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Home My WebLink About20171079COLORADO 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 April 11, 2017 Dear Sir or Madam: RECEIVED APR 1 4 2017 WELD COUNTY COMMISSIONERS On April 13, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Synergy Resources Corporation - SRC Vista Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by postings copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer PobkRz_v, tt/lq/1 7 cc PLC MMITP) I-(LCP6), PGA) £R(CH/TM/GK) 2017-1079 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Synergy Resources Corporation - SRC Vista Pad - Weld County Notice Period Begins: April 13, 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: SRC Vista Pad Oil It Gas Well Production Facility NWSW Section 2 T4N R68W Weld County The proposed project or activity is as follows: Exploration Et Production well site in the ozone non - attainment area, with condensate storage tanks, produced water storage tanks, hydrocarbon liquid loadout, a 145hp natural gas -fueled engine, a 286hp diesel engine, and a permit -exempt 48hp natural gas -fueled engine. 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 analyses, and a draft of Construction Permits 16WE0917, 16WE0918, 16WE0919, 16WE0920 and 16WE0921 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: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 I AW COLORADO w PSic Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package It: Received Date: Review Start Date: Section 01- Facility Information Andy Gruel 352602 8/24/2016; wholesale revision rec'd 3/2/17 9/26/2016; review of March revision commenced 3/14/17 (after 12 days login and scanning delays) Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Oil & NaturatOttsOroduct Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? El Carbon Monoxide (CO) Synergy Resources Corporation 123 9ECF SRC Vista Pad NWSW Section 2 T4N R68W Exploration & Production Section 02 - Emissions Units In Permit Application II Pad & Processi ❑ Particulate Matter (PM) Q Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate StorageTank yes. 16WE0917 CP1 yes % Per knrtial See Section 03 below issuance,;; 002 Produced Water'StorageTank yes 16WE0918 CP1 Yes Permit Initial Issuance 003 l iyiarbon L►quid Loading ,:... No 16WE0919 _ , CPS yes :. Initiai Nuance-- ;: 004 lyatural<Ca5RtCE Yes 16WE0920 CP1 Yes Pe€tt rsitia# Issuance 005 Diesel RICE 16WE0921 CP1 yes Permit initial; Jssuance 006 Nattiral:t3as'RICE No h' 16WE0922.XI XP No itt; Rd. APEequireXPjless than 50 hpJ er-Eitertt Section 03 - Description of Project Applicant constructed and started up this E&P site on 5/27/2016. Initially, controlled requested VOC emissions for point 001 on the APEN rec'd 8/24/16 were requested to be 168.42 tpy. This is a potential violation of Regulation Number 3, Part D, in their failure to obtain an NANSR permit prior to commencing construction and failure to implement LAER and obtain offsets. I explained the gravity of this situation to the applicant and their consultant. They monitored actual VOC emissions on a rolling -12 basis to make sure they stay below 100 tpy. The applicant completely revised their application in March 2017 to become synthetic minor for VOC for both Title V and NANSR. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why?" Requesting' yi nor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?' i a 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? No Section 01- Adminstrative Information Condensate Storage Tank(s) Emissions Inventory 16wEO917 CP1 Condensate. Facility AIRs ID: 123 9ECF Plant Point Section 02- Epuloment Description Details Detailed Emissions Unit Description: Foto (4) 400 -bbl Reed -roof atmpspherfc storage Ms Ehsission Control Device Enclosed combustors With minimum Control efficiency of 9514. Description: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = 432,306 Barrels (bbl) per year 538,768 Barrels (bbl) per year 518,768', Barrels (bbl) per year Btu/scf 52.26.. scf/bbl Actual Condensate Throughput While Emissions Controls Operating = 27112200 sef/yr (from Promax) divided by 518768 bbl/yr 53,343 MMBTU per year 64,012 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 64,012 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant 7 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) liZEIIMINIIIIINNVIIININNINICIII r\\\\ItI\\\'\O MilliMill8.13 0.25650 I \ : iii..NILIVIIIIN Y.\\\\ .\\\\ill 0 01 .. I'' MIIIIKT 0.00664 0.00043 N.IIIII\*I\I \\\\ Milliell 0,00615 0.00031 \1.\\'40 6\\\,\* MEMI=MEMQ 0.00002\\\\ h\\\ 1 0.00177 0.00009 \\\\ L\\\\1 • 0.0690 0.00345 141.1447401ILVIII .\\\\` IEZIECI 0.000615 0.00003\\\\\\\\� M PM2.5 Control Device 0.068 Uncontrolled E.F. (Ibs/bbl Condensate Throughput) 0.0000 0.0000 0.0084 Emissions Factor Source Citation Section 05 - Emissions Inventory 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 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.2 2.2 2.18 1.8 1.8 1330.6 1330.6 66.53 1108.9 55.4 9.9 9.9 9.92 8.3 8.3 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) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2.24 2.24 0.11 1.9E+00 9.3E-02 1.60 1.60 0.08 1.3E+00 6.6E-02 0.09 0.09 0.00 7.4E-02 3.7E-03 0.46 0.46 0.02 3.8E-01 1.9E-02 17.90 17.90 0.89 1.5E+01 7.5E-01 0.16 0.16 0.01 1.3E-01 6.6E-03 ion 06- Regulatory 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 0000 Storage tank is subject to NSPS 0000, including but not limited to Regulation 8, Part E, MACF Subpart HH Storage Tank is not subject to MACI HH (See regulatory applicability worksheet for detailed analysis) Controlled PTE Uncontrolled PTE (Ib/yr) (lb/yr) 4482 224 3190 160 178 9 918 46 35795 1790 319 16 432,306.: Barrels (bbl) per year 1 of 2 K:\PA\2016\ 16WE0917.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Samoling 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. 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 OS- Technical Analysis Notes Applicant modeled flash and working/breathing emissions using Promax, based on a model throughput of 4323O6 b modeled throughput to arrive at the emission factors listed above, which match the amounts listed on the APEN. Vapors from the condensate and produced water tanks are controlled at a single bank of enclosed combustors, The fuel based on Proman (for condensate flash & working/breathing). Section 09- Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # 01 SCC Code 4 utputsfar VOC and HAP emissions are d Uncontrolled Emissions Pollutant Factor Control % Units NOx 0.200 0 lb/1,000 gallons condensate throughput VOC 122.143 95 lb/1,000 gallons condensate throughput CO 0.911 0 lb/1,000 gallons condensate throughput Benzene 0.206 95 lb/1,000 gallons condensate throughput Toluene 0.146 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.008 95 Ib/1,000 gallons condensate throughput Xylene 0.042 95 lb/1,000 gallons condensate throughput n -Hexane 1.643 95 lb/1,000 gallons condensate throughput 224 TMP 0.015 95 113/1,000 gallons condensate throughput 2 oft K:\PA\2016\16W E0917.CP1.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Synergy Resources Corporation 123 9ECF SRC Vista Pad History File Edit Date Ozone Status 3/14/2017 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.S H25 S02 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S S02 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL - i_ 0.0 0.0 OA 0.0 0.0 0.0 0.0 0.0 00 0T 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility- No Previous Total Previous Perrnfted Facility total 0.0 0.0 00 0.0 0.0 00 0.0 0.0 0.0 5.5 0.0 0.0 0.0 0.0 0.0 0.0 00 0.0 001 16WE0917 Condensate storage. iSHObbl 2.2 1,330.3 9.9 22.4 2.2 66.5 99 1.0 SSEF5 submitted 002 16WE0918 Produced water storage, BOO bbl 0.0 18.3 0.0 1.8 0.0 0.8 0.0 0.1 Default EFs. 003 i6WE0919 Lcadoutb tank trucks 2.5 0.0 2.5 00 max 10% of condensate production is loaded out by truck; usually its LACT pipeline 004 16WE0920 Cat G3306NA. 145 hp 15.3 3.1 18.4 0.2 1.4 1.0 1.4 0.2 005 1BWE0921 Sohn Deere 6068HF485 diesel generator 0.3 0.3 2.4 7.0 3.0 1.2 0.0 0.3 0.3 2.4 7.0 3.0 1.2 0.0 006 16WE0922.XP Zenith 428, 2.9L .48 hp 0.0 0.0 1.3 1.3 2.2 0.0 0.0 0.0 1.3 1.3 2.2 0.0 XP due to less than 50 hp when limited to 2100 rpm APEN-e empt and Insignificants Fugitives 0.37 0.02 037 0.02 Separator Heaters 0.14 0.14 0.01 1.78 0.10 1.50 0.04 0.14 0.14 0.01 178 0.10 1.50 0.04 I1 FACILITY TOTAL 0.4 0.4 0.0 2.4 27.5 1,356.5 0.4 33.2 24.5 0.4 0.4 0.0 2.4 13.7 75.2 0.4 16.3 1.4 V0C: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (POD and OP) HAPS: Syn Minorn-hexane 2222: Syn Minor Pemr,ttnd Facciky Total 0.3 0.3 0.0 2.4 24.5 1,355.1 0.0 29.5 24.4 0.3 03 0.0 24 10.6 73.8 0.0 12.6 1.3 Excludes units exempt from permits/APENs (d) Cha 8e in Permitted Emissions 0.3 0.3 0.0 2.4 10.6 73.8 0.0 12.6 Pubcom required based on new syn minor limits Note 1 Total VOC (4) Change in Total Permitted Facility Emissions (point and fugitive VOC emission (point and fugitive) 755 Facility is eligible for GP02 because <90 Sty Project emissions less than 25/50 tpy 73.8 Note 2 Page I oft Printed 3/16/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Synergy Resources Corporation County AIRS ID 123 Plant AIRS ID 9ECF Facility Name SRC Vista Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bb1 4482 3190 178 918 35795 319 22.4 002 16WE0918 Produced water storage, 800 bbl 873 2745 1.8 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 f 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTAypy) 0.1 0.0 0.0 2.7 1.6 0.1 0.5 19.3 0.0 0.2 0.0 0.0 24.5 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bb1 22 160 9 46 1790 16 1.0 002 16WE0918 Produced water storage, 800 bbl 44 137 0.1 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTALlitpy) 0.1 0.0 0.0 0.0 0.1 0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.4 2 I239ECF.x1sx 3/16/2017 Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package It: Received Date: Review Start Date: Section 01- Facility Information Andy Gruel 352602 8/24/2016; wholesale revision recd 3/2/17 9/26/2016; review of March revision commenced 3/14/17 (after 12 days login and scanning delays) Company Name: Synergy Resources Corporation County AIRS ID: 123 Plant AIRS ID: 9ECF Facility Name: SRC Vista Pad Physical Address/Location: NWSW Section 2 T4N R68W Type of Facility: Exploration tProduction.Well Pad ' What industry segment? Oil & Nato oduction & Process Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ID Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) ❑o Ozone (NOx & VOC) AI Rs Point p Emissions Source Type Emissions Control? Permit U Issuance # Self Cert Required? Action Engineering Remarks 001 002 003 004 Na 005. 006 e Storage Tank Produced Wat Diesel RICI e Tank Vi No 16W E0917 16W E0918 16W E0919 16WE0920 16W E0921 L6WE0922.XI CP1 CP1 CP1 CPI CP1 XP Pert ISs uani Perm n' Require :ermit Eacecrr See Section 03 below XP(less than 50 hp) Section 03 - Description of Project Applicant constructed and started up this E&P site on 5/27/2016. Initially, controlled requested VOC emissions for point 001 on the APEN reed 8/24/16 were requested to be 168.42 tpy. This is a potential violation of Regulation Number 3, Part D, in their failure to obtain an NANSR permit prior to commencing construction and failure to implement LAER and obtain offsets. I explained the gravity of this situation to the applicant and their consultant. They monitored actual VOC emissions on a rolling -12 basis to make sure they stay below 100 tpy. The applicant completely revised their application in March 2017 to become synthetic minor for VOC for both Title V and NANSR. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why?' Etequestittg Syr thebc Minor Pe 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? No Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 Section 01- Adminstrative Information Facility AIRs ID: 123 92 Plan Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput= Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = 103,985... Barrels (bbl) per year 124,782, Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Applicant did not provide NOx or CO emission calculations for control of vapors from these tanks. In the absence of gas volume information, I applied the condensate flare emission factors from the 3/22/2005 CDPHE memo (0.003716 NOx/lb VOC, and O.0O94 lb CO/lb V0C). Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Produced Water Storage Tanks Uncontrolled E.F. (lbs/bbl Produced Water Throughput) Controlled E.F. (lbs/bbl Produced Water Throughput) Emissions Factor Source Citation Control Device Uncontrolled E.F. (lb / lb VOC ( controlled) Uncontrolled E.F. (Ibs/bbl Produced Water Throughput) `N, , , NtANA ' 0.0037 ! 0.000048 0:262 0.01310X\''\1\` IMMIMEINIILN.NlibiNilliVICIIIIi.1011b0.0094'. Section 05 - Emissions Inventory 0.00110 0.000123 %WOO Wk. -NO k XXX `8 Actual Produced Water Throughput While Emissions Controls Operating = 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 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0-0 0.003 0.0 0.003 0.003 0.003 16.3 16.3 0.82 13.6 0.7 0.008 0.0 0.008 0.01 0.01 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) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 4.4E-01 4.4E-01 2.2E-02 3.6E-01 1.8E-02 1.4E+00 1.4E+00 6.9E-02 1.1E+00 5.7E-02 Section 06 - Regulatory Summary Analyst Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, 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 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) Controlled PTE Uncontrolled PTE (lb/yr) (lb/yr) 873 44 2745 137 103,985<.. 1 of 2 K:\PA\2016\ 16WE0917.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 Section 07- Initial and Periodic Sampling and Testing Reauirements 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 water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. Does the company request a control device efficiency greater than 95% for a flare or combustion device? z' 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 Applicant used state default emission factorsfor VOC, hen emission factor for produced water emissions. a -hexane. Because uncontrolled VOCis NOx and CO emissions from this point were estimated using the 3/22/2005 emission factor scalar 01.0037lb NOx/ W VOC controlled, and 0.0i as producedwaterwdt produce less vapors than condensate. Using this conservative oath, NOx and Cl) emissions arecsti8. de mmmus. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point g Process if SCC Code 002 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+Flashing losses Uncontrolled Emissions Pollutant Factor Control % Units NOx 0.0012 0 lb/1,000 gallons liquid throughput VOC 6.2381 95 lb/1,000 gallons liquid throughput CO 0.0029 0 lb/1,000 gallons liquid throughput Benzene 0.1667 95 lb/1,000 gallons liquid throughput n -Hexane 0.5238 95 lb/1,000 gallons liquid throughput 2 of 2 K:\PA\2016\16WE0917.CP1.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name S9nef5H Resources Corporation 123 9ECF SRC Vista Pad History File Edlt Date Ozone Status 3/14/2017 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx HOC Fug VOC CO Total HAPs REMARKS Previous FACIIJTY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Fadlily - No Previous Total P100000 PermVtud Fealty total 0.0 00 0.0 0.0 00 00 0.0 0.0 0.0 0.0 0.0 00 0.0 0.0 0.0 0.0 0.0 0.0 001 16WE0917 Condensate storage, l6Wbbl 2.2 1.330.3 9.9 224 2.2 68.5 9.9 1.0 SSEFs submitted 002 16WE0918 Produced water storage, 800 bbl 0.0 18.3 0.0 1.8 0.0 0.8 0.0 0.l Default EFs. 003 16WE0919 Loadout to tank trucks 2.5 0.025 00 max 10% of condensate production is loaded out by truck: usually Ifs LACT pipeline 004 16WE0920 Cat G3308NA. 145 hp 15.3 3.1 18.4 0.2 1.4 1.0 1.4 0.2 005 16WE0921 John Deere 6068HF485 diesel _generator 0.3 0.3 2.4 7.0 3.0 1.2 0.0 0.3 0.3 24 7.0 3.0 1.2 0.0 006 16WE0922.XP Zenith 428, 2.8L .48 hp 0.0 0.0 1,3 1.3 2.2 0.0 0.0 0.0 1.3 1.3 22 0.0 XP due to less than 50 hp when limited to 2100 rpm APEN-exempt and Insonificants Fugitives 0.37 0.02 0.37 0,02 Separator Heaters 9 0.14 0.14 0.01 1.78 0.10 1.50 0.04 0.14 0.14 0.01 1/8 0.10 1.50 0.04 FACILITY TOTAL 0.4 0.4 0.0 2.4 27.5 1,356.5 0.4 33.2 24.5 0.4 0.4 0.0 2.4 13.7 75.2 0.4 18.3 1.4 HOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PAD and OP) HAPS: Syn Minor n -hexane ZZZZ: Son Minor Perorated Facibfy Total 0.3 03 0.0 2.4 24.5 1,355.1 0.0 29.5 24.4 03 0.3 0.0 2.4 10.6 73.8 0.0 12.6 1.3 Excludes units exempt frompemxfs/APENs (A) Cho a in Permitted Eniseions 0.3 0.3 0.0 2.4 10.6 73.8 0.0 12.6 Pubcom required based on new syn minor limits Note 1 Total VOC (A) Change in Total Permitted Facility Emissions (point and fugitive VOC missions (point and fugitive) 75.5 Facility is eligible for GP02 because <90Ipy Project emissions less than 25/50 ¢1y 738 Note 2 Page I oft Primed 3/16/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Synergy Resources Corporation County AIRS ID 123 Plant AIRS ID 9ECF Facility Name SRC Vista Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (Spy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bb1 4482 3190 178 918 35795 319 22.4 002 16WE0918 Produced water storage, 800 bbl 873 2745 1.8 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 _ 0.0 0.0 4 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTAL)tpy) 0.1 0.0 0.0 2.7 1.6 0.1 0.5 19.3 0.0 0.2 0.0 0.0 24.5 *Total Reportable = all HAPs where uncontrolled emissions c de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bb1 22 160 9 46 1790 16 1.0 002 16WE0918 Produced water storage, 800 bbl 44 137 0.1 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.0 0.1 0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.4 2 1239ECF.xtsx 3/16/2017 Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package ft: Received Date: Review Start Date: Section 01- Facility Information Andy Gruel 352602 8/24/2016; wholesale revision rec'd 3/2/17 9/26/2016; review of March revision commenced 3/14/17 (after 12 days login and scanning delays) 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 If yes, for what pollutant? Synergy Resources Corporation 123. 9ECF SRC Vista Pad NWSW Section 2 T4N R68W Prod i tion:Well Pad 'roduction & Process non -attainment area? Yes O Carbon Monoxide (CO) ❑Particulate Matter (PM) Section 02 - Emissions Units In Permit Application 0 Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Storage Tank' Yes '`" 16WE0917 CP1 Yes " P rrnit lrsitia , Issuance." See Section 03 below 002 Produced'WaterStorage 'lank Yes 16WE0918 CP1 Y P' Issuance' 003 - Hydrocarbon Liquid Loading No" 16WE0919 CP1 Yes ,..,, PerErtt lniiial lssuani , 004 . Natural Gas RICE Yes - 16WE0920 CP1 Feet Initial_., Issuance 005 Diesel RICE �_- No 16WE0921 CP1 des , Pitt�a errMttlr l= Issuance 006 Natural was RICI No 16WE0922.XF XP No APE Required , Permit i xerrtpt XP(Iess than 50 hp) Section 03 - Description of Project Applicant constructed and started up this E8iP site on 5/27/2016. Initially, controlled requested VOC emissions for point 001 on the APEN recd 8/24/16 were requested to be 168.42 tpy. This is a potential violation of Regulation Number 3, Part D, in their failure to obtain an NANSR permit prior to commencing construction and failure to implement LAER and obtain offsets. I explained the gravity of this situation to the applicant and their consultant. They monitored actual. VOC emissions on a rolling -12 basis to make sure they stay below 100 tpy. The applicant completely revised their application in March 2017 to become synthetic minor for VOC for both Title V and NANSR. Section 04 - Public Comment Requirements Is Public Comment Required? Yes Requesting Synthetic If yes, why?' Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 Nir 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? No 123-9ECF-003 16WE0919 CP1 APEN rec'd 8/24/16 Loadout of hydrocarbon liquids when LACT/condensate pipeline is down. Emissions Inventory Analysis AP -42: Chapter 5.2 Equation 1 P = true vapor pressure of liquid loaded [psia] L = 12.46*S*P*M/T M = molecular weight of vapors [lb/lb-mole] L = loading losses in lb per 1000 gallons loaded T = temperature of bulk liquid loaded [deg. R] S = Saturation Factor 1 degree Fahrenheit = 460.67 degree Rankine Assumed: Condensate pipeline is down a maximum of 10% of the year. The requested throughput entered below reflects that 10% of the permit limit of the condensate tanks (point 001). Criteria Pollutants S P M T L 0.6 Submerged loading: dedicated normal service 3.44 psia AP -42 Table 7.1-2 @ 50 F 45.42 lb/lb-mole Promax 512.67 deg. R 2.28 9.57E-02 Annual requested Throughput Annual requested VOC emissions lb/10^3 gal lb/bbl 2,178,834 Gallons per Year 4, 4 Pounds per Year Tons VOC per Year Non -Criteria Reportable Air Pollutants/Hazardous Air Pollutants VOC NCRP NCRP Are NCRP Weight emission emission Emissions Emissions Component Fraction factor(Ib/bbl) factor lb/bbl lb r Reportable? Benzene 0.00169 9.57E-02 8 No n -hexane 0.00270 9.57E-02 13 No A 0.00016 0.00026 NCRP emissions were estimated by multiplying the NCRP weight fraction by the VOC loading loss emission factor calculated above. All other NCRP5 are below the reporting threhold of 250 lb/yr. Regulatory Considerations Is this site considered an exploration and production location (e.g. well pad)? Yes If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) of crude oil per day 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.I 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.1.1 Is this site located in an ozone non -attainment area? Yes If yes, this source is subject to Reasonably Available Control Technology (RACT) requirements under Regulation 3, Part B Section III.D.2.a. This requirement may be met using "submerged fill" and/or vapor balance with emissions routed to an emissions control device. Is this facility classified as a major source of HAPs? No If yes, evaluate if 40 CFR, Part 63, Subpart EEEE "Organic Liquids Distribution" MACT provisions apply Does this facility involve the loading of refined crude/condensate in the form of "gasoline"? If yes, proceed to evaluate the following: Is this facility classified as a "Terminal" as defined per Regulation 7, Section VI.C.2.a? If yes, the provisions of Regulation 7, Section VI.C.2 may apply Is this facility classified as a "Bulk Plant" as defined per Regulation 7, Section VI.C.3.a? If yes, the provisions of Regulation 7, Section VI.C.3 may apply Section 04 - SCC Coding Emissions Factor Pollutant (lb/1,000 gallons) V0C 2.28 lb/1,000 gallons Benzene 0.0039 lb/1,000 gallons n -hexane 0.0062 lb/1,000 gallons 40600132: Crude Oil: Submerged Loading (Normal Service) Use if S = 0.6 No No No COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Synergy Resources Corporadon 123 9ECF SRC Vista Pad History File Edit Date Ozone Status 3/14/2017 Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H25 SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Faality -.50 Previous Total Previous Permitted Fee.- total 0.0 0.0 0.0 0.0 0.0 0.0 00 0.0 0.0 00 00 0.0 0.0 00 00 0.0 00 0.0 001 16WE0517 Condensate storage. 1600bbl 2.2 1,3303 9.9 22.4 - 2.2 86.5 9.9 1.0 SSEFs submitted 002 16WE0918 Produced water storage. 800 bbl 0.0 16.3 0.0 1.8 0.0 0.8 0.0 0.1 Default EFs. 003 16WE0919 Loadout to tank trucks 2.5 0.0 2.5 0 0 max 10% of condensate production is loaded out by truck; usually I's LACT pipeline 004 16WE0920 Cat G3306NA. 145 ho 153 3.1 18.4 0.2 1.4 1.0 t4 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.3 0.3 2.4 7.0 3.0 1.2 0.0 0.3 0.3 2.4 7.0 3.0 1.2 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 0.0 0.0 1.3 1.3 2.2 0.0 0.0 0.0 1.3 1.3 2.2 0.0 XP due to less than 50 hp when limited to 2100 rpm APEN-exempt and Insignificants Fugitives 0.37 0.02 037 0.02 Separator Heaters 0.14 0.14 0.01 1.78 0.10 1.50 0.04 0.14 0.14 0.01 178 0.10 1.50 0.04 FACILITY TOTAL 0.4 0.4 0.0 2.4 27.5 1,356.5 0.4 33.2 24.5 0.4 0.4 0.0 2.4 13.7 75.2 0.4 16.3 1.4 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n-texane ZZZZ: Syn Minor Permitted Fecibfy Tote) 0.3 0.3 0.0 2.4 24.5 1,355.1 0.0 29.5 24.4 0 3 0.3 0 0 2.4 10.6 73.8 0.0 12.6 1.3 Excludes unfs exempt from pennbs/APENs (A) Change in Permitted Emissions 0.3 0.3 00 2.4 10.6 73.8 00 12.6 Pubcom required based on new syn minor limits Note 1 Total VOC (A) Change in Total Permitted Facility Emissions (point and fugitive VOC emissions (point and fugitive) 75.5 Foc lity Is eligible for GP02 because < 90 By Project emissions less than 25/50 roy 73.8 Note 2 Page I oft Printed 3/16/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Synergy Resources Corporation County AIRS ID 123 Plant AIRS ID 9ECF Facility Name SRC Vista Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bb1 4482 3190 178 918 35795 319 22.4 002 16WE0918 Produced water storage, 800 bbl 873 2745 1.8 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 tt 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTALIStpyl 0.1 0.0 0.0 2.7 1.6 0.1 0.5 19.3 0.0 0.2 0.0 0.0 24.5 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bbl 22 160 9 46 1790 16 1.0 002 16WE0918 Produced water storage, 800 bbl 44 137 0.1 003 16WE0919 Loadouttotanktrucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTALstpyl 0.1 0.0 0.0 0.0 0.1 0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.4 2 1239ECF.xlsx 3/16/2017 Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Andy Gruel 352602 8/24/2016; wholesale revision rec'd 3/2/17 9/26/2016; review of March revision commenced 3/14/17 (after 12 days login and scanning delays) Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: Exploratlt What industry segment? Oil & Nato 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 9ECF SRC Vista Pad NWSW Section 2 T4 R68W rr Welt Pad Processin Yes ❑ Particulate Matter (PM) (] Ozone (NOx & VOC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance it Self Cell Required? Action Engineering Remarks 001 Condense Storage"fank Yes 16WE0917 CP1 Yes :: Permit [nitiat Issuance See Section 03 below 002 Produced Water Storagelank- Yes 16WE0918 CP1 yes Permit Initial. Issuance 003 Hydrocarbon Liquid Loading No 16WE0919 CP1 Yes Perrrtlt initial -- �fssuance 004 Iatural Gas RICE lies -; 16WE0920 CP1 Yes lmtlat lssuace - 005 Diesel RICIe :, No ' - 16WE0921 CP1 Pert Itla Issuance 006 Natural. Gas RICIM No 16WE0922.Xl XP No - APENRequired/ Permit Exempt XP{less than 50 hp} Section 03 - Description of Project Applicant constructed and started up this E&P site on 5/27/2016. Initially, controlled requested VOC emissions for point 001 on the APEN recd 8/24/16 were requested to be 168.42 tpy. This is a potential violation of Regulation Number 3, Part D, in their failure to obtain an NANSR permit prior to commencing construction and failure to implement LAER and obtain offsets. I explained the gravity of this situation to the applicant and their consultant. They monitored actual VOC emissions on a rolling -12 basis to make sure they stay below 100 tpy. The applicant completely revised their application in March 2017 to become synthetic minor for VOC for both Title V and NANSR. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why?' Requesting Synthetic Minor Permit Yes 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? No Summary of Preliminary Analysis - NG RICE Company Name Synergy Resources Corporation Facility Name SRC Vista Pad Facility Location NWSW Section 2 T4N R68W Facility Equipment ID ENG-1 Permit No. AIRS Review Date Permit Engineer 16WE0920 123/9ECF/004 03/15/2017 Andy Gruel Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One (1) Caterpillar, Model G3306NA, Serial Number 46201287, natural gas -fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 145 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for VRU compression. Natural Gas Consumption Requested (MMscf/yr) 6.12 Requested (MMscf/m) 0.52 Fuel Heat Value (Btu/scf) 1614 BSCF (Btu/hp-hr) 7775 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 8760 Uncontrolled Controlled NOx Manufacturer's spec / EMIT EMIT Technologies - Catalyst Spec VOC Manufacturer's spec / EMIT EMIT Technologies - Catalyst Spec CO Manufacturer's spec / EMIT EMIT Technologies - Catalyst Spec Formaldehyde AP -42 Table 3.2-3 No control SOX AP -42; Table 3.2-3 (7/2000); Natural Gas No Control TSP AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM 10 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control Other Pollutants AP -42; Table 3.2-3 (7/2000); Natural C No control Point Summary of Criteria Emissions (tpy) Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 15.26 1.40 15.3 90.8% VOC 3.08 0.98 3.1 68.2% CO 18.35 1.40 18.3 92.4% SOx 0.0 0.0 0.0 0.0% TSP 0.1 0.1 0.1 0.0% PM10 0.1 0.1 0.1 0.0% PM2.5 0.1 0.1 0.1 0.0% Total HAPs* 0.0 0.0 0.2 0.0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants (lb/yr HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde * * 202 0.0% Methanol * * 30 0.0% Acetaldehyde * * 28 0.0% Acrolein * * 26 0.0% Benzene * * 16 0.0% 1,3 -Butadiene * * 7 0.0% Toluene ** * 6 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source Reg 7 XVII.E Standards (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg 7 XVI.B (Ozone NAA requirements) applies? No MACT ZZZZ (area source) Is this engine subject to MACT 7777 area Yes source requirements? NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requirements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes This analysis is based on the revised application rec'd 3/2/2017. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Synergy Resources Corporation 123 9ECF SRC Vista Pad History File Edit Date 3/14/2017 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.S H2S SO2 NOx VOC Fug HOC CO Total RAPS PM10 PM2.5 HOS SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 OD 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Palmated Facility total 0.0 0.0 0.0 00 0.0 0.0 0.0 0.0 00 0.0 00 0.0 0.0 0.0 D0 0.0 0.0 0.0 001 16WE0917 Condensate storage. 1600bbI 2.2 1,3303 99 22.4 2.2 66.5 9.9 1.0 SSEFs submitted 002 16WE0918 Produced water storage, 800 bbl 0.0 16.3 00 1.8 0.0 0.8 0.0 0.1 Default EFs. 003 16WE0919 Loadout to tank trucks 2.5 00 2.5 0.0 max 10% of condensate production is loaded out by truck; usually it's LACT pipeline 004 16WE0920 Cat G3306NA. 145 hp 153 31 18.4 0.2 1A 1.0 1.4 0.2 005 16WE092/ John Deere 6068HF485 diesel generator 0.3 0.3 2.4 7.0 3.0 12 0.0 0.3 0.3 24 7.0 3.0 1.2 0.0 006 16WE0922.XP Zenith 428, 2.8L 48 hp 0.0 0.0 1.3 1.3 22 0.0 0.0 0.0 1.3 1.3 2.2 0.0 XP due to less than 50 hp when limited to 2100 rpm APEN-exempt and Insignificants Fugitives 0.37 0.02 0.37 0.02 Separator Heaters 0.14 0.14 0.01 1.78 0.10 150 0.04 0.14 0.14 0.01 1.78 0.10 1.50 0.04 FACILITY TOTAL 0.4 0.4 0.0 2.4 27.5 1,358.5 0.4 33.2 24.5 0.4 0.4 0.0 2.4 13.7 75.2 0.4 18.3 1.4 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSC. and OP) HAPS: Syn Minor n -hexane ZZZZ: Syn Minor Permitted Faci0y Total 0.3 0.3 0.0 2.4 24.5 1,355.1 0.0 295 24.0 0.3 03 0 0 2.4 10.6 73.8 0 0 12.6 1.3 Excludes units exempt fiom peanits/APENs (5) Chan 'm Permitted Emissions 0.3 0.3 00 2.4 10.8 73.8 0.0 12.6 Pubcom required based on new syn minor limits Note 1 Total VOC Facility Emissions (point and fugitive (A) Change in Total Permitted VOC emissions (point and fugitive) 755 Facility is eligible for GP02 because <90 ipy Project emissions less than 25/50 ipy 73.8 Note 2 Page I oft Pdntd 3/16/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY -HAPs Company Name Synergy Resources Corporation County AIRS ID 123 Plant AIRS ID 9ECF Facility Name SRC Vista Pad Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bbl 4482 3190 178 918 35795 319 22.4 002 16WE0918 Produced water storage, 800 bbl 873 2745 1.8 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 - Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 I 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 2.7 1.6 0.1 0.5 19.3 0.0 0.2 0.0 0.0 24.5 'Total Reportable = all HAPs where uncontrolled emissions s de minimus values Red Text: uncontrolled emissions v de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bb1 22 160 9 46 1790 16 1.0 002 16WE0918 Produced water storage, 800 bbl 44 137 0.1 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 8 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.0 0.1 0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.4 2 I239ECF.xlsx 3/16/2017 Colorado Air Permitting Project Version No. 1.00 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Andy Gruei 352602 8/24/2016; wholesale revision rec'd 3/2/17 9/26/2016; review of March revision commenced 3/14/17 (after 12 days login and scanning delays) Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Synergy Resources. Corporation 123 9ECF SRC Vista Pact NWSW Section 2 Exploration & Fro bit & Natural Gat 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 ❑ Particulate Matter (PM) ❑ Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 nd rage Tan es 16W E0917 CP1 Permit Initial Issuance Penn See Section 03 below 002 003 004 Pr dui d': Er 5tora i T ulti Loading es 16W E0918 16W E0919 16WE0920 CP1 CP1 CP1 005 RIC) 16WE0921 CP1 Yes uani nct Permit; ISsua9 Pei knittn ( 006 L6WE0922.X1 XP P RequErpdf it Exempt XP(less than 50 hp) Section 03 - Description of Project Applicant constructed and started up this E&P site on 5/27/2016. Initially, controlled requested VOC emissions for point 001 on the APEN rec'd 8/24/16 were requested to be 168.42 tpy. This is a potential violation of Regulation Number 3, Part D, in their failure to obtain an NANSR permit prior to commencing construction and failure to implement LAER and obtain offsets. I explained the gravity of this situation to the applicant and their consultant. They monitored actual VOC emissions on a rolling -12 basis to make sure they stay below 100 tpy. The applicant completely revised their application in March 2017 to become synthetic minor for VOC for both Title V and NANSR. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why?' Requesting yes ethetic Minor Permit 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? No Preliminary Analysis Summary Action: Applicant: Permit No.: Facility ID: Location: Facility Description: Status: Initial Approval - Synergy Resources Corporation 16WE0921 123-9ECF NWSW Section 2 T4N R68W Oil & Gas E&P Site --- this sheet is for a diesel generator Non -attainment Facility Summary Emission Estimates: Existing Permitted Emissions Existing PTE Emissions Permitted Controlled Emissions Permitted Uncont. Emissions Maximum Potential Engineer: Andy Gruel Supervisor: Stefanie Rucker TSP PM10 N0x VOC CO SO2 0 0 0 0 0 0 0 0 0 0 0 0 0.25 0.25 7.01 2.96 1.24 2.38 0.25 0.25 7.01 2.96 1.24 2.38 0.25 0.25 7.01 2.96 1.24 2.38 Point Summary 005 John Deere, 6068HF485, sn: PE6068L114692 Permitted Controlled Emissions Generator Total Permitted Uncont. Emissions Generator Total Maximum Potential Generator Total Percent Control (generator) HAPs List: 0.25 0.25 7.01 2.96 1.24 2.38 0.25 0.25 7.01 2.96 1.24 2.38 0.25 0.25 7.01 2.96 1.24 2.38 0.25 0.25 7.01 2.96 1.24 2.38 0.25 0.25 7.01 2.96 1.24 2.38 0.25 0.25 7.01 2.96 1.24 2.38 0% 0% 0% 0% 0% 0% HAP Name Bin Cont. Emissions Uncont. Emissions None are reportable Internal Combustion Diesel Generator Applicant: Synergy Resources Corporation Engineer: Andy Gruel Permit Number: 16WE0921 AIRs ID: 123-9ECF-005 Unit Use: Electric power generation for oil and gas production Location: NWSW Section 2 T4N R68W Status: Non -attainment County: Weld Date: 24 -Mar -17 APEN Expiration Date: 24 -Aug -21 Engine Make John Deere Engine Model No. 6068HF485 Engine Serial No. PE6068L114692 Controls/Efficiencies No controls Permit Status: Initial Approval Modification: Type Emission Unit Electricity generation Generator Kilowatt: kW Horsepower: 286 hp Fuel Consumption: 13.69 gal/hr gal/yr Fuel Flow Rate: 0 MMBtu/hr Heating Value: 0.13703 MMBtu/gal Calculated: 13.7 gal/hr 119,924 gal/yr 16433.2 MMBtu/yr 286 Horsepower 1.9 MMBtu/hr Annual Operation: 8760.0 hr/yr Capacity Factor.: 1.00 Fuel Type: No. 2 Fuel Oil Sulfur Contant 0.05 Hours/Year Potential 8760 Pollutant PM PM10 SO2 NOx VOC CO 1 or 8760 hours/year Percent by weight Emission Factor PTE (Ib/hp*hr) (lb/MMBtu) (lb/hr) (tons/yr)* (ton/yr) 0.000198 0.0302 0.0567 0.25 0.25 0.000198 0.0302 0.0567 0.25 0.25 0.001902 0.2900 0.5440 2.38 2.38 0.005600 0.8537 1.6015 7.01 7.01 0.002361 0.36 0.6753 2.96 2.96 0.000992 0.1512 0.2837 1.24 1.24 0.000006 0.0009 0.0017 15.28 0.01 0.000003 0.0004 0.0008 6.74 0.00 0.000002 0.0003 0.0005 4.77 0.00 0.000008 0.0012 0.0022 19.39 0.01 0.000005 0.0008 0.0014 12.65 0.01 0.000001 0.0001 0.0002 1.48 0.00 0.000001 0.0001 0.0002 1.31 0.00 Benzene (BIN A) Toluene (BIN C) Xylene (BIN C) Formaldehyde (BIN A) Acetaldehyde (BIN A) Acrolein (BIN A) Naphthalene (BIN B) * HAPs are in lb/yr Inventory Information Company Synergy Resources Corporation Permit No. 16WE0921 AIRs No. 123-9ECF-005 SIC # 211111 SCC For Generator 2-02-004-01 Date: September 27, 2016 Controlled Pollutant EF EF Source Emissions PTE % Control Type of Control Status lay lay PM 0.0302 Manufacturer 0.25 0.25 PM -10 0.0302 Manufacturer 0.25 0.25 SOx 0.2900 AP -42 2.38 2.38 NOx 0.8537 Manufacturer 7.01 7.01 VOC 0.3600 AP -42 2.96 2.96 CO 0.1512 Manufacturer 1.24 1.24 HAPs I yyr lay 71-43-2 Benzene 9.30E-04 AP -42 15.28 0.01 50-00-0 Formaldehyde 1.18E-03 AP -42 19.39 0.01 75-07-0 Acedaldehyde 7.70E-04 AP -42 12.65 0.01 Total HAPs 2.88E-03 AP -42 47.33 0.02 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Synergy Resources Corporation 123 9ECF SRC Vista Pad History Flle Edit Date Ozone Status 3/14/2017 Non -Attainment EMISSIONS - Uncontrolled (tons Der year EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PP/110 PM2.5 825 SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 OA New Folly - No Previous Total Previous Permitted Fealty total 0.0 00 00 0.0 00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 00 0.0 00 0.0 0.0 00 001 16WE0917 Condensate storage. 1600bb1 2.2 1,330.3 9.9 22.4 2.2 66.5 9.9 1.0 SSEFs submitted 002 16WE0918 Produced water storage, 800 bbl 0.0 163 0.0 1.8 0.0 0.8 0.0 0.1 Default EFs. 003 16WE0919 Loadout to tank trucks 25 0.0 2.5 0.0 max 10% of condensate production is loaded out by tuck; usually its LACT pipeline 004 16WE0920 Cat G3306NA. 145 hp 153 3.1 18.4 0.2 1.4 1.0 1.4 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.3 0.3 2.4 7.0 3.0 1.2 OA 0.3 0.3 2.4 7.0 3.0 1.2 0.0 006 16WE0922.XP Zenith 426 2.OL .48 hp OD 0.0 1.3 1.3 2.2 0.0 0.0 0.0 1.3 1.3 2.2 0.0 XP due to less than 50 hp when limited to 2100 pm APEN-exempt and lnslpn0,ants Fugitives 0.37 0.02 0.37 0.02 Separator Heaters 0.14 0.14 0.01 1.78 010 1.50 0.04 0.14 014 0.01 1.78 0.10 1.50 0.04 FACILITY TOTAL 0.4 0.4 0.0 2.4 27.5 1,356.5 0.4 33.2 24.5 0.4 0.4 0.0 2.4 13.7 75.2 0.4 16.3 1.4 VOC: Syn Minor (NANSR and OP) NOT: Minor (NANSR and OP) CO: Minor (POD and OP) HAPS: Syn Minor nhexane 7777: Son Minor Permitted Faulk,' Total 0.3 0.3 0.0 2.4 24.5 1,355.1 0.0 29.5 24.4 0.3 0.3 00 2.4 10.8 738 00 12.6 1.3 Excludes unls exempt from pemnfs/APENs ID) Cha a in Permitted Emissions 0.3 0.3 0.0 2.4 10.6 73.8 O 0 12.6 Pubcom required based on new syn minor limits Note 1 Total VOC Facility Emissions (point and fugitive (4) Change i Total Pemrned VOC emissions (point and fugitive) 75.5 Facility is eligible for GP02 because <90 Qty Project emissions less than 25/50 Or 73.8 Note 2 Page 1 oft Printed 3/16/2017 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Synergy Resources Corporation County AIRS ID 123 Plant AIRS ID 9ECF Facility Name SRC Vista Pad Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bbl 4482 3190 178 918 35795 319 22.4 002 16WE0918 Produced water storage, 800 bbl 873 2745 1.8 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 M 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 2.7 1.6 0.1 0.5 19.3 0.0 0.2 0.0 0.0 24.5 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0917 Condensate storage, 1600bb1 22 160 9 46 1790 16 1.0 002 16WE0918 Produced water storage, 800 bbl 44 137 0.1 003 16WE0919 Loadout to tank trucks 8 13 0.0 004 16WE0920 Cat G3306NA, 145 hp 202 28 26 16 6 30 0.2 005 16WE0921 John Deere 6068HF485 diesel generator 0.0 006 16WE0922.XP Zenith 428, 2.8L ,48 hp 61 9 8 5 9 0.0 0.0 0.0 APEN-exempt and Insignificants 0.0 Fugitives 3 6 1 6 17 0.0 Separator Heaters 3 1 1 65 0.0 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.0 0.1 0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.4 2 1239ECF.xlsx 3/16/2017 Permit number: Date issued: Issued to: D© on - = trot Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE0917 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Synergy Resources Corporation SRC Vista Pad 123/9ECF NWSW Section 2 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TNK 1 - TNK 4 001 Four (4) 400 barrel fixed roof storage vessels used to store condensate. Enclosed Combustor 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 ��e•ass:?ru�r;ca Pubtci.beaib'r:5 �<u orvr;=nc Page 1 of 8 3. i al exp if e owne r operator of the source for which this permit was issued: i 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 NOX VOC CO TNK 1 - TNK 4 001 --- 2.2 66.6 10.0 Point ote: 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 TNK 1 - TNK 4 001 Enclosed Combustor VOC and HAP COLORADO Air Pollution Control Division Pub41c; ties%aEth b Err:irorir,nr Page 2of8 PROI °' Ic. S 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 4 001 Condensate throughput 518,768 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (i.e., 123/9ECF/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. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If COLORADO Air Pollution Control Division Page 3 of 8 , it m have a design destruction efficiency of at least 98% for ydro on "- -pt - - ` he c stion 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. 15. This source is subject to the New Source Performance Standards, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution, Subpart 0000a. This facility shall be subject to all provisions of this regulation, as stated in 40 C.F.R Part 60, Subparts A and 0000a. OPERATING a MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (0&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 17. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. 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 COLORADO Air Pollution Control Division hTn merti,:sf v�hivitti;'r3 ,irorgr, ,C Page 4 of 8 repo e pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 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 + E"wirnl'ii 1 ?te614c Hea tr: J'_.P Page 5 of 8 26. % :tip o :;he erm`.; .f ..ermit •,;. of the provisions of the Colorado Air Pollution Prevention nd .''` of •r t - -• r' 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance. Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. ti ;COLORADO 1 Air Pollution Control Division `:cat:r ≥nt�a `vl : ublic H itft?: >�,;•ei; tinrn_:'ic Page 6 of 8 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 (Ib/yr) Controlled Emissions (Ib/yr) 001 Benzene 71432 4,482 225 Toluene 108883 3,190 160 Ethylbenzene 100414 178 9 Xylenes 1330207 918 46 n -Hexane 110543 35,795 1,790 2,2,4- Trimethylpentane 540841 319 16 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 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx --- 0.0084 AP -42 Ch 13.5 CO --- 0.0383 AP -42 Ch 13.5 VOC 5.13 0.25650 ProMax model based on site specific pressurized liquid sample 71432 Benzene 0.00864 0.00043 108883 Toluene 0.00615 0.00031 100414 Ethylbenzene 0.000343 0.00002 1330207 Xylene 0.00177 0.00009 110543 n -Hexane 0.0690 0.00345 540841 2 2 4- Trimethylpentane 0.000615 0.00003 COLORADO Air Pollution Control Division ilean a ErIvirOnn,,nt: Page 7 of 8 s facto for this point are based on the enclosed combustor control heat `""'nt of 2361 Btu/scf, and a waste gas volume of 52.26 scf/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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division �Y:-aarsr�er;[ 7 Pubic; Page 8 of 8 Permit number: Date issued: Issued to: D tJ rol Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE0918 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Synergy Resources Corporation SRC Vista Pad 123/9ECF NWSW Section 2 T4N R68W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description PW-1, PW-2 002 Two (2) 400 barrel fixed roof storage vessels used to store produced water. Enclosed Combustor 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 _nviruryrr;_nc Page 1 of 7 3. i al exp ` tf e owne •r operator of the source for which this permit was issued: do a 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 i AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO PW-1, PW-2 002 --- --- 0.9 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled PW-1, PW-2 002 Enclosed Combustor VOC and HAP COLORADO Air Pollution Control Division `#.uaruru:-*:fE. ^<c onranx Page 2 of 7 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 PW-1, PW-2 002 Produced Water throughput 124,782 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (i.e., 123/9ECF/002) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating 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. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS COLORADO Air Pollution Control Division C:�,�arsne^z2a : ukutc Hv €:r.,J E Lei rr. i nL Page 3 of 7 14. • s g rt► = ofd his •in i the ow r or operator shall follow the most recent operating and aint- • c= ` e M) • . . d re • • ` keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • 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 (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 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. COLORADO Aix Pollution Control Division if Page 4 of 7 19. `" s € r ` s• cifi� =ly .tes th final authorization has been granted, then the remainder thi •` d ` • n• °'.: able. erwise, 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 sets 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 enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. COLORADO Air Pollution Control Division h,aarrrtir,;r PuL�t_lisua:ichls Page 5 of 7 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) 002 Benzene 71432 873 44 n -Hexane 110543 2,745 137 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 Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x --- 0.000048 CDPHE Memo CO --- 0.000123 CDPHE Memo V0C 0.262 0.01310 CDPHE Default for Weld County 71432 Benzene 0.007 0.00035 110543 n -Hexane 0.022 0.00110 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. CDPHE COLORADO Air Pollution Control Division illr,t _i PuL*".' 1'{CF;;'!': b EriYimm ,nt Page 6 of 7 ement hold a valid permit reflecting the storage tank and late• ' t . - is `- e Co 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 NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes it 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 Dep, Page 7 of 7 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 1 6WE091 9 Issuance 1 DATE ISSUED: ISSUED TO: Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the SRC Vista Pad, located in the NWSW of Section 2, Township 4N, Range 68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Hydrocarbon Liquid Loading 003 Truck loadout of condensate, for when the pipeline or lease automatic custody transfer (LACT) unit is not available. Emissions from the loadout are not controlled. 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 of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.00v/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date AIRS ID: 123/9ECF Page 1 of 7 Condensate Loadout TM Version 2012-1 Public Health and Environment Air Pollution Control Division on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall 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 5. 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 VOC Hydrocarbon Liquid Loading 003 , 2.5 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. 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. PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AIRS Point Process Parameter Annual Limit 003 Condensate Loading 51,877 BBL AIRS ID: 123/9ECF Page 2 of 7 The owner or operator shall calculate monthly process rates based on the calendar month. Public Health and Environment Air Pollution Control Division 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 7. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 8. 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) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. 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): 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 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. c. The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 11. 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 12. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 13. This source is not required to comply with any testing and sampling requirements. AIRS ID: 123/9ECF Page 3 of 7 Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 14. 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. 15. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of 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 16. 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. 17. 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 AIRS ID: 123/9ECF Page 4 of 7 Public Health and Environment Air Pollution Control Division 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. 18. 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. 19. 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. 20. 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 arel'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. 21. 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. 22. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. AIRS ID: 123/9ECF Page 5 of 7 Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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 Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 003 Benzene 71432 8 No N/A n -Hexane 110543 13 No N/A 5) The emission levels contained in this permit are based on the following emission factors: CAS Pollutant Emission Factors Uncontrolled lb/BBL loaded - Source VOC 0.0957 AP -42 71432 Benzene 0.00016 Eng. Calc. 110543 n -Hexane 0.00026 Eng. Calc. 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) = 3.44 psia, from AP -42 Table 7.1-2 @ 50 degrees F M (vapor molecular weight) = 45.42 Ib/Ib-mol, from ProMax model T (temperature of liquid loaded) = 512.67 °R, average annual local ambient temp. AIRS ID: 123/9ECF Page 6 of 7 Public Health and Environment Air Pollution Control Division The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 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: 123/9ECF Page 7 of 7 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: 16WE0920 CONSTRUCTION PERMIT Issuance 1 DATE ISSUED: ISSUED TO: Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as SRC Vista Pad, located in NWSW of Section 2 of T4N R68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description ENG-1 004 One (1) Caterpillar, Model G3306NA, Serial Number 46201287, natural gas -fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site rated at 145 horsepower. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for VRU compression. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.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 No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9ECF Page 1 of 14 Public Health and Environment Air Pollution Control Division 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type NO X VOC CO ENG-1 004 238 167 238 Point (Note: Monthly limits are based on a 31 -day month.) The owner or operator shall calculate monthly emissions based on the calendar month. AIRS ID:123/9ECF Page 2 of 14 Public Health and Environment Air Pollution Control Division Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO. VOC CO ENG-1 004 1.4 1.0 1.4 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined 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 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 ENG-01 001 Non -selective catalytic reduction (NSCR) system and air/fuel ratio controller vOC, NOx, CO PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID:123/9ECF Page 3 of 14 Process/Consumption Limits Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) ENG-1 004 Consumption of natural gas as a fuel 6.12 MMscf/yr 0.52 MMscf/month Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsiVility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (i.e., 123/9ECF/004) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVI1.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of 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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. A source initial compliance test shall be conducted on emissions point 004 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the AIRS ID:123/9ECF Page 4 of 14 Public Health and Environment Air Pollution Control Division requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Oxides of Nitrogen using EPA approved methods. Carbon Monoxide using EPA approved methods. Volatile Organic Compounds using EPA approved methods. Periodic Testing Requirements 15. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as AIRS ID:123/9ECF Page 5 of 14 Public Health and Environment Air Pollution Control Division 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. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 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 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. 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 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. 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. AIRS ID:123/9ECF Page 6 of 14 Public Health and Environment Air Pollution Control Division 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 enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. AIRS ID:123/9ECF Page 7 of 14 Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aacc-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 Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 004 Formaldehyde 50000 202 No N/A 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled Ib/MMBtu Factors — g/bhp-hr NOx 3.091 10.90 0.284 1.0 CO 3.715 13.10 0.284 1.0 VOC 0.624 2.20 0.198 0.7 50000 Formaldehyde 0.0205 0.072 0.0205 0.072 Emission factors are based on a Brake-Spec'fic Fuel Consumption Factor of 7775 Btu/hp-hr, a site -rated horsepower value of 145, and a fuel heat value of 1614 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EF Source Controlled EF Source NOx Manufacturer's Spec/EMIT EMIT Technologies — Catalyst Spec CO Manufacturer's Spec/EMIT EMIT Technologies — Catalyst Spec VOC Manufacturer's Spec/EMIT EMIT Technologies — Catalyst Spec 50000 Formaldehyde AP -42, Table 3.2-3 No Control AIRS ID:123/9ECF Page 8 of 14 Public Health and Environment Air Pollution Control Division 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.qovittn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr181a08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www. epa. qov/ttn/atw/area/arearu les. html 9) This facility is classified as follows: Applicable Requirement Status F Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: 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 Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID:123/9ECF Page 9 of 14 Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to 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 comprbssor 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. AIRS ID:123/9ECF Page 10 of 14 Public Health and Environment Air Pollution Control Division 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 https://www.colorado.gov/pacific/cdphe/alternate- operating-scenario-aos-reporting-forms. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID:123/9ECF Page 11 of 14 Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (Ib/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 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: 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. AIRS ID:123/9ECF Page 12 of 14 Public Health and Environment Air Pollution Control Division 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 NO X CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (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 AIRS ID:123/9ECF Page 13 of 14 Public Health and Environment Air Pollution Control Division 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:123/9ECF Page 14 of 14 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: 16WE0921 CONSTRUCTION PERMIT Issuance 1 DATE ISSUED: ISSUED TO: Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the SRC Vista Pad, located in the NWSW of Section 2 Township 4N, Range 68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description ENG-2 005 One (1) Make: John Deere, Model: 6068HF485, S/N: PE6068L114692, diesel -fired, reciprocating internal combustion engine, site heat input rated at 6559 BTU/hp-hr, having a site rated output at or below 286 HP, used for electricity generation. This engine is equipped with no controls. This engine is subject to NSPS IIII Tier 3 Standards. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another John Deere 6068HF485 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permittinq-notices. Failure to notify the Division of startup of the permitted source is a AIRS ID: 123/9ECF Page 1 of 12 Public Health and Environment Air Pollution Control Division 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) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 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) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type so, PM NO. VOC CO ENG-2 005 405 --- 1191 503 211 Point (Note: Monthly limits are based on a 31 -day month.) AIRS ID: 123/9ECF Page 2 of 12 Public Health and Environment Air Pollution Control Division The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type SOX PM NOX VOC CO ENG-2 005 2.4 --- 7.1 3.0 1.3 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined 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. 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 rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) ENG-2 005 Consumption of diesel gas as a fuel 119,926 gallons/year 10,186 gallons/month The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9ECF Page 3 of 12 Public Health and Environment Air Pollution Control Division During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and AIRS ID point number (i.e., 123/9ECF/005) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, 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. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. This engine is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart 1111, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE) including, but not limited to, the following: a. Owners and operators of 2007 model year and later non -emergency stationary CI ICE with a displacement of less than 30 liters per cylinder must comply with the emission standards for new CI engines in 40 CFR 60.4201 for their 2007 model year and later stationary CI ICE, as applicable. b. All fuel used shall meet the following specifications: (1) Sulfur content shall not exceed 15 ppm. (2) Have a minimum cetane index of 40 or Have a maximum aromatic compound content of 35% by volume. Compliance shall be demonstrated by maintaining copies of the fuel specifications provided by the supplier on -site or in a readily accessible location and made available to the Division for inspection upon request. c. All engines and control devices must be installed, configured, operated, and maintained according to the specifications and instructions provided by the engine manufacturer. d. If the engine is equipped with a diesel particulate filter, the filter must be installed with a backpressure monitor that notifies the owner or operator when the high backpressure limit of the engine is approached. Records shall be kept of any AIRS ID: 123/9ECF Page 4 of 12 Public Health and Environment Air Pollution Control Division corrective action taken after the backpressure monitor has notified the owner or operator that the high backpressure limit is approached. If the engine is an emergency stationary CI internal combustion engine that does not meet the standards applicable to non -emergency engines, you must install a non- resettable hour meter prior to startup of the engine per Subpart IIII §60.4209(a). 13. The following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, including but not limited to, apply: a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) OPERATING & 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. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 9 to measure opacity from this source. The opacity shall be measured and interpreted as an average of the readings taken over fifteen (15) second intervals for a total of six (6) minutes. (Reference: Regulation No. 1, Section II.A.1 & 4) ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per AIRS ID: 123/9ECF Page 5 of 12 Public Health and Environment Air Pollution Control Division 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, th6 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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of 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). 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 No. 8, Part E) 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section AIRS ID: 123/9ECF Page 6 of 12 Public Health and Environment Air Pollution Control Division 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: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. AIRS ID: 123/9ECF Page 7 of 12 Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The emission levels contained in this permit are based on the following emission factors: Point 005: Pollutant Emission Uncontrolled lb/hp-hr Factors - lb/MMBtu Emission Factor Source PM 0.000198 0.0302 Manufacturer NOx 0.005600 0.8537 Manufacturer CO 0.000992 0.1512 Manufacturer VOC 0.002361 0.36 AP -42 SOx 0.001902 0,29 AP -42 Note: Emission factors for PM, NOx, and CO are based on manufacturer's specifications for maximum load and represent the manufacturer's not -to -exceed values. Emission standards requirements per 40 CFR 60 Subpart 1111 are based on a weighted cycle average. 5) 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. 6) 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/fr18ja08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.htnnI AIRS ID: 123/9ECF Page 8 of 12 7) This facility is classified as follows: Public Health and Environment Air Pollution Control Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC NSPS 1111 Area Source Requirements: 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 NtSPS 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: 123/9ECF Page 9 of 12 Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS STATIONARY (CI) ENGINE October 1, 2011 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of Stationary (CI) 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 an 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 any all tests and the associated calculations required by this AOS shall be submitted to the Division within 60 days. 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. 2.1.1 The owner or operator may temporarily replace an existing engine that is covered by this permit with a different 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. Calculation of emissions from the temporary replacement engine shall be made as set forth in section 2.1.3. 2.1.2 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 AIRS ID: 123/9ECF Page 10 of 12 Public Health and Environment Air Pollution Control Division 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 an analysis of any new applicable requirements for the replacement engine as required by Condition 2.2. 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. 2.1.3 Compliance of the replacement engine with the applicable emission limitations of the original engine shall be monitored by one of the following methods: 1) Manufacturer certified emission factors showing compliance. 2) Stack tests of same make and model showing compliance. This would only be considered if the test was done under similar conditions to Colorado (i.e. at altitude). 3) Stack tests on the engine. 2.2 Applicable Regulations for Permanent Engine Replacements 2.2.1 NSPS for stationary compression ignition internal combustion engines: 40 CFR Part 60, Subpart 1111. A permanent replacement engine that is ordered after July 11, 2005 and manufactured after April 1, 2006 or is modified or reconstructed after July 11, 2005 is subject to the requirements of 40 CFR Part 60, Subpart 1111. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in any request for a permanent engine replacement. 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 date of manufacture for purposes of determining the applicability of NSPS 1111 requirements). 2.2.2. MACT for Stationary Reciprocating Internal Combustion Engines:40 CFR Part 63, Subpart ZZZZ. Any permanent replacement engine located at either an area or major source is subject to the requirements of 40 CFR Part 63, Subpart ZZZZ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in any request for a permanent engine replacement. AIRS ID: 123/9ECF Page 11 of 12 2.3 Additional Sources Public Health and Environment Air Pollution Control Division The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9ECF Page 12 of 12 RS O O LL V w 0) M N Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] 16WE0917 Permit Number: 0 N 0 0 0 L_ a) 0 E 0 y 3 s c 0 Q 0 a W N 0 a. TNK 1- TNK 4 Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re D z h or or z 0Li ® ❑ O t MODIFICATION to exi O CU 'O U U U z� -0 Change company name N s 0 ❑ Transfer of ownership ❑ ❑ Change process or equipment O O O vi Change permit limit N O N O 00 0 0 a 70i1 U U a>) 0. W N APEN Submittal for update only (Please note blank APEN's will not be accepted) ❑ ❑ Person To Contact: 0 u Un I- 0 N N N V] O N I❑ ❑ V) 5 ti It It El El rn -00 00 0 Q.10 01NIy .n N -O a) 0 aa) a) O U 0c a 0 • o N b0 a 417 x o Y 0, a. y o : - L) L a) o a a cn Q 0 0 a) c C s 0 a 0 C) cn vl etl ZZ00 ` U 0 ❑ ❑ U 3 O Ca U o 3 4- u 0 o E o 4, O C G y \ co `.. a) C L 0. O. .\ c,., T O 4� 7 ti \ M on M O a) U L d a [Z W CV C y� O' 01 z g rn O O` 4 eT b0 (V J rj �, M m G I. O 'O C n' 00 .<0,, N ..� COO O N G" is y Q W 0 .F U O L O "O y d C N h 4. .. $...' o � a) V V) 0, ° W kr)0. 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V] . bk O a 0 12 2 O 0 • ro R.. d d O O b "' r 0 . al ,4 C.) ♦♦ a) y w°H.°a3� L /) a) a) O O T � L L 00 00 CO 0 N C) N 00 RVP of Sales Oil External Floating Roof: Fixed Roof: N N A AP Form-APCD-205-Condensate-Tanks-APEN.doc N 0 0 z FORM APCD-205 C es t AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Stora O O LL U w 0) Emission Source AIRS ID: N- o) O W CD Permit Number: Section 06 —Stack (Source, if no combustion) Location patum & either Lat/Long or UTM) O S E CC ` 5rso N U U U LID -104.978905 E a ES —z� I N °3 ' a xz a7 8g J al 0 0. fL F ❑ 'irection of stack outlet (check one): xhaust Opening Shape & Size (check one): Combustion Device Storage Tank(s) u Make/Model a Manufacturer Gu Waste gas heat content: O 0 a d0 an 63 o z 7 .a cr U O O; U ❑ O L U iir • Elta O 9 • II] U R7 c Q 0 0 U o. o. E o Q tJ' Ct. o e C 0 L C 0 9 N .0 O T I - U u CC c o O — CO-. CC u O C rl c4 t u Q O '' Y u C O O u U v 1 0.L' IS NC N- u r 1 Make/Model: Requested VOC & HAP Control Efficiency: .0 CC C0 N cd for control of th 7 E H E&P Sites Onl Information tion Technolo CC ction 08 — Gas/Li N Vhat is the pressure of the final separator vessel prior to discharge to the storage tank(s)? Information & Emission Control Informati 8 N CC CC t es .0 C c E V I- c w CC w C. Y O Emission Factor Data Source AP -42 Pro Max AP -42 ProMax CC 0 a ProMax CC 0 a ProMax ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 00 v. 9.92 .^. O Q © o O� O N S O Oo • . O O O Uncontrolled (Tons/Year) 9.92 2.24 - - r 7; 7 '7 . N .. o R.N h .• x a O l ,A r c r :° O Actual Calendar Year Emission2 Controlled (Tons/Year) co . N O 0.07 E O h 0 .. w CO o 0 0 0 0 Uncontrolled (Tons/Year) in P LZ'8 •qr 0.38 ea d7 ,- 0 1 0 Cr: .I • • Emission Factor ,v, CC m a Z H CZ .O C Z. d L .C L Uncontrolled Basis I eh e7 a M N Q o o 'f �+ o et ann e a r c; o o OC 45 W5 — ,C 45 Pollutant VOC Benzene Ethylbenzene Xylenes u V r u 0. cc T OZ O U C LI X L E C F N L C 0 CC a L L y • d a L COI C ▪ d 09 a Era a 0 1r01 0 o a o C • O C CC u ▪ .c 8 1.1 E 3 0 V = 3 e 7 d E E a O u C is N = W r-1 e 7 go L ." F E9 td* liCtizi LL)C = G r u • ` — o C � • y Z E . o — .a V C▪ I u • 0 � V .0 • I. — o 0 a C 74 L U C Mer. Environmental and Health u I' - u g to A O 0 7 E G r V .0 C y g. L o ACCa v < S. — o z 7 a o < 0 O .D :o — n Cc m (Vj C 21`-'13 O o • n ° E O uy U L h a - n O E P., O C ° E o r < 9 S 8 V CC • C °c C. C -co G C U 0 0 Y U U N u 0 y a o. .0 4.. 0 G a J C C a 0 Ii C) U U CC 0 f.0 C t ❑ APForm-APCD-205-Condensate-Tanks-APEN.doc w O Co 0 a FORM APCD-205 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Synergy Resources Corporation Source Name: SRC Vista Pad Emissions Source AIRS ID2: 123 / 9ECF / 001 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 41058 SRC Vista D -2N -C 05 - 123 - 41057 SRC Vista 44 -2N -C /1 05 - 123 - 41056 SRC Vista 43 -2N -C e'' /1 05 -123 - 41055 SRC Vista 44 -2N -A ! .1 05 -123 — 41055 SRC Vista 43-2C k" ! ►5 1, I ❑ - - ❑ - - Y ❑ - - ❑ - - ❑ - .- - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: I 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-Addendum.docx N 0 0 LL U w m Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] 16WE0918 Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] PW-1, PW-2 Facility Equipment ID: r 0 CV C7 L z ca ca a u 0 0 u d Section 02 — Re Section 01— Administrative Information E a A A z z d I) W 0 d 0 u u E 0. Q A cat C 0 z O Q C 7 d C ;'14 ® ❑ ❑ N O �o V U Q U z� '0 3 Change company name C 0 Transfer of ownership 0 Change process or equipment E G. m U ❑ ❑ w O CO 11.7 N 0 N O O '0 O U P. N ❑ APEN Submittal for Permit Exempt/Grandfathered source C L C) C APEN Submittal for update only (Please note blank APEN's will not be accepted) 0 Person To Contact: Section 03 — General Information 0 N N N O L.: N ❑ ® ❑❑ ❑ En > y N I®❑ 4) 1.0 N C 0 7 y N 0 Y U 0 •o o. v 7 0 0 ° C C O N O c O C7 0 t. cu O O C. O En - 7) ti 7 0 X O Normal Hours of Source Operation: ti C c — V • m - O o. U G 0 C S s y Lel C• U LSD - Q a U L U P. S O 7 0 L1 > O O '_.: o ti a•O w 2 C C U L °•,,) d C O O O Y O U o ct - C o 0 0 ^o — " 0 -a - O cam•U 'D C sU. -. U cd = N @ U 707 V c C•c EO o u °? I C E ° y ea •�o,o�� U L O C > ai o� E `o t� 4. C y O oo v� N C L O. C. /� 1— . N 6. o o i:l r—rccrry� C .D O U L w CN N E row 7 W '" C N = LZ.] E> '.-. o w a u u i c O ..N.' ° E U ! M Q L' U CO N Q 1/7 V O {j 4 U'M irn " U . 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Q u .o w r, U p gz ) vw.colorado.eov/cd APEN forms: littn:// U C) 0 O O 0 Information h R Section 04 — Stora 0 -C tin OD a M O U G) C N cc S ° 0 cn C) 7 o, Produced Water OO M O cd a U 0 External Floating Roof: 0 Internal Floating Roof: Fixed Roof: O N O 0 N 0 O O O Cie N Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) Newly Reported Well ®®®-1® Name of Well SRC Vista 44-2C SRC Vista D -2C SRC Vista D -2N -A SRC Vista 43 -2N -A SRC Vista S -2N -C API Number 05 - 123 - 41063 05 -123 - 41062 05-123-41061 0 7, 00 O . 7 e.i e4 0 0 AP Form-APCD-207-ProducedWaterTank-APEN.doc FORM APCD-207 y AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Produced Water Stora N O O LL W as 1" f N Emission Source AIRS ID: CO T w W Permit Number: I- H CO C 0 .4 O O lV C 0 b r+' 0 VI 0 O N Cr: • ig 3 20 Q 0 O Y 03 E o < w C II u ❑ C▪ D C c 0 ❑ ction 07 — Control Device Information a 0, turer Guarante V� GD Q ro G 0 O C, O C 0 0 (5 w 0 .a a '- 5 o E _a � E 'E c 2 U 0 C O LL N cribe Any Other: a F- (VRU) used for control of the S Vapor Recovery U n Make/Model: n 0 0 ✓ tern used for control of C 0 a 04 Lzl Information aration Technolo ction 08 — Gas/Liquids Se a N (7) 3 -phase separators, (2) Gasbusters C ese 0 0 U 0 C m 3 C) .0 V pV G C 0 .10 a u O U 0 m V C C. C E C O C C. U C O U, E C 0 C E e C. 0 C v C C E 0 O C 0 u N N ei 0 V 0 t 0 0 0 ✓ a c 0 E C 9 • Estimation Method or Emission Factor Source < z Sec Calcs z Sec Calcs < z < z < z Sec Calcs Q z portable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) V/N 0ND C N/A N L4 ^0 N V/N V/N V/N N O V/N Uncontrolled (Tons/Year) < Z in ,a < z [ 0.44 < z < z ; N/A Actual Calendar Year Emission2 Controlled (Tons/Year) N/A oz 0 N/A N C w o N/A N/A t. , `yC z r 5.72E-02 z u 0 Cp C {. .7. C� z Z 0.36 z z .• Emission Factor Units < z�z < zzz�, < .< e V/N Please use the APCD Non -Criteria Re Uncontrolled Basis N/A C. V/N i7 C W o N V/N < z < z N o V/N Pollutant X z VOC CO Benzene C) F. V C V W C V X n -Hexane u C C, v a .0 u .E C O C- W • E L . V t. ir1 a= 0 4 m O 0, C O y co a. C O C E 0 w u C) ., V 'p0. U ✓ 3 0 .. u 0 a o V N < a ?, E E 7:0. >_ .. W ..1 m 0 V co O E • C 1 ° m C E , 0c w ; zw a 0 C C O O C - r z c I C. a E 3 < flC / _ 0 I' m r-9 C ▪ V T o ▪ `a/ V O �/jV / V C• °w i mm u • i- Q C E R t• at' m u L - • V = C 0 V E u ` ` i-^E m z c '•••• (I a V .. >, < E V O d` V L IL 0 V ] V V U ri. 0zm - ° Do' C =4D O - �- a 3 u A m aC .�'j s ._ c u elf. O n < .fl1 \/ 0. • c Ia C C 0 E "" u e o c c a 0 >.. < dei e 8. u U C C 0 C .GF CG 0 0 a 0 U C e 0 L) AP Form-APCD-2O7-ProducedWatcrTank-APEN.doc N 0 N V CO A FORM APCD-207 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Synergy Resources Corporation Source Name: SRC Vista Pad Emissions Source AIRS ID2: 123 / 9ECF / 002 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 41058 SRC Vista D -2N -C 'iI 05 - 123 - 41057 SRC Vista 44 -2N -C ►�� 05 - 123 - 41056 SRC Vista 43 -2N -C r, d; ail 05 - 123 - 41055 SRC Vista 44 -2N -A r' , ` A 05 - 123 — 41055 SRC Vista 43-2C t 3 - - t; ❑ - - 6' Y r,p ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - - ❑ Footnotes: I 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-Addendum.docx uid Loadin M N # & AIRS ID] C ro C) 00 C) C) C) C, C) C) C) 16WE0919 Permit Number: renced within your organization.] [Provide Facility Equipment ID to identify how this equipment is r Hydrocarbon Liquid Loading Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information General Permit GP07 Individual Permit Action Applies To: C 0 0 2- 0 U 0 0 23 a) T a) C Company Name: C u L L V C 0 u u V L "V C O C o C7 L U CU C L C C C) C Z h r u u C 7 Q, LY = a 0❑❑ ❑ ❑ ❑❑ Change company name O 0 Transfer of ownership 00 ip' G U U Q U 'NV C c C C) C 0 u a O .0 7 C) u .0 d c e C z O U O 2 U) C C' N O U 1625 Broadway, 3rd Floor Mailing Address: C) C. O O O C!7 O O a) C a) O z 6. C U c o0. C U O O � c U � a C) C V � no O E u I U u O `C)7 C . O U c. < 7 = .. _ C c .gzt LV V ee to N 0 N 0 eb Person To Contact: Jerry Brian E 0 O c 0) T C Ca C) CCL7 T C O N a) N 0 2- 0. U C a) m C C O a) U) C 0 C 0 a Ca 0 0 C N a) Ca N a) Ca U) C a) C O U O a) C C C U 5 Addl. Info. & Notes: ti N U) U 3 N C) .0 Section 03 — General Information r - C) 0 N Normal Hours of Source Operation: 0 N N- N a; 0. C3 v U 0' C).. O Cd 00 .0 ro a 0 C) 0 Don't know Don't know Don't know O O 0 O OO 0. a) E O @ a) T La-.) d >+ t` N 0 E C E X to E CC 0 a N a) C U 0 0 0 0 U C U a) co C O U Don't know < < < V) C) C) C) U) U U U C) U >- >- >- ❑ ❑ 111 ❑ C) a ro .b 0 0 J m co ti N (C a 000 u 0 C) C O .D O ,y ro o s 7 CZ, COV"I d C. G 7 r E z O U Q M M M C CL) OU y N N N O G - L CT CT C, _ Q ^ fl. 0. v vJ ., > Q 'D U Y C M M M C N .- _ O C O O O N L-1 V 'n r P O ��.,.�,M.. 0 G> cs °J eV L c3 C )`_' E w C O - 01 O L .O .. p _. C . 7 —jz, . N b0 O °� Li.) 0-. C- N 1:21 `y_. V y ) m N U L77�{i u C N •.- n . u b0 u .D L' 3 N . V L i = E "D U o ro r .. y i> a. g n 4. 0 ,1 O •5, C E ^� C t co 9 O O o U c. d° � a. O O N d •0 ≥ 7 e c i s °> U -7) -7) y `0 0 8 o r C c a) C C o 0 0 c 'q, a n E o 0 v L cd U L! l et L L N ,- C 't1.< S N 4.. `E O C.44U U >, N r U y L, L. O 0F� 5c.. L Q d L O Ur O .^ _ L cui r ?''y 4� C^ U F.;.° y �!' r ro C _ O N O O O `/� L -7 - m CE C) V p� `['' . O CC 00C) O O- z - 42 'C. U4s:'CC) ‘r, O a. OM u - `L- �'- - 4) O O 0 C U ❑ Condensate Product Loaded: .C lume Loaded: Tank Trucks Ci 00 O to M U c O V N O a U 4�. u C > C z C .C r C V C C i 0 .. C O LZ.E u V V u 'C u CZ O 'C c C CC O C. CU 000 i O O 0 U Li C) C C) O 'C Q N Cn True Vapor Pressure: J 0 C U I 'O 40. C E O u C O C >- C O CY N a) a7 U y R - a, L U L h O 0 c 0 .9 w 00 C L z W • Ft3/truckload X U i C= 'O ac N c eP C C) O N a • 0 0 J FORM APCD-208 CC o 7 z C) C 00 C C) 'C C) O C) '2! 00 N N 0 U 0. v N w O 00 1f V M uid Loadin C') 0 0 Permit Number: 2 L e: C U) a E C Q 0 0 3 Vl E O O e CJ L 0 O .) u O 0 0 u rn °cam . U 0 C7 0 0 E 'C r7 V E N it O -104.978905 en co 0 z E z e o. V C .F6 C 2 'a V C 8 _ V c G a) on xhaust Opening Shape & Size (check on ction 07 — Control Device Information Describe Any Other (Including VRU) V c V z VOC & HAP Control Efficiency: Loading occurs using a vapor balance system. Combustion Device used for control of the loadout emissions. n n Make/Model/Serial t4: Manufacturer Gu VOC & HAP Control Efficiency: 2 Eo 2 ction 08 — Emissions Inventory Information E L a '0 O e a C a O 0 O a E a C7 L V c C L V 7 Q' a L u U) C E W u U) U) J 0 0 C u U CO CO J C- N C 0 O Condensate a CC a c 0 0 u u u 07 co O C O J' O fl 1- O N Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007): Emission Factor Documentation attached (If using site specific emission factor) n 0 0 E Actual Calendar Year Emissions5 Z 0 U 'a) ) VJ Z en 0 To 0 a) �a) V/ en 0 0 W^C^), ll^ V/ Z co cV Z M O w CO C'-) 9 w ti (D z co N z €d C� O W OD O • W_ N (D z r` O N < CZ !;) K. 1tl 4� t 0 W C) M CC) 9 W Q) tf') U) z S` O N E, Z 9 W Q) C') O w Q) U) Emission Factor Z a CO a J Z J CD .0 Uncontrolled Basis Q z 0 w 0 W 0) lf7 N Control Device Description C O 8 En 0. V .0 C) C c C C «a L C 4 C E 3 c 'O C U) C 0. a V a 4 CC Var 0 C C 0 a d C ae a C 4 C c a C z O 0 C V N tb c CC c C U) L rb C- u 0 u 4 m 0 u c.;i y^^ E ti' E o. O W U L c u c o0 c 0 c 0 a-0 m c h C Manager Environmental and Health H C •a a) CC Cl 0. c O v 0. C) t u N Z a O .. u .L c v T E o 33 a ,. c c E c 0 SO C. m e _ 03 � Cz L g 02 C01 C 'O E 'O2. c to e el 1. c V ) a p r a. L u 1/ .. e 9 -f E C E .y 'J O y .. O i 1 a C E o a ■ t G .E 17, a I-1 S o r W c L. 3...V .L I- L V 6 u L w d + V L 7,E a ..? z : 0. f-' .. < e '^ = p. I; C ^ V L O - a%- c �' E'z4 to w p C u =�T '•a o� a t Ts m e y(1., u C! L _ u M � c W a` E L 1 E ` re e e c O } G I .. d C I.V `l : L u O O Ic FormAPCD-208-HydrocerbonLiquidLoadingAPEN-Ver.4-I4-2014 ( I ).docx N 0 N u oq Internal Combustion En M CV Emission Source AIRS ID: a to 16WE0920 E z E G O N a) on a) O E 9 C E C- ti 0 O E R W a) w m v 6 z w Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01— Administrative Information Request for NEW permit or newly reported emission source 10 O N O -OO V U z� a) C. C. ea ea d C O L s a Z E G •x O z O FN 0 d 7 a County: Weld Change company name Change fuel or equipment N 0 Transfer of ownership Change permit limit w Portable Source 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: C E d U W c d L C c E u a 0 O C O 7 O z Section 03 — General Information For new or reconstructed sources, the projected startup date is: 05 For existing sources, operation began on: LU O 3 o m C) C w > `o cn col a) n E O U N i Normal hours of source operation: General description of equipment purpose: O 0 O,..., ` E O ,o a_ z �� E W U QV M t•'1 c-,-, ti C o L _ .O N d L 'C \O 'C 0 A C a c E ,o 9pV > 0 a; oo g ooen o� C Q u5, w a •> E .. W a •C .E '" ° C O C R E 5 on L OC4z y> 7 co a w W Q •O x �y U N d v 2° c -w�3� -= Ili' E a °� E s V. O ' `o O : ._ bp o U v ' s Et' 0 c o O L V] L .E 0> L 3 . Gs i p 8O •J d E = w L .�C] L •D L -O O C C L C d i =1.4 . _v1'; ~ 3 O= y O O ca a, rr 4 = ',L' eo-67' 40 �w E u 5, U2 o U¢ c.L. N o o ,° d a.= t.,. c°i o ,c 0 w��s3 t -0 U 0 • _ V O Rya.Y� U d .. = = b!V C C m nO" 7, Ha0i'`_-- v3C�.Q•"aA w0 QcA p re APEN forms: htto://www.colorado. C) Application status: int Date the engine was ordered: Date the engine was relocated into Colorado: = O o -g O z C) Ca C E C a) c O C za g c a� — t7 'O O .0 o CC) E CL J U Q• 3 73. ine Information Section 04 - En Engine displacement: Engine date of manufacture: z co O r� M 0 •aa 0 671 a a) co O Manufacturer: C) 3 o ❑ R R a C) ..O 0 c. oo cat 0 y E ❑ ❑ C O C v E b1 C O O CD v Manufacturer's maximum rated horsepower @ sea level: Manufacturer's maximum site rating: C a Z 70 j C C a z ❑ E Combustion: c O a) a v 0 C U a) V R OO O O O. O. a 10 O O T. O O y N O O 0 .D . U U U U C -o O C a) ' Cuco O O� U 0 E E C O U cn a .1 N Cn a w w O U a R VD iii L U O. U H O C C,2 ..- W U b OD O What is the maximum number of hours this engine is used for emergency back—up powe Form APCD-201-RICEAPEN-Ver.02.10.2014.docx FORM APCD-201 Internal Combustion En O O 11 U W C) CC co N L r AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Reci Emission Source AIRS ID: Permit Number: 16WE0920 the event of multiple stacks; provide datum & either Lat/Long or UTM) ction 05 — Stack Information (Attach a separate sheet with relevant information E 5 �Q 0 U O O O O CO OD OD O -104.978905 E O0c C 00 re. oD O Z C v w 41 o a � < F�F O 0 0 ui :> Z C) C C) U U •C v 0 )irection of stack outlet (check one): Inner Diameter (inches) _ ction 06 — Fuel Consumption Information C) CO Seasonal Fuel Use (% of Annual Use) O C//)) Ln N DD 7 CD CO i S N C) Q N O 1,614 Btu/SCF Requested Permit Limit 6.12 MMscf/yr C) CI — a 67 ol �U 6.12 MMSCF/yr 698.50 SCF/hr C z Estimation Method or Emission Factor Source AP -42 N a d AP -42 N a d Manufacturer Manufacturer Manufacturer AP -42 N a a AP -42 AP -42 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) I 0 W a0 in C) 9 W Q) CD Q 9 W a) CO V 9 W O 0 N co v, co C) O O ' O O 9 W aD PI 9 W 0 M — 9 W 0 CD 1.: IUncontrolled I (Tons/Year) ON w Co 10 O w Q) c0 NI 9 W co O 9O w O T U) N co O c- ) c') as a 0C ..-1). O 'w C N 0 W O c.) CO W O OD Actual Calendar Year Emissions2 Controlled (Tons/Year) N 9 owwww c 0 Oi N 0 rn 1a c N 0 m CD Q CO 9 o 0 N 11.40 m a) O o v r• k3 L i o CJ .1N 10 ;coo C) 1— N o o (n .— C•) 9 0 m I• Uncontrolled (Tons/Year) N O W 100 O N O W CD R N O W CD ? n) O W 0 N 0 N u7 O fh co C) CO 0 0 O N O W M ,— N O W 0 — M O W 0 co f` Emission Factor Units 2 co co lb/MMBtu 2 g/hp-hr lb/MMBtu [Ib/MMBtu co Uncontrolled Basis N w Cr)r r OD 0 w 0 10 (D OD 0 w 0 1 0 CD O 0 w co CD t!•) 0 O O N N o N 0 w O N C') 0 es 0) N C') 0 LL1 CO Ni C`) 0 W 100 .- Control Efficiency (% Reduction) 4( Z N/A d Z Q Z o a) •0 0 cc),., o Q Z d Z d Z V/N Control Device Description CO cs a O v v V/N V/N V/N V/N a Z d Z V/N V/N V/N � d Z Z Primary I d ZZZZ Q d d Catalyst T co O CO co `m O d Z N/A d Z V/N Pollutant TSP 2 a 2 a > 0 x 0 z VOC CO w -o L w t o w T u 75 Y C 0 o t. -.)- Benzene o•E I- m c 0 CCD CO C+ C to c.)" S C_ ... DVp U 6. a0 0 U •r .. 'D c CD O • CO CD 1 t L �> d V t= C C J CDC. z -D — m 0. o V ` •C i V u 'CD i a o E C Z CO o ta. C 00 c e , .) age _ C w E " n cQ r c ' .CO CJ _ E t m O CO O N p CD C. C) 1n a CD O w CJ b N CD O CO DD C) 4. O F CC z O O S O 00 U O Form APCD-20 1 -RICEAPEN-Vcr.O2.1O.2O 14.docx N w O (N OA G Internal Combustion En 0 0 LL O LL 0) r Permit Number: C) Cl Pip 0 0 i 0 saa 0 C) o. 0 0 -o 0 • CID 0 az V 0 u Facility Equipment ID: uested Action (check applicable request boxes) Section 02 — Re Section 01 — Administrative Information New Source: Company Name: Synergy Resources Corporation r O a > C) 0 on ro Cl O 2. E E C C L O u c y = L L cu i u R OD0 •0 R bD C L ` 5 U 0 O 0 R U 0 D o o O to to =CO = CIO Source Name: SRC Vista pad NWSW Sec. 2 T4N R68W Source Location: .O a) C) U U O O 0 Portable Source (may only stay at one site for <2 years) 111 tationary Source u C) 0 O O LO 0 U C) 0 Cr) 1625 Broadway, 3rd Floor Mailing Address: ation of Permit 0 O a) a) O L = C C C z O (720) 616-4301 Fax Number: Phone Number: c 0 0. O C) 4! a u E R C .J y Z E a. C) o CC = v LE jbrian@syrginfo.com E-mail Address: z u Q D C) c C) O .a G CC E 0 c V c R O C O R U 4 t -E z;E Section 03 -General Information O a) C a) 0) U U a) W General Description of Operation: 9 w C) C C L:] 0 CC CC u En oEn H 0 U O O r bD cC7 o�-- ''� Cl Er M C E '- 'n M M C U c3 z co:"U U X N C N 0 O U C V. 0 C r 0 4 '•= a- C) Cl u^ U_V . E o r, a _ Cl N -0 - a rM-. O O C:7 o _O" V et _N O U M M M = bD C 0. IL L ... 0 ,0 za -0 c •E ° a 0' U N 44. _ C a o r .� o z = C CID C0 LI re i C > ti 0 « 70- O W 0 i U u 0 •+- a7 z �y O C . o O C F. cCS _ _o 0 0 t _ v 7 = o d ' 4 .0 Et Q "> .0 I R U o p Urs C oo u V Q U V --ClUyt‘o,' 0 .1 O Ck d V 74 2'3•� '� C O 6 T p +�-+ y �' L O U. C U ai _ 8 2) 0 (� o ' oD ' a a 0 .o b�D.f o c, o u `o L E l 0. 3 C to O O O C 0 0. P. C C) Cl LI co U N C bnL E wGo nw • 0 O O Cl O_ L bu 'IL v w n0 0 C� o m c 0 o ro E w bD w z To 0 O Make (for AOS, permitted (old) engine): Displacement: C. a) a) a) O C L 0 co co N v az z az Maximum Design Horsepower Rating: 0. Site -Rated Horsepower Rating (optional): O co a o u, Z U C R � O o = R o = • o U R t_oa_ Cl. U R 1. c a —80 R. Z 0.i Q c o 0 R C, w_ E 0 E w L zw w� c`•4Gla �v *Date of First Location into Colorado: r" - CV 0 *Date Engine Start Operating: APEN- Diesel Engine -1 FORM APCD-213 Internal Combustion En V Emission Source AIRS ID: ction 05 — Stack Information (Attach a separate sheet with relevant information in the event of multiple stacks; provide datum & either Lat/Long or UTM) O V F o 0 N -104.978905 CO N D N- of lL Fu- ' N ao Ez O�U N 6 z Other (Describe) ❑ D Data Year (e.g. 2013) : ction 06 — Fuel Data and Throughput Information Diesel Fuel Heat Value (Btu/gal) 137030 btu/gal a C O O .O C V C O 0 IL! 172 T V C I c < 4 119,926 gal/yr C A 119,926 gal/yr ction 07 — Emissions Inventory Information r documenta U C 00 a V O roughput information suppl C u n .c C O C U n C P E L 0 O 0 m O O E (Mfg, AP -42, etc Manufacturer C) 7 U CO 7 C C6 2 N T C Y N O L / N O LC) N O CO CO (Ni O ti co N C O w V ea a t La N O LU N LU O O C fission Factors O a C a C Q c. L a C) .C L_ c) 7 n � .n C. L_ O) C 2 O lE C) O C) O O C) O O Lo Lo N C z co C,) O U 0 C O C, C O ._ al APEN fee if APEN is filled a 7, L = CO m V V W .O O in U V. Q T C O r. u E E O U C Q C re C 0 O Q C. A a O T 0- 0 C U CC O L C U an .c C G O •- U "O CC) ea a- d.) a) � C. o G 0 tr= 10 a O cC 7.7 O � S v C. 0 O C' 0"0 C co a co ` a m w C a' u C) C a�z t G � C U C L n J 4) L U O ction 08 —A c C C) a U APEN- Diesel Engine -11. N C- 0 N O1 P. FORM APCD-213 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado New Source Performance Standards (NSPS) - 40 CFR Part 60, Subpart IIII Applicability Air Pollutant Emission Notice (APEN) Addendum Form for Diesel Engines Company Name: Synergy Resources Corporation Engine Information' Make: John Deere Model: 6068HF485 Date of Engine Manufacture: 7/16/2012 a• a, st : PE6068L114692 2. Has this engine operated outside of the state of Colorado? P? ❑ Yes El No a 3. If you answered "Yes" to question 2, please answer the following question. (If you answered "No" to question 2, please leave this field blank.) What is the date of first entry into Colorado? tbd 4. This engine was manufactured to meet the following tier level standards' (e.g., Tier 1. Tier 21: Tier 3 Permit : 16WE0921 AIRS ID : 123 , 9ECF 005 A copy of this form, along with appropriate supporting documentation`, shall be maintained on -site or at a local field office, with stationary source responsibility, with a copy of the construction permit, exemption letter or general permit approval letter issued by the Colorado Air Pollution Control Division (the Division) for this emissions source. These records may be kept in either electronic or hard copy format provided that they can be promptly supplied to the Division or agents thereof upon request. This engine shall comply with the New Source Performance Standards (NSPS) requirements of Colorado. Air Quality Control Commission Regulation No. 6. Part A, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines ICI ICE) including, but not limited to, the following: [The requirements below reflect the rule language of 40 CFR Part 60 Subpart 1111 published in the Federal Register on 01/30/2013. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60, Subpart IIII.; All fuel used shall meet the following specifications: A. Sulfur content shall not exceed 15 ppm B. Have a minimum cetane index of 40 or have a maximum aromatic compound content of 35 by volume C. Compliance shall be demonstrated by maintaining copies of the fuel specifications provided by the supplier on -site or in a readily accessible location and made available to the Division for inspection upon request. II. The engine and control devices must be installed, configured. operated and maintained according to the specifications and instructions provided by the engine manufacturer. If the engine is equipped with a diesel particulate filter, the filter must be installed with a backpressure monitor that notifies the owner or operator when the high backpressure limit of the engine is approached. Records shall be kept of any corrective action taken after the backpressure monitor has notified the owner or operator that the high backpressure limit is approached. IV. If the engine is used for emergency purposes, a non-resettable hour meter must be installed prior to start-up. V. If the diesel fuel -fired engine referenced herein avoids tier 4 or 4i requirements by being an emergency generatorthe engine shall not be used for any purpose except emergency power generation and for the purpose of maintenance 4300 Cherry Creek Drive S.. Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov'cdphe I John W. Hickenlooper, Governor Larry Wolk. MD, MSPH, Executive Director and Chief Medical Officer FORM APCD-214 Page 1 of 2 Version 2015-06-15 checks and readiness testing, provided that the tests are recommended by Federal, State ei local geremment, the manufacturer. the vendor or the .su;c.,;e company associated veth the engine Maintcnance checr,s. and readiness testing of s=uch units is limlted.to '00 hours per year There is no time limit on the use of emergent' Aatiooary ICE in emergency situations. The owner or operator may petition the Administrator for approval of additional hours to be used Mnr maintenenee cheep-= and readiness t_sti:ig, but a peliticn is not rep,.,'red if the owner or onee-Sic mainta;,ns records indicating that Federal, State; Cr local standards require maintenance and testing of emerge) .:y ICE beyond 133 hours per year. Emergency stationary ICE may operate up to 50 hours per year in non -emergent situations, but those 50 hours are counted towards the 100 hours per year provided for maintenance and testing. Ti s 50 hours per year far non -emergency situations cannot be used for peak shaving or to generate income for a facia' y to supply power to an electric grid or otherwise supply non -emergency power as part of a financial arrangement with another entity. For owners and operators of emergency engines, any operation other than emergency operation, maintenance and testing, and operation in non -emergency situations for 50 hours per year. ES permitted in this secti_r. is prohibited_ Emission Standards: A The engine referenced herein shah meet at, the emissions standards applicable to the cry b re. E Compliance with the NSPS Subpart 1fl1 Emissions Standards far Non -Methane Hydrocartpons (JN,HC,. Nitrogen Oxides (NOr), Carbon Monoxide (CO) and Particulate Matter (PM) shall be demon ttrat 'l by filing a copy c` the unit's certification documentatio" of compliance with the NSPS Subpart 114( emissirat standards, with the associated application. t y, Vii. The following requirements of Regulation No. 6, Fart A, Subpart A, General Pros^lions, shall apple' A. At all times, including periods of start-up, shutdown, and malfunction, the engine an4iicistiol equipment shall, to the extent practicable, be maintained and operated in a manner consistent rt46, coed air pollution control practices for minimizing emissions. Determination of whether or not acceptable r4era tng and maintenance procedures are being used will be based on information available to the"Cdvis'on, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. Gen*T* Provisions from 40 CFR 60.11) E. No article, machine, equipment or process shall be used to conceal an emission which word otherwise constitute a violation of an applicable standard. Such concealment includes, but is not lim ted to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. iS 60.121 C. Written notification of construction and initial startup dates shall be submitted to the Dian, ion as required under 5 60.7. D. Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. VIII. This engine meets all the requirements in New Source Performance Standard (NSPS) Subpart Ill) as applicable to the specific engine, including the standards required for relocating into Colorado as set forth in Regulation No. t, Part B, Section I.C. I hereby certify that all information contained herein is complete. true and correct. I certify that this source is and v: ' be operated in full compliance with the applicable tier standards of Colorado Air Quality Control Commission Regulation Nz. 6, Part A, Subpart'III, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE) as -i'll as all other requirements referenced herein. Jerry Brian Manager of Environmental and Health Name of Legally Authorized Person (Please Print) Title Signature of Legally Authorized Person Date i it the eorere r.at not trees selected a- o'de-es as a` the dale n submission c' the co -at o,Ur per a,. ,. _ ohs fo-re rue t be ce^pie.e`` an" 5,1t,rf-, Colorado 4i' Poe -adore control Division fora a'fe_ted envIne vei:hr one hut died a.-" e eha f f85; Seas arse' the cornmenremerd of conZ.' uruonioper a'.t 'This information car. be obtained f' an the eo,ne manufacturer Fleas= enter this informa'ior ,r this for.is heist_ subrnrteC ef,c .he Cato c. submss.,, a the .. a .,' re < , -a- and e pe'rrot numbe' ae- i r5 IC -,sre,her have been asstge ,O. Otherwise. leave u,ese t,elos titan,, 4 5_ppo.t;ns do urrenta.ior teetude,..�_..-cn's p'e,i, g the .,., w o; first r yiene ' 1 : tae (Du -chase ,ecant, o_Oenrt rr er•r. en iend ;In! s:an__. - 'l'OvUer, inl'rrnatior from the manuiaeturer. s applica.b.e. I P(PM AP('Th-21d Hello