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Home My WebLink About20162682.tiff(COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 August 8, 2016 Dear Sir or Madam: On August 11, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Synergy Resources Corporation - SRC Kiehn 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, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 2016-2682 V bk.. C. 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692.2000 www.colorado.gov; cdphe cZ—e.V> QA.k> John W. Hickenlooper, Governor Larry Wolk, MD, .MSPH, Executive Director and Chief Medical Officer s -/G@/1 cc' PLC torwrq } pw ce cicH I sm icK) lam Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Synergy Resources Corporation - SRC Kiehn Pad - Weld County Notice Period Begins: August 11, 2016 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 Kiehn Pad Exploration and production facility SWSE Section 4, T4N, R68W Weld County The proposed project or activity is as follows: Exploration and production facility consisting of condensate tanks, truck loadout and three (3) reciprocating internal combustion engines. 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 Permits 15WE1153-15WE1156 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: Stephanie Spector Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 I AV" COLOR ADC Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Synergy Resources Corporation Permit Number: 15WE1153 Source Location: SRC Kiehn Pad SWSE Section 4, T4N, R68W, Weld County (non -attainment) Equipment Description: 26-400 bbl condensate tanks AIRS ID: 123-9E05-001 Date: December 2, 2015 Review Engineer: Stephanie Spector, PE Control Engineer: Chris Laplante Section 2 — Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3 —Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? July 20, 2015. I received a revised application via mail on 6/15/2016. Section 4 — Source Description AIRS Point Equipment Description 001 Twenty-six (26) above ground 400 bbl atmospheric condensate storage tanks. Emissions from these tanks are controlled by an enclosed flare. Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PMio CO X Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM10 CO Ozone Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of Regulation 7, Sections XII and XVII.C may apply) X Yes No Page 1 Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 001 CDPHE Condensate Storage Tank Emission Factors PS Memo 05-01 Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit (PTE) AIRS Point Process Consumption/Throughput/Production 001 661,380 BBL per year Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory} AIRS Point Process Consumption/Throughput/Production Data Year 001 551,150 BBL per year 2015 Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 551,150 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 001 01 Enclosed flare 95 Section 6 — Emission Summary (tons per year) Point NQ VOC CO Single HAP Total HAP PTE: 001 0.8 426.4 3.7 7.4 (Hexane) 10.0 PTE Controlled: 001 0.8 21.3 3.7 0.4 (Hexane) 0.5 Actual uncontrolled point source emission rate: 001 0.7 355.3 3.1 6.2 (Hexane) 8.9 Actual controlled point source emission rate: 001 0.7 17.8 3.1 0.3 (Hexane) 0.4 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) Requested Benzene 71432 A 2152 Yes 108 Toluene 108883 C 1398 Yes 70 Ethylbenzene 100414 C 114 No 6 Xylenes 1330207 C 422 Yes 21 n -Hexane 110543 C 14897 Yes 745 2,2,4-TMP 540841 C 1050 Yes 53 Actual Benzene 71432 A 1793 Yes 90 Toluene 108883 C 1165 Yes 58 Ethylbenzene 100414 C 95 No 5 Xylenes 1330207 C 352 Yes 18 Page 2 n -Hexane 110543 C 12414 Yes 621 2,2,4-TMP 540841 C 875 Yes 44 Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8 —Testing Requirements Will testing be required to show compliance with any emission rate or regulatory standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 001 01 VOC, HAPS PS Memo 05-01 Liquids Analyses according to PS Memo 05-01 001 01 Opacity Regulation No. 7 Section XVII.AII Method 22 Section 9 — Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Total facility X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? Yes X No Section 11 — Modeling Is modeling required to demonstrate compliance with National Ambient Air Quality Standards (NAAQS)? Yes X No AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 001 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Regulation 2 — Odor 001 Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Page 3 Regulation 3 - APEN5, Construction Permits Operating Permits, PSD 001 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) 001 Part B — Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section ILD.2.a) Regulation 6 - New Source Performance Standards 001 NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons (471 bbl)? No Is this source subject to NSPS Kb? No WHY? Tanks are 400 bbl each, less than the criteria of this subpart. Therefore, this point source is not subject to this subpart. 001 NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY. Are uncontrolled VOC emissions greater than 6 TPY? Yes Are controlled emissions greater than 6 TPY? Yes Is the operator requesting a permitted limit less than 6 TPY? No Source is subject to NSPS OOOO requirements. Regulation 7 —Volatile Organic Compounds 001 XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non -attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are greater than 6 tpy of VOC.) Regulation 8 — Hazardous Air Pollutants 001 MACT EEEE: Organic Liquids Distribution This source is not subject to MACT EEEE because it is not located at a major source of HAP. 001 MACT HH This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13 —Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant / CAS # Fugitive (Y/N) Emission Factor Source Control (%) 001 01 E&P Condensate Storage Tanks 30.6974 lb/1000 gal VOC No Engineering Calculation (ProMax) 95 0.068 Ib/mmbtu NOx No AP -42 Table 13.5-1 0 0.31 Ib/mmbtu CO No AP -42 Table 13.5-1 0 0.0775 lb/1000 gal Benzene / 71432 No Engineering Calculation (ProMax) 95 0.0503 lb/1000 gal Toluene/ 108883 No Engineering Calculation (ProMax) 95 0.0041 lb/1000 gal Ethylbenzene / 100414 No Engineering Calculation (ProMax) 95 0.0152 lb/1000 gal Xylenes/ 1330207 No Engineering Calculation (ProMax) 95 0.5363 lb/1000 gal n -Hexane / 110543 No Engineering Calculation (ProMax) 95 0.0378 lb/1000 gal 2,2,4-TMP/ 540841 No Engineering Calculation (ProMax) 95 SCC 40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing losses Page 4 Section 14 — Miscellaneous Application Notes AIRS Point 001 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Original application came in 7/20/2015. When I started my review, I noticed that the facility was going to be major for VOC. I emailed the operator/consultant and was asked to put the project on hold on 12/3/2015. I received a revised application for all point sources (plus a new APEN) on June 15, 2016. I started reviewing that application and the facility is now synthetic minor. Operator calculated VOC and HAP emissions using an extended gas analysis sampled 8/5/2015 and a Promax simulation model. The model was based on the PTE throughput of 661,380 lb/bbl: Component Uncontrolled Uncontrolled Uncontrolled Uncontrolled Uncontrolled Controlled Emission Emission Flash gas Working Total (lb/hr) Total (TPY) Total (lb/yr) total factor factor (lb/hr) (lb/hr) (lb/yr) (lb/bbl) (lb/1000 gal) VOC 67.72034716 29.62119226 97.34153942 426.36 -- 21.32 1.2893 30.6974 TPY Benzene 0.192949 0.0527322 0.2456812 1.08 2152 108 0.00325 0.0775 Toluene 0.120792 0.0387836 0.1595756 0.6989 1398 70 0.0021 0.0503 Ethylbenzene 0.00968575 0.00332063 0.01300638 0.057 114 6 0.00017 0.0041 Xylenes 0.0322332 0.015973 0.0482062 0.2111 422 21 0.000638 0.0152 n -hexane 1.10128 0.599293 1.700573 7.44850974 14897 745 0.0225 0.5363 2,2,4-TMP 0.0757364 0.0441441 0.1198805 0.52507659 1050 53 0.00158 0.0378 The tanks are controlled by an enclosed flare. This flare emits NOx and CO. Operator included these emissions with the tanks since the enclosed flare is controlling the tanks. Operator used AP -42, Table 13.5-1 for NOx and CO emission factors: NOx = 0.068 lb 2124 btu 11.11 mmscf 1 T = 0.802 TPY NOx mmbtu scf yr 2000 lb CO = 0.31 lb 2124 btu 11.11 mmscf 1 T = 3.66 TPY CO mmbtu scf yr 2000 lb Page 5 STATE OF COLORADO Poo , s al .z COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1153 Issuance 1 DATE ISSUED: ISSUED TO: Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the SRC Kiehn Pad, located in the SWSE of Section 4, Township 4 North, Range 68 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description TNK-1 — TNK-26 001 Twenty-six (26) 400 BBL fixed roof storage tanks used to store condensate. Emissions from these tanks are controlled by an enclosed flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, y submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, I II.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: CO 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 AIRS ID: 123/9E05 Page 1 of 12 Condensate Tank SM/M Version 2012-1 bli"Health and Environment it Pollution Control Division such constru �"�ct w .e: d �.a(:-rmme *';.s set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO. VOC CO TNK-1 —TNK- 26 001 0.8 21.3 3.7 Point See Notes to Permit Holderfor information on emission factors and methods used to calculate Wilds. Compliance with the annual limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TNK-1 — TNK26 001 Enclosed combustors (12) VOC and HAPs PROCESS LIMITATIONS AND RECORDS AIRS ID: 12319E05 Page 2 of 12 -? dR This source s t.:kzamite��lo tki�;f491owm :: m pr tsmg 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 blidHealth and Environment it Pollution Control Division Facility Equipment ID AIRS Point Process Parameter Annual Limit TNK-1 — TNK26 001 Condensate throughput 661,380 BBL/yr The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1.&4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). If a combustion device is used to control emissions of volatile organic compounds to comply with Section XII. D, it shall 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. The operator shall comply with all applicable requirements of Section XII. 14. This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 15. The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: XVII.C.1.a. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. AIRS ID: 123/9E05 Page 3 of 12 Health and Environment it Pollution Control Division 16. The flare(s) c• '- bj-_-, • . ulatio s� 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.2.b If a 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 combustion device, or by other means approved by the Division, determine whether it is operating properly. XVII.B.2.d Auto -igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto -igniter as follows: XVII.B.2.d.(i) All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device. XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 17. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve-month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto -igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and AIRS ID: 123/9E05 Page 4 of 12 `€Color Depa blic'1Health and Environment es it Pollution Control Division XVII C_tr ir(y tf a i b :_ „-deal _.isased, i tion of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(a) A storage tank constructed on or after May 1, 2014, must comply with the requirements of Section XVII.C.2.a. by the date the storage tank commences operation. The storage tank must comply with Section XVII.C.2.b. and implement the approved instrument monitoring method inspections within ninety (90) days of the date that the storage tank commences operation. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections AIRS ID: 123/9E05 Page 5 of 12 Health and Environment it Pollution Control Division Thre • • ora• `"' n Uncontrolled Actual VOC Emissions (tpy) Ap.' • . ""trum Monitoring Method Inspection Frequency Phase -In Schedule > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 18. 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: 123/9E05 Page 6 of 12 blid Health and Environment r Pollution Control Division COMPLIANCE TESUN€37ANDa: Initial Testing Requirements 19. The operator shall complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine a site -specific emissions factor using Division approved methods. Results of site -specific sampling and analysis shall be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 20. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7 Section XVII.All) Periodic Testing Requirements 21. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7 Section XVII.All) ADDITIONAL REQUIREMENTS 22. 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 (NO,) 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 AIRS ID: 123/9E05 Page 7 of 12 e. No lat 23. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 24. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) Health and Environment it Pollution Control Division GENERAL TERMS AND CONDITIONS 25. 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. 26. 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. 27. 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. 28. 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. 29. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. AIRS ID: 12319E05 Page 8 of 12 bliclHealth and Environment it Pollution Control Division 30. Section 25 7 1) 7,¢2Xa), nQ S qg es gurcest ired 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 notifythe Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 31. 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: Stephanie Spector, PE Permit Engineer Permit Histor Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. Newly permitted condensate tanks at a synthetic minor facility. AIRS ID: 123/9E05 Page 9 of 12 Notes to Permit Holder "'°`Mm° "` e of Health and Environment it Pollution Control Division 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.qov/pacific/cdphe/aucc-reqs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 001 Benzene 71432 A 2152 Yes 108 Toluene 108883 C 1398 Yes 70 Ethylbenzene 100414 C 114 No 6 Xylenes 1330207 C 422 Yes 21 n -Hexane 110543 C 14897 Yes 745 2,2,4-TMP 540841 C 1050 Yes 53 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Emission Factors Uncontrolled lb/BBL Condensate Throughput Emission Factors Controlled lb/BBL Condensate Throughput Source NOx 0.068 Ib/mmbtu --- AP -42, Table 13.5-1 CO 0.31 Ib/mmbtu --- AP -42, Table 13.5-1 VOC 1.2893 0.0645 Engineering Calculation 71432 Benzene 0.00325 0.0002 Engineering Calculation 108883 Toluene 0.0021 0.0001 Engineering Calculation AIRS ID: 123/9E05 Page 10 of 12 tColora°HL Depa" mer* f F blic Health and Environment '5 !Pollution Control Division At :.. ,a CAS # Pollutant 11ssttactors ;y Uncontrolled lb/BBL Condensate Throughput .E fission E fprs Controlled lb/BBL Condensate Throughput Source 100414 Ethylbenzene 0.00017 0.00001 Engineering Calculation 1330207 Xylenes 0.000638 0.00003 Engineering Calculation 110543 n -Hexane 0.0225 0.0011 Engineering Calculation 540841 2,2,4-TMP 0.00158 0.00008 Engineering Calculation Note: The controlled em ssions factors for point 001 are based on the enclosed flare control efficiency of 95%. NOx and CO emissions are based on a fuel heating value of 2124 Btu/scf, and a potential fuel usage of 11.11 MMscf/yr. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: htt :''ecfr.g oacccss.goc_ 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 SubpartA— SubpartZ 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 AIRS ID: 12319E05 Page 11 of 12 Health and Environment it Pollution Control Division 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: 12319E05 Page 12 of 12 Division Information Engineer Stephanie Spector. PE Control Engineer Christopher Laplante Review Date. 06122/2016 Application Date 6/15/2016 (original application came in 7/20/2015) Facility Identifiers Permit No. 15WE1154 Al Rs County # Facility 4 9E05 Point # 002 Section 01: Administrative Information Company Name'. Synergy Resources Corporation Source Name'. SRC Kiehn Pad Source Location: SWSE Section 4 T4N. R68W SIC'. 211111 Elevation (feet) 5064 Mailing Address Address 1 Address 2 '. City, State Zip Synergy Resources Corporation 1625 Broadway. 3rd Door Denver. CO 60651 Person To Contact Name. Phone Fax'. Email. Jerry Brian 720-6164300 720 616-4301 jbrian[Nsyrginfo.com Section 02 - Emissions Inventory Analysis AP -42: Chapter 5.2 Equation 1 L = 12.46*S*P*M/T L = loading losses in lb per 1000 gallons loaded S =Saturation Factor P = true vapor pressure of liquid loaded [psis] M = molecular weight of vapors [Ib/b-male] T = temperature of bulk liquid loaded [deg. RI 1 degree Fahrenheit = 460.67 degree Rankine Criteria Pollutants Vanables S P M T L 0 6 Submerged loadingdedicated normal service 5 psia 45.02 lb/lb-mole 508 deg. R 3.31 1.39E-01 lb/10"3 gal Ib/bbl Annual requested Throughput Annual requested VOC emissions 27,777960 Gallons per Year 2,02r Pounds per Year 4 .r Tons VOC per Yea Non -Criteria Reportable Air Pollutants/Hazardous Air Pollutants HAP emissions were calculated using site-speafic information from ProMax model. Component Mass Flow (lb/hr) from Promax - Flash Mass Flow (lb/hr) from Promax- Working Total Mass flow (lb/hr) Total Emissions (TPY) Total VOC emissions (TPY) Ratio Emissions (TPY) Emissions (Ib/yr) Emission factor (lb/bbl) Emission factor (lb/1000 gap Benzene 0.192949 0.0527322 0.2457 1.08 426.3559 0.002523909 0.11612 232 0.0003512 0.008361 Toluene 0.120792 0.0387836 0.1596 0.70 426.3559 0.001639337 0.07543 151 0.0002281 0.005431 E-Benze 0.00968575 0.00332063 0.0130 0.06 426.3559 0O00133616 0.00615 12 1.859E-05 0.000443 Xylenes 0.0322332 0.015973 0.0482 0.21 426.3559 0.000495227 0.02279 46 6.89E-05 0.001641 n -hexane 1.10128 0.599293 1.7006 7.45 426.3559 0.017470168 0.80380 1608 0.0024307 0.057873 Section 03 - Regulatory Considerations Is this site considered an exploration and production location (e.g. well pad)? Yes 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 This emissions point is not categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Is this site located in an ozone non -attainment area? Yes This source is subject to Reasonably Available Control Technology (RACT) requirements under Regulation 3, Part B, Section III.D.2.a. This requirement is met using "submerged fill." Is this facility classified as a major source of HAPs? No Does this facility involve the loading of refined crudelcondensate in the form of "gasoline"? No Is this facility classified as a "Terminal" as defined per Regulation 7, Section VI.C.2.a? No Is this facility classified as a "Bulk Plant" as defined per Regulation 7, Section VI.C.3.a? No Section 04 - SCC Coding Emissions Factor Pollutant (Ib/1.000 gallons) VOC 3.31 lb/1,000 gallons Benzene 232 2497 lb/1,000 gallons n -hexane 1607 6018 lb/1,000 gallons 40600132: Crude Oil'. Submerged Loading (Normal Service) STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1154 Issuance 1 DATE ISSUED: ISSUED TO: Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the SRC Kiehn Pad, located in the SWSE of Section 4, Township 4 North, Range 68 West, in Weld County, Colorado, THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Hydrocarbon Liquid Loading 002 Truck loadout of condensate. Emissions from the loadout are not controlled. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). AIRS ID: 123/9E05 Page 1 of 8 Condensate Loadout TM Version 2012-1 o Public Health and Environment Air Pollution Control Division 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 retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type VOC Hydrocarbon Liquid Loading 002 46.0 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AIRS Point Process Parameter Annual Limit 002 Condensate Loading 661,380 BBL AIRS ID: 123/9E05 Page 2 of 8 err of Public Health and Environment Air Pollution Control Division Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. &4.) This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 12. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 13. This source is not required to comply with any testing and sampling requirements. AIRS ID: 123/9E05 Page 3 of 8 Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30`" whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 15. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 16. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 17. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with AIRS ID: 123/9E05 Page 4 of 8 a;qp o D)artimter(ofPublic Health and Environment y Air Pollution Control Division 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: Stephanie Spector, PE Permit Engineer Permit History Issuance Date Description AIRS ID: 123/9E05 Page 5 of 8 Public Health and Environment Air Pollution Control Division Issuance 1 This Issuance Issued to Synergy Resources Corporation. Newly permitted truck loadout at a synthetic minor facility. AIRS ID: 123/9E05 Page 6 of 8 of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reqs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 002 Benzene 71432 A 232 No 232 Toluene Ethylbenzene 108883 C 151 No 151 100414 C 12 No 12 Xylenes 1330207 C 46 No 46 n -Hexane 110543 C 1608 Yes 1608 5) The emission levels contained in this permit are based on the following emission factors: CAS Pollutant Emission Factors Uncontrolled lb/BBL loaded - Source VOC 0.139 AP -42 110543 n -hexane 0.0024 AP -42 71432 Benzene 0.00035 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) = 5.0 psia M (vapor molecular weight) = 45.02 Ib/Ib-mol T (temperature of liquid loaded) = 508 °R AIRS ID: 12319E05 Page 7 of 8 Public Health and Environment Air Pollution Control Division The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC 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: httb://www.colorado.aov/pacific/cdphe/air-permit-selfcertification AIRS ID: 12319E05 Page 8 of 8 Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID Synergy Resources Corporation SRC Kiehn Pad SWSE Section 4, T4N, R68W RICE ENG-1 Permit No. AIRS Review Date Permit Engineer 15WE1155 123/9E05/003 12/02/2015 Stephanie Spector, PE Requested Action Issuance No. New permit/newly reported emission 1 Emission Point Description One (1) Caterpillar, Model 3508B, Serial Number RBK01548, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 690 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural gas compression. Natural Gas Consumption Requested (mmscf/yr) 43.49 Requested (mmscf/m) 3.69 Fuel Heat Value (btu/scf) 1161 BSCF (Btu/hp-hr) 8353 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer Manufacturer VOC Manufacturer Manufacturer CO Manufacturer Manufacturer Formaldehyde Manufacturer Manufacturer SOX AP -42; Table 3.2-2 (7/2000); Natural Gas No Control TSP AP -42; Table 3.2-2 (7/2000); Natural Gas No Control PM10 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-2 (7/2000); Natural Gas No Control Other Pollutants AP -42 AP -42 Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 8760 Point Summary of Criteria Emissions (t Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 3.3 3.3 3.3 0.0% VOC 9.7 4.7 9.7 51.7% CO 20.9 13.3 20.9 36.1% SOx 0.0 0.0 0.0 0.0% TSP 0.3 0.3 0.3 0.0% PM10 0.3 0.3 0.3 0.0% PM2.5 0.3 0.3 0.3 0.0% Total HAPs* 0.0 0.0 2.4 0.0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minim us thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants lb HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 3731 3731 3731 0.0% Acetaldehyde 422 422 422 0.0% Acrolein 260 260 260 0.0% Methanol * * 126 0.0% n -Hexane * * 56 0.0% Benzene * * 22 0.0% Toluene * 21 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Operator calculated 3728 Ib/yr uncontrolled formaldehyde. This could be a rounding issue. Controlled emissions were calculated the same. I will accept the operator's uncontrolled since it's very close and controlled is the same. Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ Missing or invalid entry information over 500 HP located at a(n) Area Source Reg 7 XVII.E Standards (g/hp-hr) NOx: NA CO: NA VOC: NA Reg 7 XVI.B (Ozone NAA requirements) applies? Yes MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area source requirements? Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes 0 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: DATE ISSUED: ISSUED TO: 15WE1155 CONSTRUCTION PERMIT Issuance 1 Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the SRC Kiehn Pad, located in SWSE Section 4, T4N, R68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description RICE ENG-1 003 One (1) Caterpillar, Model 3508B, Serial Number RBK01548, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 690 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar 3508B engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq) TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permittinq-notices. Failure to notify the Division of startup of the permitted source is a 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: 12319E05 Page 1 of 14 NGEngine Version 2014-1 Public Health and Environment Air Pollution Control Division 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, I I I. F.4. ) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO, VOC CO RICE ENG-1 003 3.3 4.7 13.3 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) AIRS ID: 123/9E05 Page 2 of 14 Mel oftPublic Health and Environment Air Pollution Control Division from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled RICE ENG- 1 003 Oxidation catalyst and air/fuel ratio controller VOC and CO PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility EquipmentPo ID Point t Process Parameter Annual Limit RICE ENG- 1 003 Consumption of natural gas as a fuel 43.49 r MMscf/yr Y Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, AIRS ID: 123/9E05 Page 3 of 14 o'Public Health and Environment Air Pollution Control Division Sections XII.C.1.d or XVI1.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. OPERATING & 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. A source initial compliance test shall be conducted on emissions point 003 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 16. 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 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 AIRS ID: 123/9E05 Page 4 of 14 mer'l of Public Health and Environment ?i Air Pollution Control Division For volatile organic compounds (VOC) and nitrogen oxides sources (NO„) 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. 18. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 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 AIRS ID: 123/9E05 Page 5 of 14 Public Health and Environment Air Pollution Control Division obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Spector, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. Newly permitted engine at a synthetic minor facility. AIRS ID: 123/9E05 Page 6 of 14 Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reqs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 003 Formaldehyde 50000 A 3,731 Yes 3,731 Acetaldehyde 75070 A 422 Yes 422 Acrolein 107028 A 260 Yes 260 Methanol 67561 C 126 No 126 n -Hexane 110543 C 56 No 56 Benzene 71432 A 22 No 22 Toluene 108883 C 21 No 21 5) The emission levels contained in this permit are based on the following emission factors: Point 003: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled lb/MMBtu Factors — g/bhp-hr NOx 0.1320 0.50 0.1320 0.50 CO 0.8261 3.13 0.5279 2.00 VOC 0.3827 1.45 0.1848 0.70 50000 Formaldehyde 0.0739 0.28 0.0739 0.28 75070 ' Acetaldehyde 0.0084 0.03 0.0084 0.03 107028 Acrolein 0.0051 0.02 0.0051 0.02 67561 Methanol 0.0025 0.01 0.0025 0.01 110543 n -Hexane 0.0011 0.00 0.0011 0.00 71432 Benzene 0.0004 0.00 0.0004 0.00 108883 Toluene 0.0004 0.00 0.0004 0.00 AIRS ID: 123/9E05 Page 7 of 14 Public Health and Environment Air Pollution Control Division Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8353 Btu/hp-hr, a site -rated horsepower value of 690, and a fuel heat value of 1216 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer 75070 Acetaldehyde AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 67561 Methanol AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 110543 n -Hexane AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 71432 Benzene AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 108883 Toluene AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is val'd for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr18ia08.odf Additional information regarding area source standards can be found on the EPA website at: http://www.eoa.clovittn/atw/area/arearules. html 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: AIRS ID: 123/9E05 Page 8 of 14 http.//ecfr.gpoaccess.goy/ Public Health and Environment Air Pollution Control Division Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 12319E05 Page 9 of 14 Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a 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: 12319E05 Page 10 of 14 of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 123/9E05 Page 11 of 14 Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 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: 123/9E05 Page 12 of 14 erpi oft'Public Health and Environment fu Air Pollution Control Division The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 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: 12319E05 Page 13 of 14 Co + do i °p. " e i' o Public Health and Environment Air Pollution Control Division requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 12319E05 Page 14 of 14 Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID Synergy Resources Corporation SRC Kiehn Pad SWSE Section 4, T4N, R68W RICE ENG-2 Permit No. AIRS Review Date Permit Engineer 15WE1156 12319E05/004 12/02/2015 Stephanie Spector, PE Requested Action Issuance No. New permit/newly reported emission 1 Emission Point Description One (1) Caterpillar, Model 3508B ULB, Serial Number TBD, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 690 horsepower. This engine shall be equipped with an oxidation catalyst and air -fuel ratio control. This emission unit is used for natural gas compression. Natural Gas Consumption Requested (mmscf/yr) 42.64 Requested (mmscf/m) 3.62 Fuel Heat Value (btu/scf) 1161 BSCF (Btu/hp-hr) 8190 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer Manufacturer VOC Manufacturer Manufacturer CO Manufacturer Manufacturer Formaldehyde Manufacturer Manufacturer SOX AP -42', Table 3.2-2 (7/2000), Natural Gas No Control TSP AP -42, Table 3.2-2 (7/2000)', Natural Gas No Control PM10 AP -42', Table 3.2-2 (7/2000), Natural Gas No Control PM2.5 AP -42, Table 3.2-2 (7/2000)'. Natural Gas No Control Other Pollutants AP -42 AP -42 Hours of Operation PTE Calculated at (hpy) Permit limits calculated at (hpy) 8760 8760 Point Summary of Criteria Emissions (t Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 3.3 3.3 3.3 0.0% VOC 9.6 5.3 9.6 45.1% CO 21.3 1.5 21.3 93.0% SOX 0.0 0.0 0.0 0.0% TSP 0.2 0.2 0.2 0.0% PM10 0.2 0.2 0.2 0.0% PM2.5 0.2 0.2 0.2 0.0% Total HAPs* 0.0 0.0 2.3 71.6% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants llb HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 3731 373 3731 90.0% Acetaldehyde 414 414 414 0.0% Acrolein 254 254 254 0.0% Methanol * * 124 0.0% n -Hexane * 55 0.0% Benzene * * 22 0.0% Toluene * * 20 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Operator calculated 3728 lb/yr uncontrolled formaldehyde. This could be a rounding issue. Controlled emissions were calculated the same. I will accept the operator's uncontrolled since it's very close and controlled is the same. Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT Z777 Missing or invalid entry information over 500 HP located at a(n) Area Source Reg 7 XVII.E Standards (g/hp-hr) NOx: NA CO: NA VOC: NA Reg 7 XVI.B (Ozone NAA requirements) applies? Yes MACT ZZZZ (area source) Is this engine subject to MACT ZZZZ area source requirements? Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes 0 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: 15WE1156 CONSTRUCTION PERMIT Issuance 1 DATE ISSUED: ISSUED TO: Synergy Resources Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the SRC Kiehn Pad, located in SWSE Section 4, T4N, R68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description RICE ENG-2 004 One (1) Caterpillar, Model 3508B ULB, Serial Number TBD, natural gas -fired, turbo -charged, 4SLB reciprocating internal combustion engine, site rated at 690 horsepower. This engine shall be equipped with an oxidation catalyst and air - fuel ratio control. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar 3508B ULB engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air- permittinq-notices. Failure to notify the Division of startup of the permitted source is a 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: 123/9E05 Page 1 of 14 NGEngine Version 2014-1 o Public Health and Environment Air Pollution Control Division 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO, VOC CO RICE ENG-2 004 3.3 5.3 1.5 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) AIRS ID: 123/9E05 Page 2 of 14 of'Public Health and Environment Air Pollution Control Division 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. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled RICE ENG- 2 004 Oxidation catalyst and air/fuel ratio controller VOC and CO PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS in Pot Process Parameter Annual RICE ENG- 2 004 Consumption of natural gas as a fuel 42.64 MMscf/yr Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 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, AIRS ID: 123/9E05 Page 3 of 14 Public Health and Environment Air Pollution Control Division Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 13. This equipment is subject to the control requirements for stationary and portable engines in the 8 -hour ozone control area under Regulation No. 7, Section XVI.B.2. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. OPERATING & 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. A source initial compliance test shall be conducted on emissions point 004 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The test protocol must be in accordance with the 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 16. 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 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 AIRS ID: 123/9E05 Page 4 of 14 Public Health and Environment Air Pollution Control Division For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. 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. 18. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 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 AIRS ID: 12319E05 Page 5 of 14 Public Health and Environment Air Pollution Control Division obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Spector, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Synergy Resources Corporation. Newly permitted engine at a synthetic minor facility. AIRS ID: 123/9E05 Page 6 of 14 of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www,colorado.gov/pacific/cdphe/agcc-reqs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 004 Formaldehyde 50000 A 3,731 Yes 373 Acetaldehyde 75070 A 414 Yes 414 Acrolein 107028 A 254 Yes 254 Methanol 67561 C 124 No 124 n -Hexane 110543 C 55 No 55 Benzene 71432 A 22 No 22 Toluene 108883 C 20 No 20 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled lb/MMBtu Factors — g/bhp-hr NOx 0.1346 0.50 0.1346 0.50 CO 0.8587 3.19 0.0601 0.22 VOC 0.3876 1.44 0.2127 0.79 50000 Formaldehyde 0.0754 0.28 0.0075 0.03 75070 Acetaldehyde 0.0084 0.03 0.0084 0.03 107028 Acrolein 0.0051 0.02 0.0051 0.02 67561 Methanol 0.0025 0.01 0.0025 0.01 110543 n -Hexane 0.0011 0.00 0.0011 0.00 71432 Benzene 0.0004 0.00 0.0004 0.00 108883 Toluene 0.0004 0.00 0.0004 0.00 AIRS ID: 123/9E05 Page 7 of 14 Public Health and Environment Air Pollution Control Division 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 1216 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Manufacturer CO Manufacturer Manufacturer VOC Manufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer 75070 Acetaldehyde AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 67561 Methanol AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 110543 n -Hexane AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 71432 Benzene AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 108883 Toluene AP -42; Table 3.2-2 (7/2000); Natural Gas No Control 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.qov/ttn/atw/area/fr181a08.pdf 8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: httn://www.epa.qov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules. html 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT ZZZZ Area Source Requirements: Applicable 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: AIRS ID: 123/9E05 Page 8 of 14 f + gseio D!3, rii aarterA3'° of1 Public Health and Environment Fe- II Air Pollution Control Division 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 SubpartA— SubpartZ MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9E05 Page 9 of 14 o" Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a 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: 123/9E05 Page 10 of 14 Cold opaftli e of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.ciov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 123/9E05 Page 11 of 14 Public Health and Environment Air Pollution Control Division For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 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 5O2, 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 5O2: 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: 123/9E05 Page 12 of 14 arli rr'ierporPublic Health and Environment Air Pollution Control Division -- The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requ i rem ents). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting AIRS ID: 123/9E05 Page 13 of 14 Public Health and Environment Air Pollution Control Division requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 12319E05 Page 14 of 14 V z LL c- Emission Source AIRS ID: k unless APCD has al s equipment is referenced within your organisation.) 0 C eet = Z T L 0) Section 02 — Requested Action (Check applicable request boxes) Section 01 — Administrative Information C y N 0 2." 5 C — U o o `m o c CL PO re ▪ en ndfathered source EN Sub EN Submittal for update only (Please ❑ ❑ r < `e 9 Z ® ❑ ❑ ❑ ❑ ,t" Li0 U U Q U Z Synergy Resources Corporation Company Name SRC Kiehl Pad 7 T .= o C) J SWSE Sec. 4 T4N R6SW C) - G z P. 0 2 -o U v 20203 Highway 60 0 7 on 2 Platteville, CO (970) 737-1073 Phone Number (970) 737-1045 C R L E-mail Address: Section 03 — General Information N n 3 u 0 a P 0 U N O 0 La- y F 9CZ - T It, T N } -2 3 N Normal Hours of Source Operation: Midstream or Downstream Z ❑'`OD } >- 0, a7 E U C Al_d_A© a2= 1 0 ? E c O m = C 0. 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P- C 2 �' R .. co co E n u b Q Q o 7,_,© c L. tA♦v0) G - '- C o °3 R _ � rn UH r gri -E; 00 e Tri ✓ O C Vi o u 0. ;Y Q m Q 00 C re e C N C Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) Newly Reported Well ® ® ® ® 4 Name of Well L _ SRC Kiehn 22-4CtIZ - SRC Kiehn 32-4NH7 SRC Kiehn 32-40112 - — SRC Weis K-9NI1Z SRC Kiehn C-4N1IZ API Number r 115 123-39712 05 123 -39713 05-123-39714 r P Cr. M en M eV N C C u CO 0O M m FORM APCD-205 H CI 4) cop C) aS h CI) O C.) E 0 u 0 U L 0 C) u a a d d cn IN H 0 0 H d H 0 x IN d SRC Kiehn N-4N11Z SRC Weis I2-9NHZ SRC Kiehn C-4CHZ SRC Kiehn 31-4CHZ SRC Weis 12-9CHZ SRC Kiehn 31-4NHZ h SRC Weis A-9NHZ 1 IC a ¢ 3 U cc 05-123-39716 05-123-39717 05-123-39718 T 05 -123 - 39720 05-123-39721 05-123-39722 05-123-39746 ..I- .0 M N N O FORM APCD-205 hCs Emission Source AIRS II): Permit Number: 00 a 0 = 0 cin ces 0 0 0 0 0 x u C a z3 _ E 7. ��y 7 c c L QC M It 0 ce C Z > > v 0 3 .92 o > mom of stack outlet (check one)'. E&P Sites On 0 E 0 C O F O n co 0 c— 0 0 • w V 8 w o • C E W p a O 4 C C — v t u • ` cC V o C C = C C v ≥ a O G L CC 0 C E Emission Factor Data Source See Coles N o u 2 v. N/A z z p] z Please use the.APCI) Non -Criteria Re pliable Air Pollutant Addendum form to report pollutants not listed above. Controlled (Tons/Year) M1 ¢ N V • P V v f .2 2 c — t c z z 3 4 z F 0 0 F I lacontro lied (Tons/Year) 6,27738'I(., 'P La o a e < < < N _ x— Z Z Z T Z Actual Calendar Year Emissions Controlled (Tons/Year) ; In 0 a N e O. z z z 4 Y E. c `° — , 0. Z Z Z a z Emission Factor v - m7 d > C L ._ = — Z Z. Z .0 g a_ e a z z Z._ 'z V Pollutant Benzene lathy then zene C O 6 O C 0 N Y V Z > U c -7 X 0 .E EL- -4 - NJ' N C 0 G 5 — G i a ea e L y e d - z ce c.? c E. • 3 ✓ i = 0- C E 2' E za a L O V y 0 Craie Rasmucon v 0 eu - cto Q v C U ti CV pm z_ 51. z L ` m C N O lest copy Bran L) ®I❑ FORM APCD-205 5 o k zts- eu G G Q Liu U I- 0 Z z O -- WI �/� �o co y W E r G Q C F o N J c J -o O 0) a cc _o s N Q y C] ` Q N H O w s, ce Q LwL r U O AIRS ID Number: Permit Number: Synergy Resources Corporation N E co z C co a E O 0 Zip Code: 80651 a) SO/SE Sec. 4 T4N R68W Plant Location: rsandquist@syrginfo.com E-mail Address: Controlled Actual Emissions (Ibs/year) A- -7 m 0- mm 0 e Uncontrolled Actual Emissions (lbs/year) 0 m co CI co w 04 m m Emission Factor Source CDPHE CDPHE Emission Factor (Include Units) 0.210 Ibs/bbl 0,0„0/:)/. L 9 in o O Control Equipment / Reduction (%) Le C) LO O) Chemical Name C C a1 x a) 2 C Benzene Chemical Abstract Service (CAS) Number 110543 171432 N for which Actual Data Applies: 2O15 } a) O 0 0 U co >, a a O N 0 -C Q >, C J C y a) O G O d m E N a1 CC a) C O) CO 0 Iu) 0 Title of Person Legally Authorized to Supply Data a a) N m a) a a) m C T a a 0 N C O L 3 Q T To a) J C O a) a a O a) E as z a 0 N Form Revision Date: A drocarbon Li a. GO Tc $ 1. • • Permit Number: Hydrocarbon Liquid Loading .10 Section 01 —Administrative Information Synergy Resources Corporation U pitied. Blank APENs j)}{OO}} SRC Kiehn Pad at )2 SWSE Sec. 4 T4N R68W Source Locatioi 20203 Highway 60 2 Platteville, CO Rhonda Sandquist rsandquist@syrginfo.com nail Address: (970) 737-1045 (970) 737-1073 \ddl. Info. & Notes: tors • Z co di • 07, L; z - AAAZch U :fli o = This product is loaded fro' • C ; co 5 FORM APCD-208 `o 0 C y a a 0 C .0 E 0 1- 4) 0 0 Y V C u en o O N O 4 8 cc CO e -105.005066 Other (Describe): Vertical with obstructing rainca Width (inches)= V V G Section 07 —Control Device Information Section 08 — Emissions Inventory Information E 0. 74 e. 9 e V C 0 = 0. 4 rn Yn 0' O V R e 0 E " Ct a fx 0 0 x c 0 0 C N CO ..1 n eN c U C a C e V i u 0 0 .rd _1 CO c 0 c CO LI1 C^ CC 0 U Q O 4 a r Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007): Emission Factor Documentation attached (If using site specific emission factor) Estimation Method or Emission Factor Source N/A N/A N/A N/ip 0 N/Arlo Li N/Ai//, L• N/A 0.23600 /1, I '/I Lbs/BBL 90:11256!, 1 90.112 108:136 108.136 CDPHE N/A N/A N/A N/A N/A N/A N/A 0.000410,ouo3S Lbs/BBL 0.157d,o'I} 0.157&t't - 0:18809, 0.1884. )t_ CDPHE 0.00360'0O19 Lba/BoL 1.3750,a 1;3750.b 1.6500,?) 1.650^•F CDPHE Requested Permitted Emissions Controlled _ (Tons/Year) Uncontrolled (Tons/Year) _ Actual Calendar Year Emissions' Controlled (Tons/Year) = t° C 00 C F Emission Factor in Uncontrolled Basis Control Efficiency (% Reduction) Control Device Description 'Cl. e U va no Pollutant E et E z u C O u 0 U o R U ci E G G 6 O see C .A C 6 a'" CC • 0 r tu a 9 o E p c y E y = u w cc E ° .m E U C ,o " 0 " 0 CI o` -a u e` U.0 E 0 N o` h FormAPCD-21)8-HydrocarbonLigaidLoadingAPEN-Ver 4-l4-2014 (1).docx 0 C) m 2 � o C Z C C Q U H Z Z � V�/J� co 17, L LU I Z E Q V O J c c J a 0 n- o Q c Lu 8 Q a) cc O a cc s V1 UJ AIRS ID Number: Permit Number: Company Name: Zip Code: 80651 C1 rn N- N - w Q) C L C r O — U z a) C O t d SWSE Sec. 4 T4N R68W Plant Location: E 0 U 0 C C) T C C co I- E-mail Address: Controlled Actual Emissions (lbs/year) m aio N • CO Uncontrolled Actual Emissions (lbs/year) C) ti• (V o M Emission Factor Source w a C O CDPHE i Emission Factor (Include Units) 0.00360 Ibs/bbl 0.00041 Ibs/bbl Control Equipment / Reduction (%) O O Chemical Name N m N S C Benzene Chemical Abstract Service (CAS) Number M Cr O O 171432 O m p c.) Title of Person Legally Authorized to Supply Data Form Revision Date: A Internal Combustion En C S U O L nested Action (check applicable request boxes) Section 02 — Re Section 01 —Administrative Information :7 U = Clre 7 •❑ Z C C N 7.0 d u 3 C = c = W v v o — 0. E ru c x E :._ o a c < . C C ❑ ❑ y LI z X t Cl Cl C C p d G £ Cl Z - a E U C _ E i .''t P _ R L) t _ _ 70 5 < ^ Cl` G — Z Z C w G U c c U 5 Y ❑ ❑ Cl Cl 0 LU N (4 5 J < J U Synergy Resources Corporation SRC Kiehn Pad U o R r z z 6 = F � 0 U co co ✓ N 20203 Highway 60 cc Platteville, CO (970) 737-1073 Phone Numh Rhonda Sandquist randquist@syrginfo.com Section 03 — General Informati o[ Ut Y V c S C • w =J U z o 0 0 O G 3 C 0 U ❑ - z cfr Engine date of manufacture: CO 0 CO z N U N O. U ❑ E1 C) L 0 ❑o 0 What is the maximum number or hours this engi PIN-Ver.02. 102014.doex 0 6 U LU 1 FORM APCD-201 Internal Combustion En n in the event of 2 v U U C V 0 n to C 2 o a4 E w co O -105.0D5066 n 0 o2 N a 0 H ctC Y 0 0- “(14' 0) CO O L6 E Y O Z r/) B O O .0 U I 2 o .0 E • F r. F O • • o C Y Y L O 0 V N 421 a a O Y y tt v `o 0 0 .) LU • C lion Inform Section 06 — Fuel Consum Seasonal Fuel Use (% of Annual Use) h CV C C) LU 0 O c Z 1,216-Btu/SCF non (gal/yr of MMSCF/yr) C 5 L , U Requested Permit Limit 41.52 MMscf/yr 0 41.52 MMscf/yr m m Z G E v >- E g a _ W v U 0 u c Ee [L 7 4 o C C) 3 a, o_ c0 y c I go N v o Lel 0 u H v 2 C 0 C 7,2 L C C 0 E C 'C ° 0 ii Estimation Method or Enusslon Factor Source N O < N 0. a N d < N 0 < Manufacturer `C 5 i¢ C 2 Manufacturer y O m C E N O C< N v N y C Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) m N O Ci LL `a. -- en W h m N W CO - o' ri M N N' N o 0 CO m N 0 0 N w Uncontrolled (Tons/Year) V) N O-- (7 O W V) en O W N 03 N 0 W D .71: ,- en n n LO COm e Co p N- <0 (O N 0 f p CV O W - Actual Calendar Year Emissions' 0 O C... c 0 U J V) N0.- o 0 EL - o VW) m„ - o n - m M n CO n` Co 00) CO c0 - N- o en o o W - Uncontrolled (Tons/Year) Inm N o 9 W - 9 W N m - 9 W [O v - co7 m (D o) LU C N ED CO - - N o o 0 W - Emission Factor 2 J m s- 2 IC C C s 2 a 0 m 2 7 , m 2 2a a P L L L L L L L 0 m 2 a , m 2 a = o 7 a 4 - O .- n O w Ci 0) V] G W- h r 7 on O w a CO C) o- it, .n- C `)N o en 9 O W n m 0 W y L. G 9 C) V LU Control Efficiency ("%o Reduction) Z C Z C Z C Z a Z a' g m<< n Z z C Z C Z Control Device Description n ^, C 0 0 C Z Z <<<<<<4<a Z Z Z Z Z Z Z Z a Z C C 0. C Z C Z C Z C 2 T a F Z U Catalyst I a Z C< Z Z a Z Pollutant TSP d ' c x ON x O OZ > 0 L' Formaldehyde IAcetaldehyde C N p C = H v 0 ti N C U C � U - U rOs 0. Ty C m .o • - O 0 O U C _ � V w V w n C Lr. L C - a E E o _ c R 0 o ' E" L 2 C L E C - _v w - L.0 E9 = F O R O v N C U M C 0 _ O O U 0 E co eC 0) 0 0 0 0. 0 N 0 Form APCD-201-RICEAPEN-Ver.02. 10.2014.docx C N 0 L • t z S t- ❑ N_ Q W _U E H 2 O ❑ z Vj Z ce O — a co y W ._ F- a) n O E U O - C - a O 8, NQ _o P d w u J CO a" O a Lit — iu Ce Z O Z Permit Number: C O Ct 0 a o U U) U O a) a) CC 9) O C T U) E U) z C C U? a E O U Zip Code: 80651 SWSE Sec. 4 T4N R68W Plant Location: rsandquist@syrginfo.com E-mail Address: Controlled Actual Emissions (lbs/year) 3,727.82 m o Ni N C' LU m N N N N N N N N N T -N Uncontrolled Actual Emissions (lbs/year) N m N- N CO O 0 N V Lt) N N N N N N N N, Emission Factor Source Manufacturer N Cr 01- 4 N 'I- a 4 AP -42 N 0- 4 Emission Factor (Include Units) 0.28 g/hp-hr C O W (D CS) 0 5.14E-03 lb/N/1MBtu 7 m v O W O .2.50E-03 Ib/MMBtu F-Tontrol Equip eduction 0 0 0 0 0 I Chemical Name Formaldehyde Acetaldehyde C 0 O 4 Benzene CD 0 N Chemical Abstract Service (CAS) Number O O O 175070 W N o o N CO <0 N- (.9 m is ❑ a a a 0 'D U) N O t 0 Q C7:4 C) U) J C y a) a 0 a) O (0 ❑ H C a a> a) U) 0_ CU ❑ a a 0 0 U) N N O 7 Q a To C) U) C O 5- U) a O U) C U3 z 0 Form Revision Date: A • rocatintf Internal Combustion Lt urce AIRS ID: I ID to idenfity how this equipment is referenced within y( Section 02— Requested Action (check applicable request boxes) Section 01 — Administrative Information N d_ P P r C_ P C _ ❑ ❑ O 00 C N o U `I Z Synergy Resources Corporation 0 z 0 SRC Kiehn Pad z z Platteville, CO (970) 737-1073 Rhonda Sandquist ❑ Notification of AOS permanent replacement Addl. Info. & Notes: rs andq u i st@ syrg i nfo, com Section 03 —General Information For new or i n r-- N CD n Z v } (attainment area? 0 c M ❑ ❑ O N W N E .a o m 2 U 0 S 0 ti 00 N rEE G 7 L J ❑o Form APCD-201-RICEAPNN-Vcr.02. 10.21)14. - a- O 00 GO M. Cr, 0 00 What is the maximum number of FORM APCD-201 rnal Combustion En S R i O m 0 0 c u N. aa C•) ► E Y ❑ oc . r < 0 • C ° o C C ..+ - v U y c., a 9 0 U = s t w e N Ci Y R . U C c n t_ O < r _y C C a CWi 3 - r) F - TeD 4 3 z'-" 2 o N q n WCI 0 Z rd I-4 C 0 0 V Cl)0 Y Z U 5 E v Y J — - Co U U CJ C ro n CO CO 0 0) O z CO O tiz o cN O co 0 _ II to 30 2 v ection 06 — Fuel Consumption Information 0 CO CN nal Fuel Use (% of An 0 J N i U) v L C LO N w ; 0 U co o. Requested Permit Limit 40.71 MMscf/yr to 0 40.71 MMscf/y 0 N Z C 4. a C 9 C R a v C e Co Estimation Method or Emission Factor Source N V a N C a N< O a a Manufacturer Manufacturer Manufacturer Manufacturer N 0. a N C a N S a Please use the APCD Non Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) l) N O 0 r On 0 r C o 0 — M to, ri I. N ¢i 0) R CO 0 0 N 0 N 0 n O O) ED '- `m F.t O O 0 C v N N a m U) LL - co o W g N O W (O Q M M CJ W L7 T N - N N (C 0.207 ' O N O W 0, a Actual Calendar Year Emissions Controlled (Tons/Year) vn N O- 0 W w 0 at m .- 0 W (0 0 .- m m 6 N N U) C) e . O s o N ON ry 0 I-- 0 0 W 0) o I- Uncontrolled (Tons/Year) N 0 O W Q. — M O W CD. .- N O W C .- CO M of CD Ln 0i C (`v m - r N o N- o N 9 W O j C LU .� 0 m 2 2 a J m 2 2 a J m 2 2 a 0 m 2 2 a L b m c e on L r eh r r of X m 2 2 a 0) m 2 2 0 m n 2 a Uncontrolled Basis M O ) O a o W r 0 O W r o W Lo Lo ' c � 0 coM m O 9 O W m rn 0 W c in 0 W O e Control Efficiency (% Reduction) C Z a Z a Z a Z a Z No O o O a Z a Z a Z Control Device Description I a Z a Z a Z C Z a Z N/A VIN a Z a Z a Z a Z r n E to V/N N/A a Z s ZZ N/A T .) U Catalyst T . 0222 a a a C .C i- a r> v: Z> U 9 Formaldehyde 9 ` i C 4 U G Y M CZ N O 0 r U m a O O v N DO 7;:a. O 9 o tOP Ws 0 1 5 en C a -o 0 O C C z ally Authorized to Supply Data Form APCD-201-RICFAPEN-Ver.02.10.2014.docx C N DO CO C- J 5 ❑ Z Liu ❑ Q w U H O Z z E w c H a Z O J c c —IJ-10c O a / te Lim O Q w`� a CO QL N cc 0 w ce Li La L.6 Z 0 AIRS ID Numbe w a Permit Number: C O O LZ O U U O N N CC Cl a> C Company Name: Zip Code: 80651 a) T N C 0 c o Z N C O r SWSE Sec. 4 T4N R68W Plant Location: (970) 737-1073 rsandquist@syrginfo.com E-mail Address: Controlled Actual Emissions (lbs/year) 372.78 LO CO M C Lel 7 V O N CO N 123.76 Uncontrolled Actual Emissions (lbs/year) N Nto N rl co ma V to a to N co r. N 1 23.76 Emission Factor Source Manufacturer a a v a C N a a N d_C a Emission Factor (Include Units) r n s C' co N O 8.30E-03 Ib/MMBIu CO a en o W ,- N en I- 0 W O V a 2.50E-03 Ib/MMBtu Control Equipment / Reduction (%) m in A co o o 0 0 0 Chemical Name Formaldehyde Acetaldehyde c O C N C m c co 2 Chemical Abstract Service (CAS) Number O 0 o U' 75070 107028 N Cl v r r CO to CO LA C N N LV 0 a Q m Ca 0 Cc O L 3�= o - a) >- a> Cc U C O Cc 0 0 d to Supply Data N m C ZO Cl Craig Rasmus Title of Person Legally Authorized to Supply Data Name of Person Legally Authorized to Supply Data (Please print) Q O N Form Revision Date: Aoril 14 rocatine Internal Combustion En Ca v C U r • G L atta ED 2 ti -c 9 o x c ▪ o a - ✓ C • E. < Out • '_ [iy O j < C _ • c C � C C n U a z RICE ENG-3 .7 ~ R O c ti L G ca E E E • e 4 w C E — C L O d 0. w Section 02 —Requested Action (check applicable request boxes) Section 01— Administrative Information Request for NEW permit or newly reported emission source Request for coverage under GENERAL, PERMIT number GY02 (Natural Gas Only) SRC Kiehn Pad Request MODIFICATION to existing permit (check each box below that applies) Source Location: SWSE Sec4 T4N R68W ❑ ❑ C L C v v C L L g v F 'c' < 9 v m an0 o U L C ❑ ❑ Request AMEN Update ZIP Code: 80202 1625 Broadway, 3rd Floor Mailing Addre Emissions data must be completed. Blank APENs will not be accepted. 0 O (720) 616-4300 Phone Number c z 0 (720) 616-4301 Fax Number Section 03 — General Information C N O C- C O 0 V U c 6 For new or reconstructed sou f- C •a, W R N -Era at G c_ E U N > U z E� sG z U L C a; < E p o 6 >> n at v C 00 Co r C R at a U e 3 v T G r` 0 v >2 v • m a 6 .2 l U_ •0 - C O r E C S -a ' .• ., m P .a z v A .== 2 v • E •J CC G ca a c e an C W ^ N1 C Ti C y R' E vrc L . f",1R C , q V i C. i 7 Z C i C A ^y c --:L .R4 R _ L For guidance on how to c C U • r. N 92, C 0ci 2 C <C ie engine was ordered: e engine was relocate rC - > C 0 z o r V < <c z 21 C n =li -E 01 p. E C v MCI Ce S I C S COl c F - W O • S U • Cm Manufacturer: ❑ E a •9-2 m L a Manufacturer's maximum rated in Manufacturer's maximum site ratin Engine Brake Specific Fuel Consumption (fp, I00% Load: E❑ C �C z E S C p U < E❑ C J • G C 0 6 6 C E a a at m C `O a a 0 ad C C E Q o c COO O = a Y Y J a) C) U O What is the max Form APCD-201-RICEAPEN-Ver.02.10.201 FORM APCll-201 5 al Combustion En C U y o L 0. C W o" U 0 U M O O n 00 O en Cr) CO V N a i W a Q w� co F 0 OC0 N O U 0 O C 2 O u a 0 u a a 0 U w 0 0 a Circular: Inner Diameter (inches) = O C N L umotion Inf ection 06 — Fuel C Seasonal Fuel Use (1% of Annual Use) 0 O a 0 1.0 N N i N U J N a Z 1,216 Btu/SCF Requested Permit Limit U 2 S c0 N 8.12 MMscf/yr z L 0 0 El �81 ;c7 N N! e =' of V O ~ E > May 0 o O 4 n cr W G I c v o -Ca d In Estimation Method or Emission Factor Source AP -42 LManufacturer Manufacturer it Manufacturer Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) Uncontrolled (Tons/Year) Actual Calendar Year Emissions' Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Uncontrolled Basis Control Efficiency (% Reduction) N/A Control Device Descnption Catalyst Pollutant TSP Acetaldehyde I ea tn yC.- - N 0 G, 2 V IFC 5 • a o O o e e U • m d o E O O 0 u O O u o m.3 -. h a ^ Y 1 3 E O .-o° F O ' C g o DG 0 N N a dt� )p o . T • 6 ▪ ;o a m a3 cps U t 2 Y s = - `c° , "sta.), 3 2 E `o m 10— • o _ p E i ° G 0 e O • cc 1 g r -- T Off. p h g C ,0 '_ U U o e • z F a a 't v b X N EtUp, z 0 0E a .0 N u .!Ilk° .y 0. d As'uL • • .'2 m4 aI o ^ F OD a € p o 3 3o gm a, u N Hello