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Home My WebLink About20170207.tiffCOLORADO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 January 10, 2017 Dear Sir or Madam: RECEIVED JAN 1 3 2017 COMMISSIONERS On January 12, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Verdad Oil and Gas Corporation - Cervi 34-1N. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et. Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govfcdphe John W. Hickenlooper, Governor Ot/S31I7 Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc t PLC mm/TPA, NLCPe) PtJJC ER/CH / -sm/CK) pl/tCn/V7 2017-0207 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Verdad Oil and Gas Corporation - Cervi 34-1N - Weld County Notice Period Begins: January 12, 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: Verdad Oil and Gas Corporation Facility: Cervi 34-1N Oil and Gas Exploration and Production Facility NENE Sec 36 T3N R63W Weld County The proposed project or activity is as follows: The applicant proposes to operate a new exploration and production facility, consisting of condensate tanks, separator venting, produced water tanks, and condensate loadout. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 16WE0768 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: David Thompson Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORXDO _.w PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? -; If yes, for what pollutant? 0 Carbon Monoxide (CO) 0 Pardoiate Matter (PM) David Thompson 350442 23 June 2016 20 July 2016 Verdad Oil and Gas Corporation 123 9E96 cervi 34-1N NENE Sec27 T3N R63W :P-xpForafion & pfOduetors Well Pad Olt.&Natural GaaProdut,tlon & Processing .. Section 02 - Emissions Units In Permit Application 0 Ozone Ivan & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit N Issuance N Self Cert Required? Action Engineering Remarks 001 Separator Venting Yes' ` :' 16WE0329 . 1 Yes Permit initial Issuance 002 Fugitive Component Leaks, `; : .. Cancellation cancelled 003 Condensate:5toiagelank ` Yes 16WE0329 1 Yes' Pr:MrEhiiiBl ` ` Issuam Operator changed through -put 004 Ci drticarbonLiquidLoading _ No 16WE0329 1 No Permit Initial Issuance Operator changed through -put 005 Produced Water Storage Tank Yes':.. Section 03 - Description of Project Operator has a Wellhead site with. pt'essioft???? n r er. Submitted calculations showing prodt€ced.wateruteedsAPEN, none submitted,.i rec Operator has no knowledge of Colorado Rules/Regulations/Calculations: Walked through most Section 04 - Public Comment Requirments Is Public Comment Required? yes If yes, why?1 Requesting Synthetic Minor Per out. RICE for Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?' If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs anti. pollutants here: No TitleVIecretngPermitsf0P):;VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): 502, NOx, CO, VOC, PM2.S, PM10 Title V Operating Permits (OP) : 502, NOx, CO, VOC, PM2.5, PM10, TSP, HAPs Non -Attainment New Source Review (NANSR): NOx, VOC No Division Information Engineer: David Thompson Control Engineer: Chris Laplante Review Date: 07/20/2016 Application Date: 06/23/2016 Facility Identifiers Permit No. 16WE0329 AIRs County# 123 (Weld Facility # 9E96 Facility Type: exploration and production facility ❑� Located in the 8 -hour non -attainment area? Administrative Information O True Minor Synthetic Minor for: l VOC r NOx r co Company Name: Verdad Oil and Gas Corporation Source Name: cervi 34-1N Source Location: SIC: NENE Sec27 T3N R63W 1311 Mailing Address Address 1: Address 2: ity, State Zip: Verdad Oil and Gas Corporation 5950 Cedar Springs Road, Suite 200 Dallas, Texas 75235 Person To Contact Name: Phone: Fax: Email: Arthur Beecherl 214 728 1840 Abeecherl@VerdadOil.com Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the cervi 34-1N, located in the NENE Sec27 T3N R63W, Weld County, Colorado. Point Name Type Control Action 001 Flare Separator Venting None Newly reported source 003 Condensate Storage Tanks Condensate Tanks Flare Newly reported source 004 Loadout Loadout None Newly reported source 005 Produced water Water Tanks Flare Newly reported source One low-pressure separator controlled by one enclosed flare during VRU downtime. Flare has a minimum 001 control efficiency of 95%. Equipment Description This source vents natural gas from: Emissions from this source are: a well head separator routed to a flare Natural gas venting from a well head separator. Emissions from this source are routed to a flare. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at 60F and 1 atm Throughput (Q) MW 36.5 MMscf/yr Ib/Ib-mol 4166.666667 scf/hr 40.05 0.1 MMscf/d mole % MW Ibx/Ibmol mass fraction lb/hr lb/yr tpy Helium 0.00 4.0026 0.000 0.000 0.00 0.00 0.00 CO2 1.28 44.01 0.562 0.014 6.17 54082.37 27.04 N2 0.26 28.013 0.073 0.002 0.80 7014.34 3.51 methane 17.93 16.041 2.876 0.072 31.62 276975.38 138.49 ethane 20.28 30.063 6.096 0.152 67.02 587098.66 293.55 propane 37.57 44.092 16.566 0.414 182.13 1595430.05 797.72 isobutane 4.23 58.118 2.458 0.061 27.02 236702.04 118.35 n -butane 12.13 58.118 7.047 0.176 77.48 678706.30 339.35 isopentane 2.21 72.114 1.596 0.040 17.54 153693.20 76.85 n -pentane 2.72 72.114 1.959 0.049 21.53 188626.63 94.31 cyclopentane 0.38 70.13 0.265 0.007 2.91 25529.91 12.76 n -Hexane 0.39 86.18 0.334 0.008 3.68 32202.67 16.10 cyclohexane 0.10 84.16 0.085 0.002 0.93 8186.17 4.09 Other hexanes 0.16 86.18 0.140 0.003 1.53 13445.44 6.72 heptanes 0.24 100.21 0.235 0.006 2.59 22679.45 11.34 methylcyclohexane 0.08 98.19 0.081 0.002 0.89 7754.16 3.88 224-TMP 0.01 114.23 0.010 0.000 0.11 990.09 0.50 Benzene 0.10 78.12 0.080 0.002 0.88 7749.13 3.87 Toluene 0.05 92.15 0.047 0.001 0.52 4526.05 2.26 Ethylbenzene 0.01 106.17 0.006 0.000 0.07 613.49 0.31 Xylenes 0.01 106.17 0.012 0.000 0.13 1124.73 0.56 C8+ Heavies 0.07 114 0.078 0.002 0.85 7465.65 3.73 VOC mass tact 0.774 Total VOC (Uncontrolled) I 1492.71 Notes Mole %, MW, and mass fractions from Critter Creek 2-03H gas analysis collected XX/XX/XX. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+ based on the average MW on the analysis for the gas. 16WE0768.CP1.xlsm One low-pressure separator controlled by one enclosed flare during VRU downtime. Flare has a minimum 001 control efficiency of 95%. Flaring Information Equipment Description Flare to combust low-pressure separator as during VRU downtime. Manufacturer Tornado Model 40' Flare Stack Serial Number 12345678 Gas Heating Value 1549 Btu/scf Throughput 56538.5 MMBtu/yr VRU Information Equipment Description Engine to recompress as to sales line. Make TBD Model TBD Requested Control 100.00% Annual Bypass Tim 50.00% Backup Flare Overall Control 95.00% Combustion emission factor source: AP -42: Chapter 13.5 0.07 jib NOX/MMBtu 0.37 IIbCO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 81792 lb/MMscf 4089.62 lb/MMscf 1492.7 tpy 74.6 tpy Gas Analysis Nox 0.07 lb/MMBTU 0.07 lb/MMBTU 1.9 tpy 1.9 tpy AP -42 CO 0.37 lb/MMBTU 0.37 lb/MMBTU 10.5 tpy 10.5 tpy AP -42 Benzene 212.31 Ib/MMscf 10.62 lb/MMscf 7749 lb/yr 387 lb/yr Gas Analysis n -Hexane 882.26 lb/MMscf 44.1132 lb/MMscf 32203 lb/yr 1610 lb/yr Gas Analysis Toluene 124.001 lb/MMscf 6.2001 lb/MMscf 4526 lb/yr 226 lb/yr Gas Analysis Xylenes 30.815 lb/MMscf 1.5407 lb/MMscf 1125 lb/yr 56 lb/yr Gas Analysis Ethylbenzene 16.808 Ib/MMscf 0.8404 lb/MMscf 613 lb/yr 31 lb/yr Gas Analysis 24.721 1.2361 Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? yes This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2 16W E0768.CP1.xlsm 003 Three 400 barrel condensate storage tanks Requsted Throughput 36500 bbl Control Flare Efficiency 95.00%1 Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 8.568 lb/bbl 156.4 tpy 7.8 tpy E&P TANK Benzene 0.02164384 lb/bbl 790 lb/yr 40 lb/yr E&P TANK n -Hexane 0.12180822 lb/bbl 4446 lb/yr 222 lb/yr E&P TANK 224 toulene xylene e benz 0.01013699 lb/bbl 370 lb/yr 19 lb/yr E&P TANK 0.0130411 lb/bbl 476 lb/yr 24 lb/yr E&P TANK 0.00334247 lb/bbl 122 lb/yr 6 lb/yr E&P TANK 0.00071233 lb/bbl 26 lb/yr 1 lb/yr E&P TANK Tank emissions have ECD emissions added on to these totals. 0.9 ton VOC, 25 n -hex controlled Regulatory Review 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. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) 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 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19,800 gallons (471 bbl) NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. Regulation 7- Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non -attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are > than 20 tpy of VOC.) 004 Hydrocarbon Loadout to Tanker Trucks Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 6.3456 psia Sales Oil AI M Molecular Weight of Vap 41.06 lb/lb-mole AP -42 T Liquid Temperature 520 deg. R Field Data L Annual requested Throughput Annual requested VOC emissions Control: None Efficiency: 0.00% NCRPs Component Mass Fraction 3.75 lb/1000 gal 0.16 lb/bbl Benzene 0.0018 n -hexane 0.0153 Source: 36500 bbl/yr 1533000 gal/yr 5742 lb/yr 2.9 tpy alysis If the operator provides HAP speciation from a stable "sales oil" analysis, enter the mass fraction from this data. Alternatively, if the operator modeled a pressurized oil to develop a site specific Pressurized oil or Stable Sales Oil Analysis Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1573 lb/bbl 2.9 tpy 2.9 tpy AP -42 Benzene 0.0004 lb/bbl 15 lb/yr 15 lb/yr PS 14-02 n -Hexane 0.0036 lb/bbl 131 lb/yr 131 lb/yr PS 14-02 Regulatory Review 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: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? 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 Yes No 005 One 400 barrel produced water storage tank verdad, Amen -5 Permit exempt Emissions Calculations Requsted Throughput 10950 bbl Control Flare Efficiency 95.00% mary Table 5 Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.262 lb/bbl 1.4 tpy 0.1 tpy CDPHE Benzene 0.007 lb/bbl 77 lb/yr 4 lb/yr CDPHE n -Hexane 0.022 lb/bbl 241 lb/yr 12 lb/yr CDPHE Regulatory Review 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. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) 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. STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 16WE0768 DATE ISSUED: ISSUED TO: Verdad Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Cervi 34-1 N, located in the NENE, S27, T3N, R63W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Flare 001 Emissions from the 3 -phase separator. Emissions are controlled by an open flare Condensate Storage Tanks 003 Three 400 barrel condensate storage tanks controlled by an enclosed flare Loadout 004 Hydrocarbon loadout to tanker trucks with no control THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). AIRS ID: 123-9E96 Page 1 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division 3. -r " t xpi - own or operator of the source for which this permit was ed: d• - of • -nce • truction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. Point 001: Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. Until the flow meter is installed, the operator shall monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl). 5. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO. VOC CO Flare 001 2.8 74.7 15.2 Point Condensate Storage Tanks 003 0.9 7.8 4.0 Point Loadout 004 -- 8.6 -- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon AIRS ID: 123-9E96 Page 2 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division •,= -s this c• edition, insignificant activities shall be defined as any vity -q`•" -n , emi y amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than: • 100 tons per year of VOC 9. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Flare 001 Open Flare VOC Condensate Storage Tanks 003 Enclosed Flare VOC PROCESS LIMITATIONS AND RECORDS 10. 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Flare 001 Consumption of natural gas as a fuel 36.5 MMscf Condensate Storage Tanks 003 Condensate Throughput 36,500 bbl Loadout 004 Condensate Loaded 36,500 bbl 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. 11. Point 001: Upon installation of the flow meter, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. AIRS ID: 123-9E96 Page 3 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. Point 001: No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 15. Point 001: The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must 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 open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open 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. 16. Point 001: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompieted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 17. Point 003: This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 18. Point 003: The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: XVII.C.1.a. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. 19. Point 003: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: AIRS ID: 123-9E96 Page 4 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division , ...g .evic=` is used to control emissions of volatile organic p• • " • t•" '` wit . . "-ction XVII, it shall be enclosed, have no visible emissions during normal operatiohs, 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. XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto -igniter as follows: XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device. XVII.B.2.d.(ii) 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. 20. Point 003: The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must 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. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto -igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; AIRS ID: 123-9E96 Page 5 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division iv) ,isu -= inspe. 'on of the air pollution control equipment to ensure th- for - piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must comply with the requirements of Section XVII.C.2.a. by the date the storage tank commences operation. The storage tank must comply with Section XVII.C.2.b. and implement the approved instrument monitoring AIRS ID: 123-9E96 Page 6 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division ctions Within ninety (90) days of the date that the storage es o• ion. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. AIRS ID: 123-9E96 Page 7 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division asso :ted with the storage tank that is designated as afe, c • �,.in. - •le to • itor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 21. Point 004: 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) 22. Point 004: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 23. Point 004: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 24. Point 001 and 003: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) 25. Point 004:This source is not required to follow a Division -approved operating and maintenance plan. . COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 26. Point 001 and 003: The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 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 (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) Periodic Testing Requirements 27. Point 001: On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in AIRS ID: 123-9E96 Page 8 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division ent (w ht fraction) of this emission stream. Results of the ysi ' a • - u "-, . " alcu _ site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 28. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. AIRS ID: 123-9E96 Page 9 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division 29. to , pr• a equire ' ents (i.e. PSD, NANSR or Title V Operating Permit) a • • '" to so `-' any • time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 30. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 31. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 32. 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. 33. 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. 34. 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. 35. 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. AIRS ID: 123-9E96 Page 10 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division 36. .n �f ' a rm of perm! •r of the provisions of the Colorado Air Pollution yen . a :,3 . ntr:' .' the `-•" lations 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: David Thompson Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Verdad Oil and Gas Corporation AIRS ID: 123-9E96 Page 11 of 19 Notes Colorado Department of Public Health and Environment Air Pollution Control Division 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 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) Reportable? Controlled Emissions (Ib/yr) 001 Benzene 71432 7749 Yes 387 Toluene 108883 4526 Yes 226 Ethylbenzene 100414 613 Yes 31 Xylenes 1330207 1125 Yes 56 n -Hexane 110543 32203 Yes 1610 2'2'4 Trimethylpentane 540841 991 Yes 50 003 Benzene 71432 790 Yes 40 n -Hexane 110543 4446 Yes 222 Toulene 108883 476 Yes 24 224 TMP 540841 370 Yes 19 004 Benzene 71432 15 No NA n -Hexane 110543 118 No NA 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx .058 .058 AP -42 AIRS ID: 123-9E96 Page 12 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division `•' I Unc trolled Emis Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source •'. n CO 0.37 0.37 AP -42 VOC 81792 4089.62 Gas Analysis 71432 Benzene 212.31 10.62 Gas Analysis 108883 Toluene 124.01 6.20 Gas Analysis 100414 Ethylbenzene 16.81 0.84 Gas Analysis 1330207 Xylene 30.82 1.54 Gas Analysis 110543 n -Hexane 882.26 44.12 Gas Analysis 540841 2'2'4 Trimethylpentane 24.72 1.24 Gas Analysis Point 003: Pollutant Emission Factors Uncontrolled Source lb/bbl Condensate Throughput VOC 8.568 E&P TANK n -Hexane 0.122 E&P TANK Benzene 0.022 E&P TANK Toluene 0.013 E&P TANK Ethylbenzene 0.001 E&P TANK Xylenes 0.003 E&P TANK 224 TMP 0.011 E&P TANK Note: The controlled emissions for this point are based on the flare cons Point 004: Pollutant Emission Factors Uncontrolled lb/bbl loaded - Source VOC 0.1573 AP -42 Benzene 0.0004 PS 14-02 n -Hexane 0.0036 PS 14-02 rol efficiency of 95%. 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) = 6.35 psia M (vapor molecular weight) = 41.06 Ib/Ib-mol T (temperature of liquid loaded) = 520 °R 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: AIRS ID: 123-9E96 Page 13 of 19 Requirement Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123-9E96 Page 14 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division ATT HMENT 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. If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, II.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed and the permanent language should be removed; also change every instance of 90 in this paragraph to 270. 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 AIRS ID: 123-9E96 Page 15 of 19 require replac en Colorado Department of Public Health and Environment Air Pollution Control Division ing en ne. Measurement of emissions from the temporary fort ection 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http://www. colorado. gov/cs/Satellite/CD PH E-AP/CBO N/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation AIRS ID: 123-9E96 Page 16 of 19 the test applie Colorado Department of Public Health and Environment Air Pollution Control Division number of hours in the month or year (8760), whichever For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. 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 If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, II.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as 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 (§ 60.331) and 40 CFR Part 72 (§ 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: AIRS ID: 123-9E96 Page 17 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division is design rate greater than 500 hp shall use a non - educe emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements 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 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 500≤Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. AIRS ID: 123-9E96 Page 18 of 19 Colorado Department of Public Health and Environment Air Pollution Control Division 2.3.4 ngin CE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123-9E96 Page 19 of 19 Emission Source AIRS ID: CID E. 0 v c oh at a as at a a) 7 at a) 0) Permit Number: Facility Equipment nested Action (check applicable request boxes) Cd N C 0 C.7 aJ o` Li o U U zo Company Name: Cervi 34-1N :) an d c a as 0 O To 0 a .0 R co ar r E a b0 X 72, z O 2 en 7 ❑ Change fuel or equipment O Transfer of ownership Change permit limit H 0 ?+ v O al L- a) O > • •- E a 0 — C CQ E y y • 0` O ▪ W a O a • E 5 c),)O 0 i N L u 3 _ E c T a) C co Cu O a aat Q 0 W U • 0 h o E v i Z c o b g d•N 0 ▪ a a NCr a ❑ ❑ ® ❑ ❑ ❑ ❑ a) a. a r d M M I yr • 9 c O ro 0 U o U NENE S27 T3N R63W Source Name: Source Location: ah N ID n N 0 0 V a N 5950 Cedar Springs Road, Suite 200 Mailing Address: Arthur Beecherl Person To Contact: Fax Number: ABeecherl@VerdadOil.com E-mail Address: c- 0 N O N O a) at O_ -0 V U 'o a a) a) a) rn 0 y 2 C 0 U V O C 0 O C O .. 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Z O m `e G o r -' C ;'-- . .-2.. a CO v ov/ttn/chief/ap42/c6Q5/indcx.htmp. uid Loadin Q R c Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) 0 :J v 4- m • E O OD in U V O bD 44-- Q 0 O C U 'O 0 Uj O = .0 al O y an 5 C an • y O•— 5 • E no • E F 0 O N�I ❑ o N Y m 0 4 w 0. 4 F/ or O CO ._ nm O Le z C) ) C n J z issions Inventor no -1 0 N .-a 01 CO 7 0 O O v C) N C Ctl CO U O 0 hi !O En .0 0O Di CC c ar c O U C) N tb CD n .0 u U O O a U L Emission Factor Documentation attached (If using site specific emission factor) Estimation Method or Emission Factor Source N/A N/A N/A N/A N/A N/A N/A 3.75 Ib/1,000gal NA N/A • .1 N/A AP -42, E&P Tanks N/A N/A N/A N/A N/A N/A N/A 0.0135 Ib/1O00ga1 NA N/A / N/A E&P Tanks I 0.0767 Ib/1,000gal NA N/A ( -, i N/A E&P Tanks Requested Permitted Emissions Control led (Tons/Year) Uncontrolled (Tons/Year) Actual Calendar Year Emissionss Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor CA 7. E Uncontrolled Basis Control Efficiency (% Reduction) Ct+trol Device Description Primary Secondary C O On as v7 w V O ea • © a) ai E ▪ L 0. S Di a O L ✓ y c a✓ e on o w 0 a e O L N f VP of Operations Arthur Beecher) Name of Legally Authorized Person (Please print) Hello