N Z 1O'O V/N T_ ,J Actual Calendar Year Emissions5 Uncontrolled Controlled (Tons/Year) (Tons/Year) N/A 4.8 V/N 0- 8'h d/N N/A 0.01 c Emission Factor Uncontrolled Basis Units Q Z I,- N J Z m m vi J m m �, J Q M P7 tP 0 V Z . YIN 71,1 Control Efficiency (% Reduction) Identify in Section 07 Control Device Description o Do a Pollutant OD DOA xON v E Ggo rl- Manager of Environmental and Health 7 t C'- W O CC o O 0. q E O y aa Li y ti a a en Oo as a a. CC u .c u III I 5� a m , 6 'R G to o G � a a, 'oa o j) a a O o .Q C a R� O y y a CC 0 V 4 S- C= C F O y � e o ru 4 t e. . ey f y I- ►r d �a 0, v S o w - O ' V a i u O E - e a d m I c, +'« C £ o a O « x I C CJ •C u u y w a 4 D-208-HydmcarbonLiquidLoadingAPEN-Ver.4-14-2014 (l).docx Q O co z r w W C bl LI 6, LI i.l �yG W U FBI O a M N Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] TNK1-TNK10 Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01— Administrative Information Change company name cu Transfer of ownership W A E a ElZ�OL ❑ ❑ L e G W ¢ W o u E A d z 7 o A z ¢ ` w W Az u L L 0 ww � ' .. p a. O C 0 = = 7 acC❑ a ❑❑ N Cl.) v U U L) z� Source Name: Change process or equipment N 00 Q Change permit limit N 0 00 o ii C C O o 1° U U 0 a_ w N APEN Submittal for Permit Exempt/Grandfathered source APEN Submittal for update only (Please note blank APEN's will not be accepted) Person To Contact: Section 03 — General Information 0 N 00 N En M 0.1 a) O v0 N ® 91®® CO a) En rd 10 o CO aa.4"C rn 0.1 Eu o. •O a) U 'O En O ° 0 0 C 0 C C C 0 CO C. 0 CO m I.U. 0 N C E N CU O Normal Hours of Source Operation: cal in CO C O E w C� O CO Li. d 2 3 E a 0 CO C) En a) CO ZZDo ` a 3 OO S' om' UOo T. O C b o 9 4 .° AI •., CO N 2 w n C 7 o o CO COO '- G �cu YU aE) E C — o ❑ ®® a `„ ` CO c O 77 E .? 20 C — O O CO• e CO -,p CO CO u C) ( _ caL C 0 u C C O 01)O v o CO i E O 'O .a Al O O a O 0. cd O .23 C a o •CO 0 V P. U B Ors o c'-) d -C U o a d '0 a) O 5i 7. c„; Z.a'�a'> o w�=0C5,� °- C. ® •o 0 .4° `CEU o Al E c L -o y C 00 0_ C. EU =•^ g. CO F, .00 CC C 7 C.. 6) 0 0 > 0 CL) C C °) C y a 0 H E gy °>,° 0. C o C a YC. L CO C a) CCa d d -Op rn 0 C • • C O N Ha 34 C7 C ,= 0 .•.. a) O r .C . O T7 6.1 L N ..A L. CC 76A .2 E o h ea U t x. Z��ddd w •C O O. CO a) 0 y I. 7 •in Q V ¢• CO C 7 o.CC .?>_ C G_.. 0 CO O A En Ca N 'O d L w W 3" u C 00 C W {0UECF, et. G sE ar O 7 3 C C CO O c,,,O E.L. ^O in c G+ >. Q. . a C L , C CO a4 d U ¢ V.)2)4 Fr;W L0 0 O 00 N VI er M M M - ..... - o Cime 'M M M Q ofitI 0 0 0 ( _ k, en C O W H W_ 7 o, a a Y E C 71. C o _N OU 7 U Q 30 0En .0 C Q O o u U o C . ? G7 000 a° ° Q V)) 7 C) ://www.colorado.Q0v/cd APEN forms: htt C) 0 G ro En C O CO C. R Section 04 — Stora CO C 0 CO o. O 0 C O U 3 CO C) C) CO ¢, C N 7 'O 0 UF- RVP of Sales Oil O En CO C 0 CO a v 00 O External Floating Roof: Internal Floating Roof: Fixed Roof: C 00 0 Y C H C O u 7 i0 44 O rd 0 N N C CL) CO eO L- 4. d 00 CO CO L G o CO 0 CO c y)' 7 a' o > .r u CO 00 CC CO N N .01 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) Newly Reported Well El El El ra El Name of Well SRC Wind A -17N -C SRC Wind 21-17C SRC Wind M -17N -A SRC Wind 21 -17N -C SRC Wind A -17N -A API Number 05-123-40113 05 - 123 - 40112 05 - 123 - 40110 05-123-40115 eP 0 7 en N. 0 UPDATED APCD-205-Condensate-Tanks-APEN.doc CI FORM APCD-205 e4 E-0 el TTyw VI a a 4 .yw Q.1 ICI O a CD 0. 0 N. w C) M Permit Number: O O Section 05 — Stack Information G v.. GO v -104.918507 GAti O 0.' O Lr' 0 C N d U a a a ® Combustion Device used for c a O azi N O C n (6) Enclosed Combustors T Manufacturer Guaranteed: L U 9 aro m ❑ F - d O O O V cfl Make/Model: 0 0 > U 0 U U "Cl w m U V a C E▪ ) Annual time tha &P Sites On Information aration Technolo cv `t ProMax ggggg Q C. 1. 4 ; i 4 O O k Q FL k I r‘Wi•rw-O \JCJJ QtCQC41CC11 Requested Permitted Emissions Uncontrolled (Tons/Year) I Controlled (Tons/Yearl tJ f+ z p D 61 $IF -5..5 9� ea �e J t _Li N o i I i f • 4j d a I 'fl C a 0 Q 2. Q a a t o Actual Calendar Year Emtssion2 Controlled (Tons/Year) �9 i 9 ,, Benzene 2.041(10-4" lbs/bbl 1.93' 2...`j1 0:1O t.'. Toluene 1•$5X10"7— lbs/bbl 1•:641 :Ls 0798' O.11, Ethylbenzene S.03X I l) 4 lbs/bbl -0.07. al 8.39E-03 -Q.pps Xylenes 5.1'1A10.1 lbs/bbl 0745 O.\p\p 0-91, 0.03 n -Hexane 1.2`11( 10-1 lbs/bbl 21.48 28. LS 1.709 1.i-{\ 2,2,4-Trimethylpentane 1.'{1X10 3 lbs/bbl O:i3 OAS 6.30E 03 O. 1 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to rep Uncontrolled (Tons/Year) • �� IP d Emission Factor I Units t IUncontrolled Basis \0 i7 C cr 0 © Pollutant O z, VOC CO • u W R CO C0 E a '• a ea O a r ai a+ u a w d d p, b 0 ti O 8_ ga ' O 0 0 O o, a a, b -O o 88 22 o U O a a UPDATED APCD-2O5-Condensate-T FORM APCD-205 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Synergy Resources Corporation Source Name: Wind Pad Emissions Source AIRS ID2: 123 / 9E7B / 005 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 40116 SRC Wind 11-17C /1 05 - 123 - 40372 SRC Wind 11 -17N -C /1 05 - 123 - 40111 SRC Wind E -17N -C /1 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 AP_FormAPCD-212-EP-StorageTank-APEN-Add endum_Condensate. docx Hello