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Home My WebLink About20161321.tiff A CDPHE Air Pollution Control Division CO 1 Notice of a Proposed Project or Activity Warranting Public , iNt Comment RECEIVED Website Title: Synergy Resources Corporation - SRC Cannon Pad - Weld County APR 1 1 2016 Notice Period Begins: April 6, 2016 WELD COUNTY COMMISSIONERS 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 Cannon Pad Oil and Gas - Well Production Facility SESE SEC 16 T4N R68W Weld County The proposed project or activity is as follows: Applicant proposes to construct and operate new well production facility and all associated equipment The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 15WE1407 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 2016-1321 • , LPL_ /��, �fL '1+1/5' ItiV � . Division Information Engineer: Christopher Kester Control Engineer: Stefanie Rucker Review Date: 02/04/2016 Application Date: 10/14/2016 Facility Identifiers Permit No. 15WE1407 Potentially located in ozone nonattainment area County# 123 (Weld AIRs Facility# 9E2E Facility Type: exploration and production facility O Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: i✓ VOC E NOx I— CO Administrative Information Company Name: Synergy Resources Corporation Source Name: SRC Cannon Pad Source Location: SESE SEC 16 T4N R68W SIC: 1311 Address 1: Synergy Resources Corporation Mailing Address 2: 20203 Highway 60 Address ty,State Zip: Platteville, CO Name: Jerry Brian Person To Phone: 970-737-1045 Contact Fax: Email: rsandquistPsyrginfo.com 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W,Weld County, Colorado. Point Name Type Control Action Newly 003 Combustors Separator Venting Flare reported source Four enclosed combustors to control the emissions from the condensate storage tanks and produced water 003 storage tanks at this facility. Calculations Condensate Storage Tanks Values Source 37.87 Mscfd E&P Tanks simulation based on pressurized liquid sample from 2109 Btu/scf this facility with throughput of 819,352 bbl/yr Produced Water Storage Tanks Values Source 89172 bbl/yr PTE Throughput=(1.2*Actual) 244.31 bbl/day 3.2 scf/bbl Flash liberation analysis 1123.87 Btu/scf 0.78 Mscfd Conversion Throughput(Q) 14.11 MMscf/yr 38.65 Mscfd Gas Heating Value 2089.07 Btu/scf Throughput 29472.45 MMBtu/yr Overall Control 0.00% Combustion emission factor source: AP-42:Chapter 13.5 0.068 lIb NOX/MMBtu 0.31 lb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Nox 0.068 Ib/MMBTU 0.07 Ib/MMBTU 1.00 tpy 1.00 tpy CO 0.31 Ib/MMBTU 0.31 Ib/MMBTU 4.57 tpy 4.57 tpy 15WE1407.CP1.xlsm STATE OF COLORADO of •coto •LO- • '• ID • -T •F P C HEALTH AND ENVIRONMENT „,a�' � s��, AIR POLLUTION CONTROL DIVISION ''T' TELEPHONE: (303)692-3150 4 * *1876* CONSTRUCTION PERMIT PERMIT NO: 1 5WE1407 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 exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Five enclosed combustors to control the emissions from the Combustors 003 condensate storage tanks and produced water storage tanks at this facility. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 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 AIRS ID: 123/9E2E Page 1 of 8 olor. Depa en P .li 'Health and Environment it Pollution Control Division a a within 18 mon - eit- h if i , . ��<:'f this:- ', truction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type X Combustors 003 1.0 --- 4.6 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 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID: 123/9E2E Page 2 of 8 R I) olor._ a Depa ens •Ii Health and Environment ,F it Pollution Control Division Process/Con- .n Facility AIRS Equipment Point Process Parameter Annual Limit ID Combustors 003 Condensate Throughput 819,352 bbl/yr Produced Water Throughput 89,172 bbl/yr 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 8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 9. 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. 10. This source is subject to the odor requirements of Regulation No. 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 XVI1.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, 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. AIRS ID: 123/9E2E Page 3 of 8 Ill oiorl Depa g en P 'II Health and Environment A it Pollution Control Division 13. The storage t. - ar - t ', ,., y t- -E stors - .re covered by this permit are 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. OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to 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 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 XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. There are no requirements under this section. ADDITIONAL REQUIREMENTS 17. 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 lastAPEN submitted; or AIRS ID: 123/9E2E Page 4 of 8 1� olor- Depa en P .li Health and Environment •it Pollution Control Division Fora _ it:- - • 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. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) 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 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This AIRS ID: 123/9E2E Page 5 of 8 olor_ Depa ens ' P .Ii Health and Environment it Pollution Control Division permit may bz. _, : a ti -r t. 'ficati. • 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation AIRS ID: 123/9E2E Page 6 of 8 II olor. Depa en . P .li Health and Environment it Pollution Control Division dy � T Notes to Permit Holder - , - me o '" .e` an 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paqename=CBONWrapper 4) The emission levels contained in this permit are based on the following emission factors: 5) Point 003: Weight Emission Pollutant Fraction of Factors Source Gas(%) Uncontrolled NOx --- 0.068 Ib/MMBtu AP-42 CO --- 0.31 Ib/MMBtu AP-42 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC 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 AIRS ID: 123/9E2E Page 7 of 8 olor. , Depa en P .li Health and Environment � it Pollution Control Division m NSPS 60.1-E SL KK 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: 123/9E2E Page 8 of 8 Division Information Engineer: Christopher Kester Control Engineer: Stefanie Rucker Review Date: 02/04/2016 Application Date: 10/14/2016 Facility Identifiers Permit No. 15WE1410 Potentially located in ozone nonattainment area County# 123 !Weld AIRS Facility# 9E2E Facility Type: exploration and production facility El Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: l VOC r NOx I- CO Administrative Information Company Name: Synergy Resources Corporation Source Name: SRC Cannon Pad Source Location: SESE SEC 16 T4N R68W SIC: 1311 Address 1: Synergy Resources Corporation Mailing Address 2: 20203 Highway 60 Address ty,State Zip: Platteville, CO Name: Jerry Brian Person To Phone: 970-737-1045 Contact Fax: Email: rsandquist@svrginfo.com 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W,Weld County, Colorado. Point Name Type Control Action Catalytic Newly 005 RICE ENG-2 Engine Reducer reported source One(1)Caterpillar G3306,SN:G6X03698,natural gas-fired,naturally aspirated,4SRB reciprocating internal combustion engine,site rated at 145 horsepower at 1800 RPM.This engine shall be equipped with an NSCR and air-fuel ratio control.This emission unit is used as a compression engine. 005 Engine Information Engine date of m 10/30/2007 Manufacturer:Caterpillar Model Number:G3306 Serial Number:G6X03698 RPM: 1800 Site-rated RPM: 1800 Engine Function Compression Mfg's Max.Rated Horsepower @ sea level 145 berating Horsepower used for calcuations: 145 BSCF @ 100%Load(btu/hp-hr):7471 Site-Rated BSCF @ 100%load(btu/hp-hr): 7471 • Other Engine Type 4SRB Parameters Aspiration naturally aspirated Max hrs/yr of Operation) 8760 Calculations Fuel Use Rate @ 100%Load 928.2733505 scf/hr ACTUAL Annual Fuel Consumption 8.132 MMscf/yr MAX PV I tN I iAL Annual t-uel Consumption 8.132 MMscf/yr REQUESTED Annual Fuel Consumption 8.132 MMscf/yr Fuel Heating Value 1167 btu/scf • Emission Control Information This engine shall be equipped with an oxidation catalyst and air-fuel ratio control Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 10.900 g/hp-hr 0.500 g/hp-hr 15.23 tpy 0.70 tpy Manufacturer CO 13.100 g/hp-hr 0.500 g/hp-hr 18.30 tpy 0.70 tpy Manufacturer VOC 2.200 g/hp-hr 0.500 g/hp-hr 3.07 tpy 0.70 tpy Manufacturer Formaldehyde 0.0205 lb/MMBTU 0.021 _ Ib/MMBTU 195 lb/yr 195 lb/yr Manufacturer Acetaldehyde 0.00279 Ib/MMBTU_ 0.003 Ib/MMBTU 26 lb/yr 26 lb/yr AP-42 Acrolein 0.00263 Ib/MMBTU 0.003 Ib/MMBTU _ 25 lb/yr 25 lb/yr AP-42 Benzene 0.00158 Ib/MMBTU 0.002 Ib/MMBTU 15 lb/yr 15 lb/yr AP-42 Regulatory Requirements Ambient Air Imps Source is not required to model based on Division Guidelines Public Comment Public Comment Required for this permit application. MACT 7777 Facility is an area source of HAPs,so engine is not subject to major source requirements.Engine is new Reg 7 XVII.E.2 Standards(g/hp-The engine is not subject to Reg 7 emission standards because it is subject to standards under NSPS JJJJ hr) Reg 7 XVII.E.3 The engine is not subject to Reg 7 XVII.E.3 because the engine is rated less than 500 hp Reg 7 XVI.B The engine is located in the NAA but is less than 500 hp and is not subject to Reg 7 XVI.B MACT 7777(area Is this engine subject to MACT 7777 area source requirements? Yes source) NSPS JJJJ Is this engine subject to NSPS JJJJ? I Yes Note:JJJJ requiiements are not currently included as permit conditions because the reg has not been 15WE1410.CPl.xlsm IF A STATE OF COLORADO ov•solo •LO- .• D ' -T' ,, •F P C HEALTH AND ENVIRONMENT 4w AIR POLLUTION CONTROL DIVISION - TELEPHONE: (303) 692-3150 *4r * *1876 s CONSTRUCTION PERMIT PERMIT NO: 15WE1410 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 exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1) Caterpillar G3306, SN: G6X03698, natural gas-fired, RICE ENG- naturally aspirated, 4SRB reciprocating internal combustion 2 005 engine, site rated at 145 horsepower at 1800 RPM. This engine shall be equipped with an NSCR and air-fuel ratio control. This emission unit is used as a compression engine. Point 005: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another <<Make, Model>> 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 after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9E2E Page 1 of 13 . , alolor- Depa en P ''•li Health and Environment 0 it Pollution Control Division 2. Within one hu- d _ .9 .. • __ . :0) men - - t of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type X RICE ENG-2 005 0.7 0.7 0.7 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. AIRS ID: 123/9E2E Page 2 of 13 olor.iDepa en : P Health and Environment it Pollution Control Division 7. The emission .- th -. e ated aintained 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 AIRS Pollutants Equipment Point Control Device Controlled ID RICE ENG- 005 Non-Selective Catalytic Reducer NOx 2 PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID RICE ENG- 005 Consumption of natural gas as a fuel 8.13 MMscf/yr 2 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 (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 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 XVI1.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) OPERATING & MAINTENANCE REQUIREMENTS 12. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) AIRS ID: 123/9E2E Page 3 of 13 ^ Il r\ olor- Depa en P li Health and Environment •it Pollution Control Division COMPLIANCE TE 3 ..II , - N r Initial Testing Requirements 13. There are no initial testing requirements under this section. Periodic Testing Requirements 14. 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 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. AIRS ID: 123/9E2E Page 4 of 13 0�: olor.* :�Depa ens P .li Health and Environment it Pollution Control Division 16. Federal regul. •.r ;- . - -- • is . ' *A,, NAN ` _- Title V Operating Permit) 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 17. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 18. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 19. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 20. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 21. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of 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. 22. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. AIRS ID: 123/9E2E Page 5 of 13 DIor. Depa en s P .•li Health and Environment iii it Pollution Control Division lir 23. Violation of t , . :. o -e of - - - .sions e 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation AIRS ID: 123/9E2E Page 6 of 13 all��. olor-_<< KDepa end P �.li Health and Environment 6°4 it Pollution Control Division Notes to Permit Holder me o •e an :'"`' 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled Rate emissions Emission Rate Pollutant CAS# (Ib/yr) reportable? (Ib/yr) Formaldehyde 50000 195 No 195 Acetaldehyde 75070 26 No 26 Acrolein 107028 25 No 25 Benzene 71432 15 No 15 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Pollutant Emission Factors - Emission Factors— Source Uncontrolled Controlled NOx 10.900 g/hp-hr 0.500 g/hp-hr Manufacturer CO 13.100 g/hp-hr 0.500 g/hp-hr Manufacturer VOC 2.200 g/hp-hr 0.500 g/hp-hr Manufacturer Formaldehyde 0.0205 lb/MMBTU 0.021 lb/MMBTU Manufacturer Acetaldehyde 0.00279 lb/MMBTU 0.003 lb/MMBTU AP-42 Acrolein 0.00263 lb/MMBTU 0.003 lb/MMBTU AP-42 Benzene 0.00158 lb/MMBTU 0.002 lb/MMBTU AP-42 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7471 Btu/hp-hr, a site-rated horsepower value of 145, and a fuel heat value of 1167 Btu/scf. 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 AIRS ID: 123/9E2E Page 7 of 13 olor-.� yDepa ens• P .Ii Health and Environment it Pollution Control Division associated with thi --- or -g ;* - cific - � '. ,ion date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor/Major Source of: VOC NANSR Synthetic Minor/Major 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.govt 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.aov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9E2E Page 8 of 13 olor. Depa en P .li Health and Environment it Pollution Control Division ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9E2E Page 9 of 13 olor. Depa en s. P .•li Health and Environment it Pollution Control Division y.' 2.1.2 The owner or o• .. .�_-s -y -a" • epl, ' isting - --,•ressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer)as found on the Division's web site at: http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. AIRS ID: 123/9E2E Page 10 of 13 olor ,,Depa en P!•li Health and Environment 11 it Pollution Control Division For comparison with a - �_�� f.- a er ��-• (lb/ -_ ' ), 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: 123/9E2E Page 11 of 13 olor. Depa _ en' • P .li 'Health and Environment 0 •it 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: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOX 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, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123/9E2E Page 12 of 13 ski olor2Depa en t . P •Ii Health and Environment 0 •it Pollution Control Division requirements for the , � - e, : -- incl - 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: 123/9E2E Page 13 of 13 Division Information Engineer: Christopher Kester Control Engineer: Stefanie Rucker Review Date: 02/04/2016 Application Date: 10/14/2016 Facility Identifiers Permit No. 15WE1411 Potentially located in ozone nonattainment area County# 123 'Weld AIRS Facility# 9E2E Facility Type: exploration and production facility ❑ Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: i✓ VOC r NOx 1— CO Administrative Information Company Name: Synergy Resources Corporation Source Name: SRC Cannon Pad Source Location: SESE SEC 16 T4N R68W SIC: 1311 Address 1: Synergy Resources Corporation Mailing Address 2: 20203 Highway 60 Address ty,State Zip: Platteville, CO Name: Jerry Brian Person To Phone: 970-737-1045 Contact Fax: Email: rsandquist@syrginfo.com (Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W,Weld County, Colorado. Point Name Type Control Action Catalytic Newly 006 RICE ENG-3 Engine Oxidizer reported source One(1)Caterpillar G3508B ULB,SN:RBK01540,natural gas-fired,turbocharged,4SLB reciprocating internal combustion engine,site rated at 690 horsepower at 1400 RPM.This engine shall be equipped with an oxidation catalyst and air-fuel ratio control.This emission unit is used as a gas lift engine. 006 Engine Information Engine date of m 1/1/2011 Manufacturer: Caterpillar Model Number: G3508B ULB Serial Number: RBK01540 RPM: 1400 Site-rated RPM: 1400 Engine Function Other Gas lift Mfg's Max.Rated Horsepower @ sea level: 690 berating Horsepower used for calcuations: 690 BSCF @ 100%Load(btu/hp-hr): 8190 Site-Rated BSCF @ 100%load(btu/hp-hr): 8190 Other Engine Type 4SLB Parameters Aspiration turbo-charged Max hrslyr of Operation' 8760 Calculations Fuel Use Rate @ 100%Load 4842.416452 scf/hr ACTUAL Annual Fuel Consumption 42.420 MMscf/yr MAX HU I tN I IAL Annual uei Consumption 42.420 MMscf/yr REQUESTED Annual Fuel Consumption 42.420 MMscf/yr Fuel Heating Value 1167 btu/scf Emission Control Information This engine shall be equipped with an oxidation catalyst and air-fuel ratio control Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 0.500 g/hp-hr 0.500 g/hp-hr 3.32 tpy 3.32 tpy Manufacturer CO 3.190 g/hp-hr 0.223 g/hp-hr 21.21 tpy 1.48 tpy Manufacturer VOC 1.440 g/hp-hr 0.792 g/hp-hr 9.57 tpy 5.27 tpy Manufacturer Formaldehyde 0.280 g/hp-hr 0.028 g/hp-hr 3723 lb/yr 372 lb/yr Manufacturer Acetaldehyde 0.00836 lb/MMBTU_ 0.008 lb/MMBTU 414 Ib/yr 414 lb/yr AP-42 Acrolein 0.00514 Ib/MMBTU_ 0.005 lb/MMBTU 254 lb/yr 254 lb/yr AP-42 Benzene 0.00044 Ib/MMBTU 0.000 Ib/MMBTU 22 lb/yr 22 lb/yr AP-42 Regulatory Requirements Ambient Air Imps Source is not required to model based on Division Guidelines Public Comment Public Comment Required for this permit application MACT 7777 Facility is an area source of HAPs,so engine is not subject to major source requirements.Engine is new Reg 7 XVII.E.2 Standards(g/hp-The engine is not subject to Reg 7 emission standards because it is subject to standards under NSPS JJJJ hr) Reg 7 XVII.E.3 The engine is subject to Reg 7 XVII.E.3 because the engine is rated greater than 500 hp Reg 7 XVI.B The engine is located in the NAA and is greater than 500 hp and is not subject to Reg 7 XVI.B MACT 7777(area Is this engine subject to MACT 7777 area source requirements? Yes source) NSPS JJJJ Is this engine subject to NSPS JJJJ? I Yes Note:JJJJ requriements are not currently included as permit conditions because the reg has not been 15WE1411.CP1.xlsm STATE OF COLORADO of cow •LO • •• D 'ARTY •F P = C HEALTH AND ENVIRONMENT r, AIR POLLUTION CONTROL DIVISION y1 `' TELEPHONE: (303)692-3150 * ' ' *' *1876 CONSTRUCTION PERMIT PERMIT NO: 15WE1411 1411 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 exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description • ID One (1) Caterpillar G3508B ULB, SN: RBK01540, natural gas- RICE ENG- fired, turbocharged, 4SLB reciprocating internal combustion 3 006 engine, site rated at 690 horsepower at 1400 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. This emission unit is used as a gas lift engine. Point 006: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another <<Make, Model>> 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 after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9E2E Page 1 of 1 , ..i olor g Depa end P ill Health and Environment i II it Pollution Control Division 2. Within one hug _ d =,;_ •• :0) , -'men ;- - t of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type X RICE ENG-3 006 3.4 5.3 1.5 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. AIRS ID: 123/9E2E Page 2 of 2 Ial olor Depa en ., liii Health and Environment 3, A it Pollution Control Division 7. The emission the a ash - - ated aintained 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 AIRS Pollutants Equipment Point Control Device Controlled ID RICE ENG- 006 Catalytic Oxidizer CO &VOC 3 PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID RICE ENG- 006 Consumption of natural gas as a fuel 42.42 MMscf/yr 3 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 (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 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 equipment is subject to the control requirements for stationary and portable engines in the 8-hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. AIRS ID: 123/9E2E Page 3 of 3 i olor . ,Depa en : P •li Health and Environment it Pollution Control Division OPERATING & M ' Y�I N , .° .. 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. A source initial compliance test shall be conducted on this emissions point 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 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. 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 AIRS ID: 123/9E2E Page 4 of 4 olor., =Depa en , P •Ii Health and Environment it Pollution Control Division For a its :; • .. . If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement engine. 17. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) • 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. AIRS ID: 123/9E2E Page 5 of 5 olor._ _Depa R end W P •li 'Health and Environment it Pollution Control Division 21. Unless specifi-. . . ed =-- g . ?+ spud onditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation AIRS ID: 123/9E2E Page 6 of 6 ilk olor.A Depa en P •liHealth and Environment it Pollution Control Division Notes to Permit Holder - me o "•e an 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled Rate emissions Emission Rate Pollutant CAS# (Ib/yr) reportable? (Ib/yr) Benzene 71432 21.8 No 21.8 Formaldehyde 50000 3723.4 Yes 372.3 5) The emission levels contained in this permit are based on the following emission factors: Point 006: Emission Factors - Emission Factors— Source Uncontrolled Controlled NOx 0.5 g/hp-hr 0.5 g/hp-hr Manufacturer CO 3.19 g/hp-hr 0.2233 g/hp-hr Manufacturer VOC 1.44 g/hp-hr 0.792 g/hp-hr Manufacturer Formaldehyde 0.28 g/hp-hr 0.028 g/hp-hr Manufacturer Acetaldehyde 0.0084 lb/MMBTU 0.0084 lb/MMBTU AP-42 Acrolein 0.0051 lb/MMBTU 0.0051 lb/MMBTU AP-42 Benzene 0.0004 lb/MMBTU 0.0004 lb/MMBTU AP-42 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8190 Btu/hp-hr, a site-rated horsepower value of 690, and a fuel heat value of 1167 Btu/scf. AIRS ID: 123/9E2E Page 7 of 7 IIolor tiDepa en . P •li Health and Environment \ ^ it Pollution Control Division A 6) In accordance with 7- • P. - --;ssion . - , - (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 Status Requirement Operating Permit Synthetic Minor/Major Source of: VOC NANSR Synthetic Minor/Major 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 X)O(XXX 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: 123/9E2E Page 8 of 8 olor-A�<Depa en P •li Health and Environment , „„ 'it Pollution Control Division ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5)years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9E2E Page 9 of 9 p olor.. ..R Depa en P .11 "Health and Environment a. ` it Pollution Control Division I 2.1.2 The owner or o• -y ,..,.."a epl ... isting,, ,, •ressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 123/9E2E Page 10 of 10 , olor. =Depa en s+� P%li Health and Environment ilk A it Pollution Control Division For comparison with a ,.• - g • I.--£ a � ,• - -er -; _>s -z. (lb/ �_I ), 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: 123/9E2E Page 11 of 11 �� all olor. �Depa ' en W� P .li Health and Environment iii Air Pollution Control Division or a� x.• . > 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: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx 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, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123/9E2E Page 12 of 12 olor_ Depa ensi, P •li `'Health and Environment •it Pollution Control Division requirements for the , J _ - e - '- incl -� r>=,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: 123/9E2E Page 13 of 13 Division Information Engineer: Christopher Kester Control Engineer: Stefanie Rucker Review Date: 02/03/2016 Application Date: 10/14/2015 Facility Identifiers Permit No. 15WE1412 Potentially located in ozone nonattainment area AIRs County# 123 !Weld Facility# 9E2E Facility Type: exploration and production facility E Located in the 8-hour non-attainment area? O True Minor Synthetic Minor for: VOC r NOx l— CO Administrative Information Company Name: Synergy Resources Corporation Source Name: SRC Cannon Pad Source Location: SESE SEC 16 T4N R68W SIC: 1311 Address 1: Synergy Resources Corporation Mailing Address 2: 20203 Highway 60 Address City,State Zip: Platteville, CO Name: Jerry Brian Person To Phone: 970-737-1045 Contact Fax: Email: rsandquist@syrginfo.com 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W,Weld County, Colorado. Point Name Type Control Action Hydrocarbon Newly 004 Liquid Loadout None reported Loading source 004 Hydrocarbon Loadout to Tanker Trucks Calculations L= 12.46*S*P*M/T(AP-42: Chapter 5.2, Equation 1) L= loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP-42 P True Vapor Pressure 3.44 psia AP-42 Table 7.1-2, 50degF and RVP 8.3 M Molecular Weight of Vap 37.15 lb/lb-mole E&P Tanks Emission stream T Liquid Temperature 511 deg. R Average local ambient temperature L 1.87 lb/10^3 gal 7.85E-02 lb/bbl Annual requested Throughput 819352 BBL/yr 34412784 gal/yr Annual requested VOC emissions 64341 lb/yr 32.17 tpy Control: None Efficiency: 0.00% NCRPs Component Mass Fraction Benzene 0.0018 n-hexane 0.0110 Toluene 0.0012 Xylenes 0.0004 Source: E&P Tanks Emission Stream Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.0785 lb/bbl 32.17 tpy 32.17 tpy AP-42 Benzene 0.0001 lb/bbl 115 lb/yr 115 lb/yr AP-42 n-Hexane 0.0009 lb/bbl 708 lb/yr 708 lb/yr AP-42 Toluene 0.0001 lb/bbl 78 lb/yr 78 lb/yr AP-42 Xylenes 0.00003 I b/bbl 27 lb/yr 27 lb/yr AP-42 Regulatory Review Regulation 3-APEN and Permitting Requirements 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)per day of crude oil on an annual average basis? No If yes,this emissions point is categorically exempt from permit requirements per Regulation 3,Part B,Section II.D.1.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 • STATE OF COLORADO •LORA D T F PU= C HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 «�e , '* *1876* CONSTRUCTION PERMIT PERMIT NO: 15WE1412 1412 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 exploration and production facility known as the SRC Cannon Pad, located in the SESE SEC 16 T4N R68W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Hydrocarbon Hydrocarbon loadout to tanker trucks; emissions from the loadout Liquid 004 are not controlled Loading THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 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 AIRS ID: 123/9E2E Page 1 of 8 olor- Depa ens P .li Health and Environment •it Pollution Control Division within 18 mon • ' eit- h; if -,`;.,if this -, truction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall 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 AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type X Hydrocarbon 004 32.2 --- Point Liquid Loading 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 rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point Hydrocarbon Liquid 004 Oil Loaded 819,352 BBL Loading AIRS ID: 123/9E2E Page 2 of 8 , D olorl Depa ens P Health and Environment •it 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.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) 8. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 9. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 10. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 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. AIRS ID: 123/9E2E Page 3 of 8 • olor- Depa en, . P ill Health and Environment i it Pollution Control Division COMPLIANCE TE �_ .-.. . N P 13. This source is not required to comply with any testing and sampling requirements. 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 (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. 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 or Title V Operating Permit) 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 AIRS ID: 123/9E2E Page 4 of 8 olor. Depa en P •li Health and Environment � �za it Pollution Control Division authorization r ;, d m: :-t "ur ..' - AP .- :;,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. 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 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. 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: Christopher Kester Permit Engineer AIRS ID: 123/9E2E Page 5 of 8 al olor_ Depa y en d°: P •li Health and Environment A it Pollution Control Division Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation AIRS ID: 123/9E2E Page 6 of 8 olor_ Depa en P •li Health and Environment it Pollution Control Division Notes to Permit Holder - me •e a 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible,but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) 004 Benzene 71432 115 No 115 004 n-Hexane 110543 708 Yes 708 004 Toluene 108883 79 No 79 004 Xylenes 1330207 27 No 27 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Emission Factors - Uncontrolled Pollutant lb/BBL loaded Source VOC 0.0785 AP-42 Benzene 0.0002 AP-42 n-Hexane 0.0009 AP-42 Toluene 0.0001 AP-42 Xylenes 0.00003 AP-42 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 AIRS ID: 123/9E2E Page 7 of 8 olor. Depa jjj en P •Ii Health and Environment z° s 'it Pollution Control Division M (vap ra s ar t) , lb/ - r• .. .. T(temperature of liquid loaded) = 511 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapor stream of the E&P tanks simulation used in this permit application 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC 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.clov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9E2E Page 8 of 8 A CDPHE COLORADO CO Department of Public • ( Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Jerry Brian 720-616-4300 April 5, 2016 Ref: Permit No: 15WE1407 SUBJECT: Draft Permit and Related Public Notice Dear Jerry Brian: The Air Pollution Control Division has prepared a public comment package for the Synergy Resources Corporation - SRC Cannon Pad. The thirty (30) day public notice period will begin on April 6, 2016. This public notice period is being provided in accordance with the Colorado Air Pollution Prevention and Control Act and Regulation No. 3, Part B, Section III.C. For thirty (30) days from the beginning of the notice period, copies will be available for public inspection at the respective county clerk's office(s). During the thirty-day period, please review your permit and call your permit engineer with any questions or concerns you may have. This application is complete and in proper form. It meets the requirements of the Colorado Air Quality Control Commission's Regulation No. 3, Part B, Section III.B. Sincerely, Christopher Kester Stationary Sources Air Pollution Control Division Enclosures 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe :. John W. Hickenlooper, Governor Larry Wolk, MD,MSPH, Executive Director and Chief Medical Officer , 4 A CDPHE COLORADO CO yr Department of Public Health Es Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 April 5, 2016 Dear Sir or Madam: On April 6, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Synergy Resources Corporation - SRC Cannon Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, 74-2 T C Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure cOF \ 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe � John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer r.,,` ,! J;j -1 f � CDPHE General APEN - Form APCD-200 CO Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD)website at www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. ri Permit Number: ' (E r LI0 - AIRS ID Number: 3 / � [Leave blank unless APED has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': Synergy Resources Corporation Site Name: SRC Cannon Pad Site Location Site Location: SESE Sec. 16 T4N R68W County: Weld 4,935 feet elevation NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 1625 Broadway, 3rd Floor Denver, CO 80202 Permit Contact: Jerry Brian Phone Number: (72O) 616-4300 Portable Source Home Base: E-Mail Address: jbrian@syrginfo.com 'Please use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. �w COLORADO Form APCD-200 - General APEN - Revision 7/20;5 1 C4 3 3IIi ' AIRS ID Number: / =� / Permit Number: _ — [Leave blank unless APCD has already assigned a permit r and.AIRS IDl Section 2- Requested Action ❑✓ NEW permit OR newly-reported emission source (check one below) E STATIONARY source ❑ PORTABLE source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership2 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Please note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info 8 Notes: Serial Nos.:(Cimarron:5903223,5903224,5903225,5903226)and(Project Consultants:unknown) 2 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Controlling vapor emissions from condensate and produced water tanks Manufacturer: Cimarron&Project Consultants Model No.: 48"High Volume,80"Dual Pressure Serial No.: See notes section above Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources the projected start-up date is: 07/15/2015 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 2 I COLORADOForm APCD-2OC - General.APEN - Revision 7/.20 15 �. .-,. Permit Number: f i , AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 4 - Processing/Manufacturing Information Et Material Use ❑ Check box if this information is not applicable to source or process From what year is the actual annual amount? 2015 Design Process Actual Annual Requested Annual Description Rate Amount Permit Limit3 (Specify Units) (Specify Units) (Specify Units) Condensate tank emissions 819,352 bbl/yr 682,791 bbl/yr 819,352 bbl/yr Material Produced Water tank emissions 89,172 bbl/yr 74,310 bbl/yr 89,172 bbl/yr Consumption: Finished Product(s): 3Requested values will become permit limitations. Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.30955/-104.99985 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Discharge;Height Operator Temp. Flow Rate Velocity' Above Ground,Level Stack1D,No. CF) (ACFM) (ft/sec) (F ) 25'(Cimarron), 30'(PJ) Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) E Circular Interior stack diameter(inches): 48" (Cimarron), 80" (Proj. Consultants) ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other(describe): COLORADO Form APCD-2OO - General APFN - Revision 7/20-5 3 I Permit Number: { J AIRS ID Number: <, /- [Leave blan'r,unless APCD has already assigned a permit g and.AIRS ID) Section 6 - Combustion Equipment Ft fuel Consumption Information ❑� Check box if this information is not applicable to the source (e.g. there is no fuel-burning equipment associated with this emission source) Design Input Rate Actual Annual Fuel Use Requested Annual Permit Limit3 (MMBTUIhr) (Specify Units) (Specify Units) From what year is the actual annual fuel use data? Indicate the type of fuel used': ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) ❑ Field Natural Gas Heating value: BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash Content: Sulfur Content: ❑ Other(describe): Heating value (give units): 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. a If fuel heating value is different than the listed assumed value, please provide this information in the"Other"field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ®Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency(% reduction): Pollutant Control Equipment Description Overall Control Efficiency (%reduction in emissions) TSP (PM) PM10 PM2.5 SOX NO„ CO VOC Enclosed Combustors 95% Other: See Condensate and Produced Water Calculations and APENs A� COIOR ADO Form APCD-200 - Gene-al APEN - Revision '/2015 4 I �b7 `..,..- Permit Number: f J ( 'IC - AIRS ID Number: ;7` --<.., / ' / /--- l v.'cLnk jr+te_s APCO n ,. l Fac _ne cnJ Section 7(continued) From what year is the following reported actual annual emissions data? 2015 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Uncontrolled . Requested Annual Permit Factor Actual Annual Emissions 3 Emission Emission Limit(s) Pollutant SourceFactor (Specify Units) (AP-42,Mfg. Uncontrolled Controlled' Uncontrolled Controlled etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) TSP (PM) N/A N/A N/A N/A . N/A N/A L I`'' -- PM,a N/A N/A N/A N/A N/A N/A I PM2.5 N/A N/A N/A N/A N/A N/A „ r SO„ N/A N/A N/A N/A N/A N/A 313 di',, NO,, 0.068 Ib/MMBtu 0.82 0.82 9,98- LC 9_98-1,o, CO 0.310 lb/MMBtu 3.73 3.73 7 Li, 47 t, VOC N/A N/A N/A N/A N/A N/A Other: 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria pollutants (e.g. HAP- hazardous air pollutant) equal to or greater than 250 lbs/year? ❑Yes ® No If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Uncontrolled Uncontrolled Controlled Overall Emission Factor CAS Emission Actual Actual Chemical Name Control Source s Number Factor Emissions Emissions Efficiency (AP-42, (specify units) Mfg.etc) (lbs/year) (lbs/year) 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. co�oaaoo AD-_-.7-2`)'„' _ 4', , :2C'.'_. 5 ,` Permit Number: `� AIRS ID Number: : save blan; .nte ,APCD has .'.r: iv Fr: Ift:a._j i mi:.. zutd Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete,true and correct. .11\")^4--\ \Co Sisaature c'1 Litgalty Authorized Person(not a vendor or consukant) Jaffe Jerry Brian -t �•rr;4 .., Director of Environmental Health and Safety Name(please print) Title Check the appropriate box to request a copy of the: ID Engineer's Preliminary Analysis conducted 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. 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