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Home My WebLink About20162628.tiffCOLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150OSt PO Box 758 Greeley. CO 80632 August 3, 2016 Dear Sir: On August 11. 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Verdad Oil and Gas Corporation — Amen -5, Pastelak 3N, Drake -5, and Young 8K 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 & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, Co $0246-1530 P 303-692-2000 www.colorado.govIcdphe John W. Hickentooper, Governor I Larry Watk, MD, MSPH, Executive Director and Chief Medical Officer %-)0t1� ¢.,v+ew Cet PLc mCn!TP3,tL cPQ) 819(D/ teo Pw (ER/CHi Stn) 2016-2628 , t `�1O / r a \ Ca Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Verdad Oil and Gas Corporation -- Amen -5 -- 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: Verdad Oil and Gas Corporation Facilities: Amen -S, Pastelak 3N, Drake -5, Young 8N Four oil and gas exploration and production facilities NENE, S14, TIN, R65Vv'; NWNVv', S2, T1 N, R64W; SESF:, S22, .1N, R65W; NENE, S28, TIN, R65W Weld County the proposed project or activity is as follows: Operator requests four permits. Each permit request is for three 400 barrel condensate tanks, loadout, and a compressor engine. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3. Part B. Section II.I.C due to the following reason(s): o the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis. and a draft of Construction Permit 16WE0329 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/cdphelair-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 oldie 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 address: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B I Denver, Colorado 80246-1530 cdphe.commentsapcdgstate.co.us COLORADO alga 3q:PE Wsztrrozn , STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 16WE0329 Verdad Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Amen -5, located in the NENE, S14, T1 N, R65W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description RICE 001 One GM 92 HP natural gas RICE with emission controls Condensate Storage Tanks 003 Three 400 barrel condensate storage tanks controlled by an enclosed flare Loadout 004 Hydrocarbon loadout to tanker trucks with no control Point 001: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another GM FX10Q 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 sea), 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation 3, Part B, Section III.G.5). 2. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123-9E63 Page 1 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 3. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G,2). 4. 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.) 5. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 6 The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO X VOC CO RICE 001 0.9 0.6 1.8 Point Condensate Storage Tanks 003 0.9 7.9 4.0 Point Loadout 004 -- 3.2 -- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8 The 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.) AIRS ID: 123-9E63 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Control Device Pollutants Controlled RICE 001 Catalytic Reduction and Air to Fuel Ratio Controller NOx, CO Condensate Storage Tanks 003 Enclosed Flare VOC 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 rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3. Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS i Point Process Parameter Annual Limit RICE 001 Consumption of natural gas as a fuel 9.81 MMscf Condensate Storage Tanks 003 Condensate Throughput 32,850 bbl Loadout 004 Condensate Loaded 32,850 bbl Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 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. Point 001: 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) AIRS ID: 123-9E63 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 13. Point 001: This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine HP Construction or Relocation Date Emission Standard in glhp-hr NOx CO VOC < 100H P Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ≥500HP July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 1 Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. 14. Point 003: This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 15. Point 003: The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: XVII.C.1.a. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. 16. Point 003: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII. B General Provisions (State only enforceable). These requirements include, but are not limited to: 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. AIRS ID: 123-9E63 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. Point 003: The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVIl.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; XVl1.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 XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. AIRS ID: 123-9E63 Page 5 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. XV1I.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: 123-9E63 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII,C.2,b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3_c. The date and duration of any period where the air pollution control equipment is not operating. XV1I.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 XVl I.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. XV11.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. 18. Point 004: This source is located in an ozone non -attainment or attainment - maintenance area and is subject to the Reasonably Available Control Technology AIRS ID: 123-9E63 Page 7 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division (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, FILE) 19. Point 004: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, I I I. E): a Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 20. Point 004: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 21. Point 001 and 003:Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section IIl.G.7.) 22. Point 004:This source is not required to follow a Division -approved operating and maintenance plan. . COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 23. Point 003: The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A_11) Periodic Testing Requirements 24. Point 001: 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 25. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, l I . C) AIRS ID: 123-9E63 Page 8 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 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. 26. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 27. 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 A000 Regulation No. 3, Pad B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 28. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final AIRS II: 123-9E63 Page 9 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 29. 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. 30. 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. 31. 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. 32. 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. 33. 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: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Oil and Gas Corporation AIRS ID: 123-9E63 Page 10 of 18 Colorado Department 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 Vl.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pacename=CBONWrapoer 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant _ CAS # Uncontrolled Emissions (lb/yr) Reportable? Controlled Emissions (Ib/yr) 001 Formaldehyde 50000 191 No 191 003 Benzene 71432 723 Yes 36 n -Hexane 110543 4613 Yes 230 Toulene 108883 427 Yes 21 224 IMP 540841 361 Yes 18 004 Benzene 71432 13 No NA 004 n -Hexane 110543 118 No NA 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors - Uncontrolled Emission Factors — Controlled Source NOx 14 g/hp-hr 1.0 g/hp-hr Manufacturer CO 11 g/hp-hr 2.0 g/hp-hr Manufacturer VOC 0.7 g/hp-hr 0.7 g/hp-hr Manufacturer Formaldehyde 0.0205 lb/MMBTU 0.0205 Ib/MMBTU AP -42 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6334 Btu/hp-hr, a site -rated horsepower value of 92, and a fuel heat value of 950 Btu/scf. Point 003: Pollutant Emission Factors Uncontrolled Source AIRS ID: 123-9E63 Page 11 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Ib/bbl Condensate Throughput VOC 8.568 E&P TANK n -Hexane 0A25 E&P TANK Benzene 0.022 E&P TANK Toluene 0.013 E&P TANK Ethylbenzene 0.001 E&P TANK Xylenes 0.003 E&P TANK 224 TMP 0.011 E&P TANK Note: The controlled emissions for this point are based on the flare control efficiency of 95%. Point 004: Pollutant Emission Factors Uncontrolled Ib/bbl loaded - Source VOC 0A946 AP -42 Benzene 0.0004 PS 14-02 n -Hexane 0.0036 PS 14-02 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*MIT S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 6.35 psia M (vapor molecular weight) = 50 Ib/lb-mai T (temperature of liquid loaded) = 520 °R 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: 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: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources AIRS ID: 123-9E63 Page 12 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 ODD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.qov/pacific/cdphe/air-permit-self-certification AIRS ID: 123-9E63 Page 13 of 18 Colorado Department of 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 AC'S, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, 11.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed and the permanent language should be removed; also change every instance of 90 in this paragraph to 270. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with ail permit limitations and other AIRS ID: 123-9E63 Page 14 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation AIRS ID: 123-9E63 Page 15 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the N0X and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, II.A_42 (e.g., 39 tpy N0x limit, etc.), permanent replacements are not allowed 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both V0C 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 502, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this ACS, 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 S02: 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 XV1 Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: AIRS ID: 123-9E63 Page 16 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NO X CO VOC 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 500<Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60. Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section l.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. AIRS ID: 123-9E63 Page 17 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123-9E63 Page 18 of 18 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Stan Date: Section 01- Facility Information Kici Bear:. ". '3#3843 02. iebcuar :2i?if : ::::.. Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? :f yes, for what pollutant? O Carbon Monoxide (CO) ;L'erdad Oil and Gas Corporation ::::::::::::::::::::: • X23 NENE, S1ATYf₹.R65S!1!:..:::'. ..::::::::::::::::::::::.,.....• Eaplorancix&eclireoduatimarwWi4:i 104&.i clral sl QdQstroi;&:. r ....................... Section 02 - Emissions Units In Permit Application el ❑ Particulate Matter (PM) ❑� atone (NO). 0 VCC) AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks ... .:' . ... :. 001 ' .::" ::::::i: ... .... ......lai .... .... ... ;-:::..:.... Naturalas : ::::::::::::::::::::::::::::::::::. .. .. .. .. ::::::.!:.1.:P.:.:.:.X...:4,;.::: o .(.��a,� �y: i:::::::1554: of s. 002::::::;;°°:: ......_..... :.,.:of Pugttive'Componentlieeks.'' :';;.:Ii:::•':'.'.:;:;-;;°:'°::::°:::°:°: ...� :................ ....�3<« cancelled .:'.:.. .: • ::.°.: :. 003: :::::::: ' CiDliidensate"Storage Tank ::: . % ':':!des: s; .° :: •16WE0329:::::::::,±:::::: ' : ' ' "ke's::':::: t t...?Errnit raitial' ' Ci rotor changed 004 • � •..:: ash Itiscdt., r<;f fqu€ ..Loading �::,::.::.,a>.::•:• "; 1rar::s::ts::::l�r ::::•:::•::::'.' l`>33x9 ' ° 1 ., ... .........No• -•i• .":•:'.:::::::laattait:C0 ! Operator changed ...... ::.:..: :..:: / • ........................t....... .... :............ccc.., cu r. ................................. 0000tx3000' . : ::..:s ...... r Section 03 - Description of Project Operaboc i lass: eacissAe: witrsepacattcat:*cum n sir�.t a :frleaia::tte:lt.3 icsdertsat t�rrtit3 -fogiues�-anti:loadau::: .............................._.........._........................:....:.,::, .... : .............. Subisftte? .Sf t o issi viii g'producei °waternee &PEj:rti tie:SEi# 44ftocFj:f: Des. . .. .. i• :a iratar:• 'ktaszti ho ledge:o€Colorado if l syi#e it�ti l ell 1&'tli i32: f :t ftTdg itiDsx Sr �5:::.::. ::::..:::..:.. :.:.:,;.:.....,.. ::::_: _•••„„: .31 • .................•I.........._....... Section 011 - Public Comment Requirments Is Public Comment Required? If yes, why?' BSI:' C itsorfe Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?` 31E if yes, for what pollutants? ....• .. if yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wlde Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? :f yes, eplainwhat,prcgramsand which pollutants here: itlei3T£7peraiih 'P.eisntt§. QP •. i cion,,,,,, -;rte :::c::::::::::::::.:: .. ............ ..... Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant De eriozaton(PSD)..S42,.NO; CO ',hoc PMZ:S;; PIli110::.;c:,:. . Title V:OperatngPermits (OP): SO2, NO); dtJ;N0E;:PM2.5,.?.M1Q;.TSP;.FiARs T. . Nqn-Attainment New SourceReview:(NANSR):NCX,.VOc.:.::.: " •::..:::: . Division Information Engineer: Kirk Bear Control Engineer: Chris Laplante Review Date: 07/05/2016 Application Date: 02/02/2016 Facility Identifiers Permit No. 1 F1N E0329 Al Rs County # 123 Facility # 9E63 Weld Facility Type: exploration and production facility ❑� Located in the 8 -hour non -attainment area? Administrative Information O True Minor Synthetic Minor for: l voc r N Ox r co Company Name: Verdad Oil and Gas Corporation Source Name: Amen -5 Source Location: SIC: NENE, S14, TIN, R65W 1311 Mailing Address Address 1: Address 2: ity, State Zip: Verdad Oil and Gas Corporation 5950 Cedar Springs Road, Suite 200 Dallas, Texas 75235 Person To Contact Name: Phone: Fax: Email: Arthur Beecher) 214 728 1840 Abeecherl@VerdadOil.com )Requested Action Self Certification Required? Issuance Number: Source Description: Yes 1 Oil and gas exploration and production facility known as the Amen -5, located in the NENE, S14, T1 N, R65W, Weld County, Colorado. Point Name Type Control Action 001 RICE Engine None Newly reported source 003 Condensate Storage Tanks Condensate Tanks Flare Newly reported source 004 Loadout Loadout None Newly reported source 001 verdad, amen -5, 16WE0329 Engine Information Engine cate of m 2/1120..5 Manufacturer: GM Model Number: FX130 Serial Number. ; CCHMM532120005 RPM: 2200 Site -rated RPM: 2200 Engine Function Compression berating Mfg's Max. Rated Horsepower @ sea level: 92 Horsepower used for calcuations: 92 BSCF a 100% Load (btu/ho-hr): 6334 Site - Rated BSCF Cb 100% load (btu/hp-hr): 6334 Other Parameters Engine Type 4SRE Aspiration naturally aspirated Electncal Generator Max SiltRaUrly rgvr\ C Max hrsiyr of Operation 8760 Calculations Fuel Use Rate @ 100% Load 1119.86 scf/hr ACTUAL Annual Fuel Consumption 9 81 MMscf/yr MAX POTENTIAL Annual Fuel r„nsrsa�at��.. 9.81 MMscf/yr REQUESTED Annual Fuel ConsumQtion 9.81 MMscf/yr Fuel Heat:na Value 950.25 btu/scf Emission Control Information This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. Emissions Summary Table 6334 Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions 'Controlled Emissions Source NOx 14.000 g/ho-hr 0.980 g/hp-hr 12.4 tpy 0.9 tpy Manufacturer CO 11 000 g/hp-hr 1.980 g/hp-hr 9.8 tpy 1.B tpy Manufacturer VOC 0.700 g/hp-hr 0.700 c/hp-hr 0.6 tpy 0.6 tpy Manufacturer Formaldehyde 0.021 Ib./MMBTU 0.021 Ib/MMBTU 191 lb/yr 191 lb/yr AP -42 Acetaldehyde 0 603 IbiMMBTU 0.003 Ib/MMBTU 26 lb/yr 26 lb/yr AP -42 Acrolem 0 003 Ib/MMBTU 0.003 Ib/MMBTU 24 lb/yr 24 lb/yr AP -42 8erzene _ 0.4002 !O/MMBTU _ 0.002 _ Ib/MMBTU 15 Ib/yr 15 lb/yr j_AP-42 Reaulatory Requirements Ambient Air Impa Source is not recuired to model based on D=vision Guidelines/No NAAQS violations expected (see deta!is of Public Comment Public Comment rot Required MACT 7777 Facility is an area source of HAPs. so engine is not subject to major source recuirements. Engine is new Reg 7 XVII.E.2 Standards (g/hp- hr) The engine is not subject to Reg 7 because max engine rating is less .111 /2008 and t is not subject to MACT 777Z or NS PS JJJJ than 100 hp, it was constructed after Reg 7 XVII. E.3 The engine is not supject to Reg 7 XVII. E.3 because the engine :s rated less than 500 hp Reg 7 XVI.B (Ozone NAA requirements) applies? located in NAA so subject to Reg 7 XVI.B MACT ZZZZ (area source) Is this engine subject to MACT 7777 area source requirements? Yes NSPS JJJJ Is this engine subject to NSPS JJJJ? I I Na Note: JJJJ requriements are not currently inc:uded as permit conditions because the req has not been 16WE0329.CP1.xlsm 003 Three 400 barrel condensate storage tanks verdad, amen -5, 16WE0329 Requsted Throughput 32850 bbl Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 8.568 lb/bbl 140.7 tpy 7.0 tpy E&P TANK Benzene 0.022 lb/bbl 723 lb/yr 36 lb/yr E&P TANK n -Hexane 0.125 Ib/bbi 4106 lb/yr 205 lb/yr E&P TANK 224 toulene xylene e benz 0.011 lb/bbl 361 lb/yr 18 lb/yr E&P TANK 0.013 Ib/bbl 427 lb/yr 21 lb/yr E&P TANK 0.003 lb/bbl 99 lb/yr 5 lb/yr E&P TANK 0.001 lb/bbl 33 Ib/yr 2 lb/yr E&P TANK Tank emissions have ECD emissions added on to these totals. 18 ton VOC, 507 n -hex, uncontrolled, 0.9 ton VOC, 25 n -hex controlled Regulatory Review Section Il.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section Il.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) : eou ation:.. ° - . or Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7123/84. This source is not subject because each tank is less than 19,800 gallons (471 bbl) NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. ................................. Regulation 7— Volatile Organic. Compounds: XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non -attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are > than 20 tpy of VOC.) 004 Hydrocarbon Loadout to Tanker Trucks verdad, amen -5, 16WE0329 Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 6.3456 psia Sales Oil A M Molecular Weight of VaR 50 lb/lb-mole AP -42 T Liquid Temperature 512 deg. R Field Data L Annual requested Throughput Annual requested VOC emissions Control: None Efficiency: 0.00% NCRPs Component Mass Fraction 4.63 lb/1000 gal 0.19 lb/bbl Benzene 0.0018 n -hexane 0.0153 Source: 32850 bbl/yr 1379700 gal/yr 6392 lb/yr 3.2 tpy alysis If the operator provides HAP speciation from a stable "sales oil" analysis, enter the mass fraction from this data. Alternatively, if the operator modeled a pressurized oil to develop a site specific Pressurized oil or Stable Sales Oil Analysis Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1946 lb/bbl 3.2 tpy 3.2 tpy AP -42 Benzene 0.0004 lb/bbl 13 lb/yr 13 lb/yr PS 14-02 n -Hexane 0.0036 Ib/bbl 118 lb/yr 118 lb/yr PS 14-02 Regulatory Review Regulation •3• L.APEN and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.I Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.I No Yes No 005 One 400 barrel produced water storage tank verdad, Amen -5 Permit exempt Emissions Calculations Requsted Throughput 12775bbl i Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.262 lb/bbl 1.7 tpy 0.1 tpy CDPHE Benzene 0.007 lb/bbl 89 lb/yr 4 lb/yr CDPHE n -Hexane 0.022 lb/bbl 281 lb/yr 14 lb/yr CDPHE Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section 11. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) Requlatioti;:2Odor :::.. ,:::°°°°° Section l.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. AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)2 Permit Number: /6 kiia529 Facility Equipment ID: Condensat Storage Tanks Section 01— Administrative Information Company Name: Verdad Oil and Gas Corporation [Leave blank unless APC) has already assigned a permit tz R AIRS ID) Emission Source AIRS ID: 12 $ 1 ,Eb 3 / 0O3 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization ] Source Name: Amen -5 Source Location: NENE S14 TIN R65W Mailing Address: 5950 Cedar Springs Road, Suite 200 Person To Contact: Arthur Beecherl Phone Number: (214) 728-1840 N.AICS, or 1311 SIC Code: Section 02 — Requested Action (Check applicable request boxes) County: Weld ❑ Request for NEW INDIVIDUAL permit Request for coverage -under GENERAL PERMIT ❑ GPO1 ❑ GPOS Request MODIFICATION to existing INDIVIDUAL permit (check boxes below) Elevation: 4,988 Feet ❑ Change process or equipment ZIP Code. 75235 ❑ Change pennit limit E-mail Address: Dallas, TX Aleecherl@VerdadOiLcom Fax Number. Section 03 — General Information For existine sources, operation began on: This Storage Tank is Exploration & Production Located at: ® (E&P) Site ❑ Will this equipment be operated in any NAAQS nonartainment area? Is actual annual average hydrocarbon liquid throughput > 500 bblyday? ❑ Yes El No ► Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COCA -2C) 805 series rules" If so, submit Fonn APCD-105. In Are you requesting > 6 ton/yr VOC emissions, or are uncontrolled actual emissions"? 6 tonlyr" General description of equipment purpose: 3 x 400 bbl steel welded tanks manifolded together for storing condensate until transported off -site Section 04 - Storage Tank(s) Information 3j 150 Condensate Throughput: Change company name Transfer of ownership ❑ Other ❑ APEN Submittal for Permit Exempt/Grandfathered source O APEN Submittal for update only (Please note blank APEN's will not be accepted) Addl. Infn. & Nutes: Midstream or Downstream (Non-E&P) Site ® Yes ❑ No For new or reconstructed sources, the projected startup date is: 4 / 23 1 2015 hours Normal Hours of Source Operation: 24 day Are Flash Emissions anticipated at these tanks If "yes", identify the stock tank gas -to -oil ratio 7 days/ week 52 year Yes D No 0.017 _ m3/liter Yes ❑ No ® Yes ❑ No weeks. - Requested Permit Limit: 221,910 hbliyear Actual: 154,639 hhi/year Average API Gravity of Sales Oil: 41.52 degrees Tank Design. Fixed Roof: Internal Floating Roof: ❑ Actual While Controls Operational: _[44143$-+bbi;year RVP of Sales Oil 9.1 External Floating Root ❑ Storage Tank ID N of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of most recent storage vessel in storage tank (Month Year) Date Of First Production (jbtantlu'Year) 001 All three storage 400 04/2015 002 tanks are in series & 400 04/2015 003 manifolded together. 400 04/2015 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Welt 05 -123 - 398G4 Amen -5 0 - - ❑ - - ❑ - - O - - ■ FORM APCD-205 Page 1 of 2 FEB 42 2016 Colorado Department of Public Health and Environment Air Pollution Control Division (APCD)This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term. or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $1 52.90 per APEN for non- E&P, midstream and downstream sources or $152.90 for up to five (5) APENs for E&P sources and S250 for each general permit registration to: Colorado Department of Public llealth & Environment APCD-SS-131 4300 Cherry Creek Drive South Denver,T:O 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Biisiness Assistance Program (SBAP): (303) 692-3148 or I (303)692-3175 APEN t nos: htrp:;iw•wvi .col orado rov cane oil vas APEN S Application status: hrtp::'• nvw.colorado grw cdphe%pennitstalus • ;o Amen_ AP Foum-APCl)-205-Condensate- Tanks-A?EN doe 343828 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit —Condensate Storage Tank(s)1 Permit Number: /p W&nZ Section 05 — Stack Information For Midstream sites oni ) _(. ... _.. —� . �"t 1— __ :A.rr •.--e.—•.�'•�ky, �c y� �f,,.,7a.?'y�!('p�Y'rt.�.' !., .. (.�►;;J'1'.• J... l+7•-1{ t+a .6''4J",f t`.,yl..., vi,�.- .Si • . - _ Direction of stack outlet (check one): ❑ Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) Section 07 — Control Device Information Emission Source AIRS 1D: /13 ! 9 e43 / 6 03 Section 06 —Stack (Source, if no combustion) Location (Datum & either I.ati Long or LITIvf . 13l- .:, . ► ' '` -'rte 'sip:. ..,�:.�;��T, • • • Ip r. • .? :... t Y '� s 'tiQiat :..+..-ati:. .:!°ir-d�'a�:..p�.:w. -,., IRM Easting cr..�,"• CiR (. " •,-l�•. ' ��yymay_,Y. \toalCir,..: egma "Ji•%y,.��.Y. ;t .d:...... ., -.., ,:s aVIM Northing or ' �: lY [`�, tile - roo ,.� }! F.J ..>W .. - .�.a.� !; 1�.ti ..... ... .. ' Md e$&of Collection fa -... ..V J'. ,f t.�C44 Mir C. , •. r. R�.•�-(modw�eBenhQ�t.!Y: .ed +a.�. ... • .T .. N Rti .: .i •.. 0 �•: } ' 40.05816°N 104.62438°W ❑ Horicontal 0 fount 0 Other: Length (inches) ❑ Other (Describe): Width (inches) _ ❑ Vapor Recovery Unit (%RU) used for control of the Storage. Tank(s) Size. Make/Model: Requested VOC & HAP Control Efficiency: Annual time that VRU is bypassed (emissions vented): ❑ Closed loop system used for control of the storage tank(s) Description: Combustion Device used for control of the Storage Tank(s) Type: Emission Control Device Rating: 2.89 MMBtwibr Make/Model Cimarron Energy Inc./ECD-2-48-210 VOC & HAP Control Efficiency: Requested: -98 i °% Manufacturer Guaranteed: 98 Minimum temp. to achieve requested control: S00 `.F Waste gas heat content: 1,020 Btuiscf Constant pilot light? ® Yes No Pilot burner ratin .: 0.5 MMBtuih; .I. C Describe Any Other: Section 08 — Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 150 psig Please describe the separation process between the well and the storage tanks: 3 -phase separator (heater treater) separates gas, condensate, and water. Section 09 — Emissions Inventory information & Emission Control Information ® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput in Sec. 04 (e.g.2007 : .-wt� y.'... ... , .. �,��'� - •s,'. :' :=r3 s ; 9 "< ;, :_t. ., Ybb . '� .r •,,,:1: .,.fie '•�%: - 41::;� �-�? � „ : - F �.. Ih. ..w.r.3",.,... o .:p•,:r_.V'F: �• 14 :,!•„•s.:..<b�E�:C:yy�:: ' ,C :'i.:" i;;c - .: : " " tit ual slent)mt tir.Etntssiun.= , • .. �-T:a�YS'�ie:...r.-or ..... :.... .. .'' .... .. Requested Permitted - Emissions . Emission Factor '�.K!: i A'i::n`. �� *'::;��≤(:. t l sUilad news•.'- t -• a .tilt' ' '. as ° 5...0 iaiititmtted' 'f`ouslYear)- . '• Controlled (Toni/Year) .; ` Uncontrolled (Toes/Year) Controlled (TonsfYear) Deja Scarce . 4 NO x NIA NtA 11 ak N/A N/A N/A N/A NIA VOC g• 1S'Z2- 952,31 • port 44.705-' -7•(;) E&P Tanks 4&2& , X66498•— CO N/A tfik N/A N/A N/A N/A NIA Benzene -3/4— X552- &0U try). O 14i, all 0.0 E&P Tanks -0.39' 0,01.2. Toluene h +3 A VS -Ph-0.332•- 01J07- -0.479 -1.-F.0101 o.o E&P Tanks -0,1 p ,, Ethylbenzene �9 814 O.O0 i .24,„•i ll9f1- -0:026 0.001 O ,p E&P Tanks 0.018 p , 1 Xylcncs - 403 0,6o3 - MSS. x.082 tits- a. I tool pR p E&P Tanks n -Hexane 1.07- Q, l* 3.1175 0 416a Z . I t)r889 O . , E&P Tanks 2,2,4-Trimethylpentane 0.04+a.Ot� 44- &258— —0:005 3.372+ a y 0,0W? 0 . 0 E&P Tanks , Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not:listed shove. Section 10 —Applicant Certification - I hereby certify tbat all information contained herein and information submitted with ibis application:is complete, true and correct. If this is a registration for coveragj under general permit GPO( or GPO, I further certify that this source is and will be operated in full compliance with each condition of the applicable general permit. /41-'44.:27.---7: Z r j iv Arthur Beecher) Vice President of Operations ?n?9d 1l1P3Y t D ` Name of ie Authorized Pelson ) rr Title. ...' . .. ou may be charged an additions: APEN fee for APEN re -submittal due to incorrectly filled -out APEN or missing information. 2 Annual emissions fees will be based on actual emissions reported here Additional information Required: FORM APCD-205 Attach a pressurized pre -flash condensate extended liquids analysis, RVP & API analysis of the post -flash oil Attach E&P Tanks input & emission estimate documentation (or equivalent simulation report/test results) Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses Page 2 of 2 Check box to request COO./ of draft wink prior to issuance Check box to request copy of draft permi; prior to public notice Amen_APForm-APCD-?05-Condensate-Tanks-APEN due STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 16WE0330 Issuance 1 DATE ISSUED: ISSUED TO: Verdad Oil and Gas Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES 1S DESCRIBED AND LOCATED AS FOLLOWS: OH and gas exploration and production facility known as the Pastelak 3N, located in the NWNW, S2, T1 N, R64W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description RICE 001 One GM 92 HP natural gas RICE with emission controls Condensate Storage Tanks 003 Three 400 barrel condensate storage tanks controlled by an enclosed flare Loadout 004 Hydrocarbon loadout to tanker trucks with no control Point 001: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another GM FX10Q 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation 3, Part B, Section III.G.5). 2. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state_co.ustap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit, AIRS ID: 123-9E64 Page 1 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 3. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Pad B, III.G.2). 4. 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.) 5. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO x VOC CO RICE 001 0.9 0.6 1.8 Point Condensate Storage Tanks 003 0.9 11.4 4.0 Point Loadout 004 -- 5.2 -- Point See 'Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The 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 AIRS ID: 123-9E64 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Control Device Pollutants Controlled RICE 001 Catalytic Reduction and Air to Fuel Ratio Controller NOx, CO Condensate Storage Tanks 003 Enclosed Flare VOC 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 rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit RICE 001 Consumption of natural gas as a fuel 9.81 MMscf Condensate Storage Tanks _ 003 Condensate Throughput 54,750 bbl Loadout 004 Condensate Loaded 54,750 bbl Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 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, Pad 9, III.E.) (State only enforceable) 11. Point 001: 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 XVll.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) AIRS ID: 123-9E64 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 13. Point 001: This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVI1.E (State only enforceable)_ The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ?500HP July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. 14. Point 003: This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 15. Point 003: The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: XVII.C.1.a. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. 16. Point 003: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: 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_ AIRS ID: 123-9E64 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. Point 003: The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XV1I.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; XVTI.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 XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. AIRS ID: 123-9E64 Page 5 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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). XV1l.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. XV1I.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: XV1I.C.2.b.(ii)(a) 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: 123-9E64 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 6 and ≤ 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVlI.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: XVI I . 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. XV1I.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 XV1I.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 18. Point 004: This source is located in an ozone non -attainment or attainment - maintenance area and is subject to the Reasonably Available Control Technology AIRS ID: 123-9E64 Page 7 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division (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) 19. Point 004: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, I 11. E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 20. Point 004: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 21. Point 001 and 003:Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section I I I.G.7.) 22. Point 004:This source is not required to follow a Division -approved operating and maintenance plan. . COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 23. Point 003: The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) Periodic Testing Requirements 24. Point 001: 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 25. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II_C) AIRS ID: 123-9E64 Page 8 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 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. 26. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 27. 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. 28. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final AIRS ID: 123-9E64 Page 9 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 29. 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. 30. 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. 31. 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 tnrfio. 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. 32. 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. 33. 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: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Oil and Gas Corporation AIRS ID: 123-9E64 Page 10 of 18 Colorado Department 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: http://www.colorado.dov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Reportable? Controlled Emissions (Ib/yr) 001 Formaldehyde 50000 191 No 191 003 Benzene 71432 1205 Yes 60 n -Hexane 110543 7349 Yes 367 Toulene 108883 712 Yes 36 224 TMP 540841 602 Yes 30 004 Benzene 71432 22 No NA n -Hexane 110543 197 No NA 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors - Uncontrolled Emission Factors — Controlled Source NOx 14.0 g/hp-hr 1.0 g/hp-hr Manufacturer CO 11.0 g/hp-hr 2.0 g/hp-hr Manufacturer VOC 0.7 g/hp-hr 0.7 g/hp-hr Manufacturer Formaldehyde 0.0205 lb/MMBTU 0.0205 lb/MMBTU AP -42 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6334 Btu/hp-hr, a site -rated horsepower value of 92, and a fuel heat value of 950 Btu/scf. Point 003: Pollutant Emission Factors Uncontrolled Source AIRS ID: 123-9E64 Page 11 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division lb/bbi Condensate Throughput VOC 8.323 E&P TANK n -Hexane 0.125 E&P TANK Benzene 0.022 E&P TANK Toluene 0.013 E&P TANK Ethyl benzene 0.001 E&P TANK Xylenes 0.003 E&P TANK 224 TMP 0.011 E&P TANK Note: The controlled emissions for this point are based on the flare control efficiency of 95%. Point 004: Pollutant Emission Factors Uncontrolled Iblbblloaded - Source VOC 0.1917 AP -42 Benzene 0.0004 PS 14-02 n -Hexane 0.0036 PS 14-02 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 6.35 psia M (vapor molecular weight) = 50 lb/lb-mol T (temperature of liquid loaded) = 520 °R 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: 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: http:lle cfr. g po a ccess . govl Part 60: Standards of Performance for New Stationary Sources AIRS ID: 123-9E64 Page 12 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 63.600-611199 Subpart AA -- Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov.ipacific/cdphe/air-permit-self-certification AIRS ID: 123-9E64 Page 13 of 18 Colorado Department of 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. If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, 11.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed and the permanent language should be removed; also change every instance of 90 in this paragraph to 270. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1A The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other AIRS ID: 123-9E64 Page 14 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/ap/oilgaspermitting.html. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http://www. colorado. qov/cs/Satellite/CD PHE-AP/C BO N/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation AIRS ID: 123-9E64 Page 15 of 16 Colorado Department of Public Health and Environment Air Pollution Control Division the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, II.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § I1.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: AIRS ID: 123-9E64 Page 16 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 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 requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. AIRS ID: 123-9E64 Page 17 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement' of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123-9E64 Page 18 of 18 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01 - Facility Information Kirk Bear .:. 02'February 2016::"" :';::' 30June 20:16 Company Name: County AIRS ID: Plant AIRS ID: ;acility Name: Physical Address/Loca-ion: ype of Facility: What : ndustry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? O Cartnn Monoxide (CO) Section 02 - Emissions Units In Permit Application Verdad Oil'and'Gas Corpb atiiiii '.. 123 9E64::: Pastefak 3N:':'::'::::::. tiWNVv', 62,.T1N; R64W • Ezploratii &R ¢diictiori Welt Pad:.." "• ..• ESE£:&iNatutt3i Gas;Prrdduction: & Rlacess[rig:: O Particulate Matter (PM; Q Ozone (NOx &'CC; AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 .r ................ ...:......... ....• ..... : ..::'::: :::.:::::.::::.. . ..:::Z: i .>....R :::::-s:Yes••::••issuance........ ,.,....... ........... . . ...:::..:::.:: • ::.::.. 002 ... FEISttiComponent Leaks : :-;;.•• . ct :: 'r' : 15WED330 :1::::::::::::.'11tb:.d•:: S; at1�Yr ""'0." • •••••••••.• ............. 003 ,...,.... .::: COnd,e,t1Sat4�:Ster.eB::Tatik. :.......:.4'.:c::.:::'16....330, ::''i:': t:.:::: i:iiiE:K��13ii ?dos ,:.•:.........`EaStia / 0 :�rtitia3...., 'et:::xcJ t t3perafo changed through-put 004 :: :°161AWE0330:.' : '::':::: 1.:•:::::.........Nos::::` ^:7---:(S , ,,,,,,: 1Ytt13t' c: Operator changed through -put • • . .. . ........................ Section 03 - Description of Project ClperatorhasawetlFie,d.sift . it C2 lt�3R ttr E3 f#!:t!( YBa£Eft£18i £5: e: a 4:ebncieriSa tajs,a::ftipitiii6S; icglidthdout:::RIC ..eoi1-ipcessuio?.?„, ;;;;.;; c ti n : s:s{iisw site:Is:nnjor-:a 'aPr:,'qq : iato stilireiitStaki (Ibis s 5hra<wit5g itod 45d:v ter eee, ..;:Operator s ii okltiplAd e„.C tra ti£si£aiteffectit uritets' operatrorts: • 5smttt e.:.:re eri a is R F $ geguit %micah 1,4 section 04 - Public Comment Requirments .s Public Comment Recuired? If yes, why?i uestiritNiataatice A'sjloii:Pefitiit:::.:..: Section 05 - Ambient Air Impact Analysis Requirements Was a Quantitative modeling analysis required?' • If yes, for what pollutants? If yes, attach a copy of Iechnicai Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what programs,and which pollutants here: TILE+V` 3i j,t #aF*1 • .......... Nam.AtthiisiieihtNewSPurceRevilm ::::::::::::::::...::............ Is this stationary source a major source? If yes, explain what programs and which pollutants here: Division Information Engineer: Kirk Bear Control Engineer: Chris Laplante Review Date: 07/06/2016 Application Date: 02/02/2016 Facility Identifiers Permit No. 16WE0330 AIRs County # 123 Weld Facility # 9E64 Potentially located in ozone nonattainment area Facility Type:Iexploration and production facility O Located in the 8 -hour non -attainment area? Administrative Information Q True Minor Q Synthetic Minor for: i' vOC r NOx r co Company Name: Verdad Oil and Gas Corporation Source Name: Pastelak 3N Source Location: SIC: NWNW, S2, Ti N, R64W 1311 Mailing Address Address 1: Address 2: ity, State Zip: Verdad Oil and Gas Corporation 5950 Cedar Springs Road, Suite 200 Dallas, Texas 75235 Person To Contact Name: Phone: Fax: Email: Arthur Beecherl 214 728 1840 Abeecherl@VerdadOil.com I _ Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Pastelak 3N, located in the NWNW, S2, T1 N, R64W, Weld County, Colorado. Point Name Type Control Action 003 Condensate Storage Tanks Condensate Tanks Flare Newly reported source 004 Condensate Loading Loadout None Newly reported source 001 Compressor Engine None Newly reported source Sr C101 verdad, pestelak 3N Engine Information 1EWE0330 Engine date cf rr 2/1/2015 Manufacturer CM Model Number: FX10O Serial Number: 10C::_I MM502"20051 RPNIV 200O Site -rated RPM: 2000 Engine Function Compression berating Mfg's Max. Rated Horsepower @ sea level: 92 lorsepower used for calcuations: 92 BSCF @ 100% Load (btuihp-hr): 633L Site - Rated BSCF @ 100% load (btuihp-hr): 6334 Other Parameters Engine Type 4SRB Asoiratinn naturally aspirated Electrical Generator .Max Site Rating (kw) 0 Max lirslyr of Operation 8760 Calculations Fuel Use Rate @ 100% Load 1120 scf/hr ACTUAL Annual Fuel Consumption 0 ft/lMscf/yr MAX YU I EN I lAL Annua rFueT Consumption 9.810 MMscf/yr REQUESTED Annual Fuel Consumption 9.810 N1Mscf/yr Fuel Heating Value 950.25 btuiscf Emission Control Information This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NCx 14.000 gihp-hr 0.980 gihp-hr 12.4 ipy 0.9 tpy Manufacturer CO 11 000 gihp-hr 1.580 gihp-hr 9 8 tpy 1.8 tpy Manufacturer VOC 0.700 gihp-hr 0.700 g/hp-hr 0.6 ipy 0.6 tpy Manufacturer Formaldehyde 0.021 Ib./MM BTU 0.021 ItiMMBTU 191 lb/yr 191 lb/yr AP -42 Acetaldehyde 0.003 lb!MMBTU 0.003 IbtMMBTU 26 lb/yr 26 lb/yr AP -42 Acrolcin C 003 ly?MMSTU 0 003 IheMMSTU 24 lb/yr 24 Iblyr AP -42 Bervene 0.002 IbiMMBTU 0.302 IbtMMSTU 15 lb/yr 15 lb/yr .AP -42 Regulatory Requirements Ambient Air Imp5Source :s not required to model patted on Division Guidelines/No VAAQS violations expected (see details , Public Comment Rohr. Comment not Required MACT 7Z77 Facility is an area source of HAPs. so engine is rot subject to major source requirements. Engine is new Reg 7 XVII,E.2 Standards (glhp-111!2008 hr) The engine is not sLb;ect to Reg 7 because max engine rating is less than 100 hp, it was constructed after and it is not subject to MA.CT ZZZZ or NSPS JJJJ Reg 7 XVII.E.3 Tine engine is not subject to Reg 7 XVIl.=.3 because the engine is rated less than 500 hp Reg 7 XVI.B pinne NAA ment require applies? located in NAA so subject to Reg 7 XVI.B MACT 2272 (area source) is this engine subject to MACT 7777 area source requirements? "es VSPS JJJJ Is this engine subject to NSPS JJJJ? No Note: J.;JJ requriements are not currently included as permit conditions because ;he reg has not Peen 16WE0330.CP1.xlsm 003 Three 400 barrel condensate storage tanks verdad pestelak 3N Requsted Throughput e 54750 bbl Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 8.323 lb/bbl 227.8 tpy 11.4 tpy E&P TANK Benzene 0.022 lb/bbl 1205 lb/yr 60 lb/yr E&P TANK n -Hexane 0.125 lb/bbl 6844 lb/yr _ 342 lb/yr E&P TANK 224 0.011 lb/bbl 602 lb/yr 30 lb/yr E&P TANK toulene 0.013 lb/bbl 712 lb/yr 36 lb/yr E&P TANK xylene 0.003 lb/bbl 164 lb/yr 8 lb/yr E&P TANK e bent 0.001 lb/bbl 55 lb/yr 3 lb/yr E&P TANK Tank emissions have ECD emissions added on to these totals. 18 ton VOC, 507 n -hex, uncontrolled, 0.9 ton VOC, 25 n -hex controlled Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section H. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) Regulation 2 — Odor Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 6 - New' Source Perfoart aric Standerds NSPS Kb: for storage vessels greater than 19,800 gallons after 7123184. This source is not subject because each tank is less than 19,800 gallons (471 bbl) NSPS Q0f :for:storage vessels in the,naturali:gas production; transmission, and processing,: This:so rce is not subject because each tank:em4less than 6 tpy VOC. Regulation 7 -- VolatiliOruanic: Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non -attainment area.) X1lll.G STATEW$DE.CONTROLS•F:OR•OIL AND GAS OPERATIONS._. • • • (Applicant is currently subject to this since actual uncontrolled emissions are > than:20:•tpy of VOCe):. 0.60 0.03 3.42 0.17 0.30 0.02 0.36 0.02 0.08 0.00 0.03 0.00 004 Hydrocarbon Loadout to Tanker Trucks verdad, pestalak 3N Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded The table of inputs below enables you to calculate the loading loss emissions factor "L". If you choose to use a state default emissions factor, you may enter is directly into cell 814 in units lb/1,000 gallons which will overwrite Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 6.3456 psia Sales Oil A M Molecular Weight of Vap 50 lb/lb-mole AP -42 T Liquid Temperature 519.67 deg. R Field Data L Annual requested Throughput Annual requested VOC emissions Control: None Efficiency: 0.00% NCRPs Component Mass Fraction 4.56 lb/1000 gal 0.19 lb/bbl Benzene 0.0300 n -hexane 0.1700 Toluene 0.0180 Xyienes 0.0050 22.4 TMP 0.0140 e benz 0.0010 Source: 54750 bbl/yr 2299500 gal/yr 10496 lb/yr 5.2 tpy alysis If the operator provides HAP speciation from a stable "sales oil" analysis, enter the mass fraction from this data. Alternatively, if the operator modeled a pressurized oil to develop a site specific emissions factor, enter the modeled mass fraction for the Pressurized oil or Stable Sales Oil Analysis Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1917 lb/bbl - 5.2 tpy 5.2 tpy wt % Benzene 0.0004Ib/bbl 22 lb/yr 22 lb/yr CDPHE n -Hexane 0.0036 lb/bbl 197 lb/yr 197 lb/yr CDPHE Regulatory Review Regulation 3 - APEN and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Does this operator unload less than 6,750 bbis per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section li.D.1.1 No Yes No 005 One 400 barrel produced water storage tank verdad, Pastelak 3N Permit exempt Emissions Calculations Requsted Throughput 21900 bbl Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.262 lb/bbl 2.9 tpy 0.1 tpy CDPHE Benzene 0.007 lb/bbl 153 lb/yr 8 lb/yr CDPHE n -Hexane 0.022 lb/bbl 482 lb/yr 24 lb/yr CDPHE Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) Regulation 2 -- Odor Section l.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. AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)' Permit Number: wE 336 (Leave blank unless APCD has already assigned a permit M&: AIRS ID] Facility Equipment ID: Condensate Storage Tanks Section 01— Administrative Information Company Name: Verdad Oil and Gas Corporation Emission Source AIRS 1D: 1 2.3 t %.04 1 CO [Provide Facility Equipment ID to identify how this equipment is referenced within your organizatiun.] Seance Name: Pastelak 3N Source Location: NWNW S2 T1\ R64W Mailing Address: 5950 Cedar Springs Road, Suite 200 Dallas, TX NAICS, or 1311 SIC Code ----- County. Elevation: ZIP Code: Section 02 — Requested Action (Check applicable request boxes) Weld 0 Request for NEW INDIVIDUAL permit Request for coverage under GENERAL PERMIT ❑ GP01 0 GP08 Request MODIFICATION to existing INDIVIDUAL permit (cheek boxes below) 5,013 Feet ❑ Change process or equipment 75235 [1 Change pennit Bout Person To Contact: Arthur Beecher] Phone Number: (214) 728-1840 E-mail Address: ABeecherb@VerdadOil.corn Fax Number: Section 03 — General Information For ea sources. operation began on This Storage Tank is Exploration R Production Located at• (F•:&P) Site Will this equipment be operated in any NAAQS nonattainment area? Is actual annual average hydrocarbon liquid throughput > 500 bbi%day? ► Are these condensate tanks subject to Colorado Oil and Gas Consen'ation Couunission (COGCC) 805 series rules? If so, submit Form APCD-h05. ► Are you requesting ≥ 6 ton+'yr VOC emissions, or are uncontrolled actual emissions > 6 tordyr? General description of equipment purpose: 3 x 400 bbl steel welded tanks manifolded together for storing condensate until transported off -she Section 04 —Storage Tank(s) Information 54 1-50 Q Condensate Requested Permit Limit: 025,580.9 bbl/year Throughput: Actual: 170,455 bbl/year Average API Gravity of Sales Oil: 41.52 degrees Tank Desien: Fixed Roof Midstream or Downstream (Non-E&tP) Site Yes ❑ No Are Flash Emissions anticipated at these tanks Yes ® No If "yes", identify the stock tank gas -to -oil ratio CI El Change company name Transfer of ownership ❑ Other APEN Submittal for Per mil Exempt/Grandfathered source APEN Submittal for update only (Please note blank APEN's will not he accepted) Addl. Info, & Notes: For new of teconsuucted sources, the projected startup date is: 7 / hours/Normal Hours of Source Operation: 24 day Internal Floating Roof: Actual While Controls Operational: RVP of Sales Oil 470,455 hbVyear 9.1 External Floating Roof ❑ Storage Tank ID # ofLiquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of most recent storage vessel in storage tank (Month/Year) Date Of First Production (Month/Year) 001 All three storage 400 07/2015 002 tanks are in series & 400 07/2015 003 manifolded together. 400 07/2015 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Welt j 05 -123 — 40319 Pastelak 3N - - 0 I 0 - D - - 0 FORM A FCD-205 Page 1 of 2 I 1 2015 7 days/ week E Yes 0.0I7 Yes Yes 52 weeks/ year ❑ No mif iter ❑ No ❑ No Colorado Department of Public Health and Environment Air Pollution Control Division (APCD)This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 per APEN for non- E&P, midstream and downstream sources or $152.90 for up to five (5) APENs for E&P sources and $250 for each general permit registration to: Colorado Department of Public Ilealth & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division. (303) 692-3150 Small Business Assistance Piogratn (SBA P). (303) 692-31,18 or (303)692-3175 APEN forrua: ht:p.: stww.colorado!tor'cdphe:oilgasAPENS Application. status. http.J wwv.colorado.gov"cdphe pennitstanis Pasteiak_AP_Form- APCD-205-Condensate-Tanks-APEN'.doc 34:,836 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)' Permit Number /4 WEnger Emission Source AIRS ID: /2.3 / mg/ 03 Section QS — Stack Information For Midstream sites only) fl �•�,�,Lk, .�j�n�': -�,..� __.:t_i•:. :}�£:;i �a'. :%•:,7 x - tt t l3`.'v:;. _.•_:at... i.-L..s:�.�.-:'..+'�t��n'+n Direction of stack outlet (check one): Exhaust Opening Shape & Size (check nne): Section 07 — Control Device Information ❑ Vertical O Vertical with obstructing raincap O Circular Inner Diameter (inches) = Section (16 —Stack (Source. if no combustionlLocation (Datum & either Lat'Long or UTM) I1"'usmatdi Ditriia' b. A33Z"� 3 c jy� •'h- ' ..' ,a..r:.". ; .j,11T7tI �t� hr 3 • �ir..'pc°..;• ViM �.. ;::.:. 1 ! t;FPt/....v6P�. t• 11 (� 9" trietars t .r:.: �.. °�'• •• • (J iii Northing or; • ♦(attic •''.1:Opd1 t meters or d s• (•.:.c:.-` .. i. • - . •F.arGng •, i - Method of CoIleciion for •••• Dalai(e.g Y ��" . GO. Cro leEaitb o ,•e,j •� . _ 8 40.05816°N 104.62438°W t ❑ Down 0 Other (Describer • Horizontal ❑ Other. Length (inches) — Width (incites) — D Vapor Recovery Unit (VRU) used for control of the Storage Tank(s) Size Make/Model. Requested VOC & HAP Control Efficiency: Annual time that VRU is bypassed (emissions vented): Closed loop system used for control of the storage tank(s) Description: ® Combustion Device used for control of the Storage Tank(s) Rating: 2.89 MMBtu/lu Type: Emission Control Device Makee�lModel Cimarron Energy Inc./ECD-2-48-210 VOC & HAP Control Efficiency: Requested: +ttt,4, °i+ Minimum temp. to achieve requested control: 500 °F Constant pilot light? Yes ] No Describe Any Other. Manufacturer Guaranteed: 98 Waste gas heat content: 1.020 Bru'scf Pilot burner rating: 0.5 fiv to/hr °Au Section 08 — Gas/Liquids Separation Technoloav Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the .storage tank(s)? 150 psig Please describe the separation process between the well and the storage tanks: 3 -phase separator (heater treater) separates gas, condensate, and water. Section 09— Emissions Inventory Information & Emission Control Information Z Emission Factor Documentation attached Data year fur actual calendar yr. emissions below & throughput in Sec. 04 (e.g. 2001): t 2015 • Y..t „r:+t :.:: �:,,,.;;. ; '. �::,,,J� � .,..- , ' • . �Y, tr-• ♦ rL' ;:�olli�t-'�,. ►7- •,� ,.,,L. ; nt - . ti;%, J.,••�•.- • t� . I11.43t4� �''CiDr.:i '-x «r.:w..t ✓�\YYP, y'G t' �� N :Y) -... ••.:.N}al:. ..-�':v{. �. K....� AG'hal• caleftdaT_YCffi '�i1faS70n?.' '� : ' :' � � � A. • • .. .. _ • - Requested Permitted Emissions Emission Factor `: .r'•i s:',- ;', y.t,.• v ,. c's.a. tst`a lied Bests"`-. ., :`� / Unit's �.:x.-:- ._ .!:'Uncotitiutied (Tons/Year)' ': Controlled (Tons/Yeatr) Uncontrolled (Tons/Year) Controlled (Tons/Year). Data Source NOx N/A N/A N/A N/A N/A N/A N/A VOC: •11638• V. sty ltgb1 14.63' 4397.04.72 t$ x.9* ( t ,ti E&P Tanks -,731:44, CO N/A N/A N/A N/A N/A N/A N/A Benzene 6).19' Q,Ofl- - 61.91• 41.91• 4.1e 0,10 p,1 E&P Tanks Toluene 43144 0.013 We. I 0.341 9.01" . 0.70• 041 oat E&P Tanks p 04 Ethylbenzene 9.04+0'001 44r 0:01 0.00- 0:04- o, t 8at18• O,O E&P Tanks Xylenes 0.03' D ,0O3 4/i' 0:09 9:00% iH$ G , ( E&P Tanks 0.09 0,0 n -Hexane Ia04r 0tl1S- 410' 3:43 •6:56 3 tt4 043 0, Z E&P Tanks I,0, 2,2,4-Trirnethylpentane 0:040.O% 1 Afir i, 11.29 0.01• 83s...,• 6,3 1 Q , I E&P Tanks Please use the APCD Nun -Criteria Reportable. Air Pollutant Addendum form to report pollutants not listed above. (Lora Section 10 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage nudcpgegeral permit GP01 or G,P08, I further certify that this source is and will be operated in full compliance with each cunditio'i of the applicable general permit. � o P ,Ainhoarzled ,Latt •::-.w;'• 1,Pa ew...' 11.w:..: /4s Arthur Beecher( Vice President of Operations bia,msof ail' sptheizedPersoo.(Pleasgpriut) ;Tide You may be charged an additional APEN fee for APEN re -submittal due to incorrectly tilled -out APEN or missing information "a 2 Annual emissions fees will be based on octua: emissions tenoned here. Additional Information Required: FORM APCD-205 Attach a pressurized pre-ilash condensate extended liquids analysis, RVP & API analysis of the postflashoil Attach F.&P Tanks input & emtss:on estimate documentation (or equivalent simulation reporthest results) Attach EPA TANKS emission analysis if emission estimates do not contair. workine/breathing losses Page 2 of 2 FEB-22°16 ® • Check box to request copy of draft permit prior 1u issuance. it :Check box to request copy of draft permit prior to public notice Pastclak AP_Form-APCD-205-Condensate-tanks-APEN.doc STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 16WE0331 Verdad Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Drake 8N, located in the SESE, S22, T1 N, R65W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description RICE 001 One GM 92 HP natural gas RICE with emission controls Condensate Storage Tanks 003 Three 400 barrel condensate storage tanks controlled by an enclosed flare Loadout 004 Hydrocarbon loadout to tanker trucks with no control Point 001: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another GM FX10O 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 This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation 3, Part B, Section IIl.G.5). 2. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section 111.G.1 and can result in the revocation of the permit. AIRS ID. 123-9E64 Page 1 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 3. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 4. 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.) 5. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II_A.4) Annual Limits; Facility Equipment ID AIRS Point Tons per Year Emission Type NO),VOC CO RICE 001 0.9 0.6 1.8 Point Condensate Storage Tanks 003 0.9 11.6 4.0 Point Loadout 004 -- 3.9 -- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The 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.) AIRS ID: 123-9E65 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Control Device Pollutants Controlled RICE 001 Catalytic Reduction and Air to Fuel RatioNpx, Controller CO Condensate Storage Tanks 003 Enclosed Flare VOC 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 rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit RICE 001 Consumption of natural gas as a fuel 9.81 MMscf Condensate Storage Tanks 003 Condensate Throughput 43,800 bbl Loadout 004 Condensate Loaded 43,800 bbl Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 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 8, III.E.) (State only enforceable) 11. Point 001: 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 XV1I.8.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4) 12. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) AIRS ID: 123-9E65 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 13. Point 001: This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC < 100 H P Any N/A N/A N/A 100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 >500HP July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 1 Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. 14_ Point 003: This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 15. Point 003: The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: XVII.C.1.a. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. 16. Point 003: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XV11.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. AIRS ID: 123-9E65 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. Point 003: The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to. Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XV11.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 XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. AIRS ID: 123-9E65 Page 5 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 X11.D. or XVI I. 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. XV11.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: 123-9E65 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 5 and 5 12 Annually January 1, 2010 > 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 XI I. 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. XV1I.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVIl.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. XVJI.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 XV1I.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 18. Point 004: This source is located in an ozone non -attainment or attainment - maintenance area and is subject to the Reasonably Available Control Technology AIRS ID: 123-9E65 Page 7 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division (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) 19. Point 004: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 20. Point 004: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 21. Point 001 and 003: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section 111.G.7.) 22. Point 004:This source is not required to follow a Division -approved operating and maintenance plan. . COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 23. Point 003: The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) Periodic Testing Requirements 24. Point 001: 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 25. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) AIRS ID: 123-9E65 Page 8 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 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. 26. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Pad D). GENERAL TERMS AND CONDITIONS 27. 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 11.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 28. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final AIRS ID: 123-9E65 Page 9 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-1 14.5(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. 29. 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. 30. 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. 31. 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 inifio. 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. 32. 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. 33. 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: Kirk Bear Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Verdad Oil and Gas Corporation AIRS ID; 123-9E65 Page 10 of 18 Colorado Department 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 Al Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pac ename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS . Point Pollutant CAS # Uncontrolled Emissions (Ib/yr,' Reportable? Controlled Emissions (Ib/yr) 001 Formaldehyde 50000 191 No 191 003 Benzene 71432 1051 Yes 53 n -Hexane 110543 6369 Yes 318 Toulene 108883 613 Yes 31 224 TMP 540841 482 Yes 24 004 Benzene 71432 13 No NA n -Hexane 110543 118 No NA 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors - Uncontrolled Emission Factors — Controlled Source Nflx 14.0 g/hp-hr 1.0 g/hp-hr Manufacturer CO 11.0 g/hp-hr 2.0 g/hp-hr Manufacturer VOC 0.7 g/hp-hr 0.7 g/hp-hr Manufacturer Formaldehyde 0.0205 lb/MMBTU _ 0.0205 lb/MMBTU AP -42 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6334 Btu/hp-hr; a site -rated horsepower value of 92, and a fuel heat value of 950 Btu/scf. Point 003: Pollutant Emission Factors Uncontrolled Source AIRS ID: 123-9E65 Page 11 of18 Colorado Department of Public Health and Environment Air Pollution Control Division Ibib bl Condensate Throughput VOC 915 E&P TANK n -Hexane 0.134 E&P TANK Benzene 0.024 E&P TANK Toluene 0.014 E&P TANK Ethyl benzene 0.001 E&P TANK Xylenes 0.004 E&P TANK 224 IMP 0.011 E&P TANK Note: The controlled emissions for this point are based on the flare control efficiency of 95%. Point 004: Pollutant Emission Factors Uncontrolled Iblbbl loaded - Source VOC 0.236 AP -42 Benzene 0.0004 PS 14-02 n -Hexane 0.0036 PS 14-02 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*M1T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 6.35 psia M (vapor molecular weight) = 50 lb/lb-mol T (temperature of liquid loaded) = 520 °R 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: 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: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources AIRS ID: 123-9E65 Page 12 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.qov/pacific/cdphe/air-permit-self-certification AIRS ID: 123-9E65 Page 13 of 18 Colorado Department of 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. If the facility is a major stationary source for NANSWPSD and this engine does not have limits below significance levels in Reg 3, part D, II.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed and the permanent language should be removed; also change every instance of 90 in this paragraph to 270. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of ail Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other AIRS ID: 123-9E65 Page 14 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so 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 pen -nit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http://www.colorado.gov/cs/Satellite/CDPHE-AP/CBON/1251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation AIRS ID: 123-9E65 Page 15 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, pad D, II.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D_2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Pad 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3,2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: AIRS ID: 123-9E65 Page 16 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 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 requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. AIRS ID: 123-9E65 Page 17 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123-9E65 Page 18 of 18 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package tt Received Date: Review Start Date: Section 01 - Facility Information • ICiifi: Bear; is - .. 343843. .. 02 February 7014:: • 30dddne 2015 Company Name: vesdad Oil and Gas Corporation. County AIRS ID: :123.• Plant AIRS ID: .9E65';:'.`"''.': Facility Name: Drake -3 Physical Address/Location: 5F5F; `S2+2, 1N,„R6SWV. ,. Type of Facility: What industry segment? EEafora#Ga§:i?touctirrtt&.P;55irfb : . Y............ Is this facility located in a NAAQ5 non -attainment area? .................... If yes, for what pollutant? Q Carlin Mctzide (CO) 0 °a'tcdlate Matter (PM) ❑ Oat :hox % Vit.) ESf(ZR1tati I3:&.P.rociaictbn'Well•ead::::.:::::::::::::::::::: :::::: Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 ::::::..:::.: _...........:.. -: ' ::::.::a4atural Gas:RICE :' ::::::::: ` 1 '.lwU.l4yi'LQQQlGI . .:.: :..::.r... :Yes:; .".° l ':16WE0331 ' 1 :...... ......:...:..:.. .......... .:::::::fmtt:#rutiai :issdance • :• operator keeps ":::::.: insisting engine HP:'evzn though iF;is:. 196.E P 002 ..... ... .. F.ug true 6ompotten:fi,eaics1 .l .l ... .. .. .. :.'::. .:• ::::::::.:::::::..:.: . . 'Cali lied' ' : 003 ..:Caryblesisate:$limtage•Tat)k .._ ....................................:::.::. . ' 3 : :T6WEO331 1 ... , :: •:.• •;...Yes:•::.:' •EYf x ' Ui3 :::: .e., :sisSi6 ::=.:-..1 Aerator changed.. thcbixgh-put .:.. .: ......,;.:: . .. iv.vcar:bor L.C(uidiQ?dt ::::::::::::No :::::............ 1 :. • Na :F.LYi45irRiftli�ta;; -::.::::1anuant f--si:: Operator changed through -put - ')900:'f)Cnn ' ... "KXXX,.. ... :' ...• •O,. •,.,.. Onfl'alnf . .,.-.,. ..-., ... if lf: UflOnllf lllf..... .....: ...:...1Of10:) a..,r.W....,/\' ., :iI`(Hi4. .+Fh)':H%QO0000(X)(lp(, ..M' ..••••• .. ... ....... .. ..... ..... .. .. .. ... Section 03 - Description of Project Orator hat a:4YeE}heacfsltjsllglii iAepar"attorx.otcurring,iri the:heatoeCl eiiiiSite F'N•: `;cgrit fls tetartks;;fugttiuenjanct:ioadoa. :::Cot'T�if2SSfOrii ::::.:: • `_:...:.'•:....................................:..............:..........' .. .. .....,...:.........:. ......... . ................. •Submitted caiculatiorsxi£ecavjriag•pF kiiitid:watetrreedsAPEN;:none:subantted%j?.te nested::. . Operator has n; tsi wIedg ;attolarado-ku{e 1& €a1)s 'aTcui ti r:: aikedthraugh ;mostfstep :................. Section 04 - Public Comment Requirments Is Public Comment Required? ::::;;; ,;; :""':',,,,, s' :<><>:><:::;= If yes, why? REgl7estijig?$SdtjtjeGc tiAitft5YPermif : :: ; section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what. programs and which. pollutants here: :;:Title. '��I £'.2fEi�its pion•Attainrt erg *Uwe. ex+:NODi Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention.of,Significant.Deterioration (PSD}FSO2, NUx,.CO, VOC, PM 2:5) PM1Q' "' Title V Operating Permits,(OP) :502, NO',.CO, VOC,.PM2i5,.PM1C;TSP,:HAll's :. .. : Non-AttaynmentNew S. urce ReviS1NAN5R): NOx' VOC " ..... Division Information Engineer: Kirk Bear I Control Engineer: Chris Laplante Review Date: 07/05/2016 Application Date: 02/02/2016 Facility Identifiers Permit No. 16WE0331 AIRs County # 123 Weld Facility It 9E65 Potentially located in ozone nonattainment area Facility Type: exploration and production facility El Located in the 8 -hour non -attainment area? Administrative Information Q True Minor Q Synthetic Minor for: R voc r NOx 3 CO Company Name: Verdad Oil and Gas Corporation Source Name: Drake -5 Source Location: SIC: SESE, 522, 1N, R65W 1311 Mailing Address Address 1: Address 2: ity, State Zip: Verdad Oil and Gas Corporation 5950 Cedar Springs Road, Suite 200 Dallas, Texas 75235 Person To Contact Name: Phone: Fax: Email: Arthur Beecher! 214 728 1 840 Abeechert@Verdad©il.com Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Drake -5, located in the SESE, S22, 1 N, R65W, Weld County, Colorado. Point Name Type Control Action 001 RICE Engine None Newly reported source 003 Condensate Storage Tanks Condensate Tanks Flare Newly reported source 004 Loadout Loadout None Newly reported source 001 verdad, Drake-5,16WE0331 Engine Information Engine date of m 211;20 - Manufacturer: GM Model Number: FX10Q Serial Number. 1 C'C H Mtv;510210062 RPM: 4000 Site -rated RPM: 4000 Engine Function Compression berating Mfg's Max. Rates Horsepower Q sea level: 92 Horsepower used for calcuations: 92 BSCF ;6), 100% Load (btu/hp-hr)- 6334 Site - Rated BSCF @ 100% load (btu/hp-hr): 6334 Other Parameters Engine Type 4SR8 Aspiration naturally aspirated Electncal Generator Max Site Ratine lkwl 0 Max firs/yr of Operation 8760 Calculations Fuel Use Rate @ 1CO% Load 613.24 scf/hr ACTUAL Annual Fuel Consumption 9 81 MMscf/yr MAX POTENTIAL Annual Fuel rnns urnatinn 5.37 MMscf/yr REQUESTED Annual Fuel Consumption 5.37 MMscf/yr Fuel Heating Value 950.25 btu/scf Emission Control Information This engine shall be equipped with a non.selective catalytic reduction (NSCR) system and air -fuel ratio control Emissions Summary Table Pollutant Uncortrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 14000 g/hp-hr 0.980 gihp-i-r 12.4 tpy. 0.9 tpy Manufacturer C 0 11 000 g/hp-hr 1.980 gihp-^r 9.8 tpy 1.8 tpy Manufacturer VOC 0.70C g/hp-hr C.700 g/hp-^r 0 6 tpy a 6 tpy Manufacturer Formaldehyde C.021 lb/MMBTU 0.021 Ib/MMBTU 105 ild/yr 105 w lb/yr AP 42 Acetaldehyde 0.003 lb/MMBTU 0.003 Ib/MMSTU 14 lb/yr 14 lb/yr AP -42 Acrolem 0.003 Ib/MMBTU 0.003 Ib/MMBTU 13 lb/yr 13 lb/yr AP -42 Benzene 0.002 lb/MA/IBTU 0.002 Ib/MMBTU B lb/yr 8 Ib/yr AP -42 Regulatory Requirements Ambient Air Imp‘Source is not required to mode. bases cn Division Guide ines/No NAACS violations expected +see details of Public Comment Public Comment not Recuired MACT 7777 Facility is an area source of HAPs, so engine is not subject to major source requirements. Ergine is new Reg 7 XVII. E.2 Standards (Who- hr) The engine is not subject to Reg 7 oecause max engine rating is less 1/112008 and it is not subject to MA.CT Z777 or NSPS JJJJ than 100 hp, t was constructed after Reg 7 XVII.E.3 The engine is net subject to Rea 7 XVII. E.3 because the engine is rates iess than 500 hp Reg 7 XVI.B (Ozone NM requirements) applies? located in NAA so suciect :o Reg l XVI.B MACT Z2ZZ (area source) Is this engine subject to MACT 7777 area source requirements? Yes NSPS JJJJ Is thus engine suoject to NSPS JJJJ? I_ I No Note JJJJ requriements are not currently included as permit conditions because the reg has clot been 16WE0331.CP1.xlsm 003 Three 400 barrel condensate storage tanks verdad, Drake -5, 16WE0331 Requsted Throughput 43800 bbl Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 9.75 lb/bbl 213.5 tpy 10.7 tpy E&P TANK Benzene 0.024 lb/bbl 1051 lb/yr 53 lb/yr E&P TANK n -Hexane 0.134 lb/bbl 5869 lb/yr 293 lb/yr E&P TANK 224 toulene xylene e benz 0.011 lb/bbl 482 lb/yr 24 lb/yr E&P TANK 0.014 lb/bbl 613 lb/yr 31 lb/yr E&P TANK 0.004 lb/bbl 175 lb/yr 9 lb/yr E&P TANK 0.001 lb/bbl 44 lb/yr 2 lb/yr E&P TANK Tank emissions have ECD emissions added on to these totals. 18 ton VOC, 507 n -hex, uncontrolled, 0.9 ton VOC, 25 n -hex controlled Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section I1. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes_ (only needed if using flare) Regulation:2—or:.::.::::: Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19.800 gallons (471 bbl) NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. Regulation 7 — Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non -attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS. (Applicant is currently subject to this since actual uncontrolled emissions are > than 20 tpy of VOC.) 004 Hydrocarbon Loadout to Tanker Trucks verdad, Drake -5, 16WE0331 Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded Factor i Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 5.4032 psia Sales Oil A M Molecular Weight of Var 50 lb/lb-mole AP -42 T Liquid Temperature 520 deg. R Field Data L Annual requested Throughput Annual requested VOC emissions Control: None Efficiency: 0.00% NCRPs Component Mass Fraction 3.88 lb/1000 gal 0.16 lb/bbl Benzene T n -hexane Source: Pressurized oil Emissions Summary Table 32850 bbl/yr 1379700 gal/yr 5359 lb/yr 2.7 tpy alysis If the operator provides HAP speciation from a stable "sales oil" analysis, enter the mass fraction from this data. Alternatively, if the operator modeled a pressurized oil to develop a site specific Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.2360 Ib/bbl 3.9 tpy 3.9 tpy PS 14-02 Benzene 0.0004 lb/bbl 13 lb/yr 13 lb/yr PS 14-O2 n -Hexane 0.0036 lb/bbl 118 lb/yr 118 lb/yr PS 14-02 Regulatory Review Regulation 3:-:APEN and Permitting Requirements . Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.I Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.I No Yes No 005 One 400 barrel produced water storage tank verdad, Drake -5, XP Permit exempt Emissions Calculations Requsted Throughput 10950 bbl Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.262 1.4 tpy 0.1 CDPHE Benzene .lb/bbl 0.007.1b/bbl 77 lb/yr _ 4 .tpy lb/yr CDPHE n -Hexane 0.022lb/bbl 241 lb/yr 12 lb/yr CDPHE Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section Il. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) ReguiationliLlOdor Section f.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. AIR POLLUTANT EMISSION NOTICE (ADEN) & Application for Construction Permit — Condensate Storage Tank(s)' Permit Number: ! ip w'E.O33 Facility Equipment ID: Condensate Storage Tanks Section 01— Administrative Information Company Name: Verdad Oil and Gas Corporation }Leave blank unless APCD has already assigned a permit 4 & AIRS ID] Emission Source. AIRS ID: 113 / eitEb5 / 003 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Source Name. Drake 8N NAICS, or 1311 SIC Code: Source Location: SESE S22 TIN R65W County: Weld Mailing Address: 5950 Cedar Springs Road, Suite 200 Dallas, TX Elevation: 5,075 Feet ZIP Code 75235 Person To Contact: Arthur Beecher) Phone Number (214) 728-1840 E-mail Address: ABeecherlaVerdadOil.com Fax Number: Section 03 — General Information Fur existing sources, operation began on: This Storage Tank is Exploration & Production Located at: (E&1') Site Will this equipment be operated in any NAAQS nonattairuuent area? Is actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? ► Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ► Are you requesting ? 6 ton/yr VOC emissions, or are uncontrolled actual emissions a 6 toulyr? General description of equipment purpose: 3 x 400 bbl steel welded tanks manifolded together for storing condensate until transported off -site Section 04 -- Storage Tan k(sl Information ❑ Midstream or Downstream (Non-E&P) Site ® Yes ❑ No ❑ Yes No Section 02 - Requested Action (Check applicable request boxes) ❑ El Request for NEW INDIVIDUAL permit Request for coverage under GENERAL PERMIT ❑ GPO} ❑ GP08 Request MODIFICATION to existing INDIVIDUAL permit (check boxes below) ❑ Change process or equipment ❑ Change permit littut U CI Change company name Transfer of ownership El Other ❑ APEN Submittal for Permit Exempt/Grandfathered source ❑ APEN Submittal for update only (Please note blank APEN's.will not he accepted) Addl. Info. & Notes: For new or reconstructed sources, the projected startup date is' 4 Normal Hours of Sow-ce Operation: 24 hours/ day Are Flash Emissions anticipated at these tanks If "yes", identify the stock tank gas -to -oil ratio: Condensate Throughput: Average Tank Design: Requested Permit Limit. Actual: API Gravity of Sales Oil: Fixed Roof: ❑Y 43 Sacs 299,308' bbllyear I59,8?(t— bbllyear 40.57 degrees Internal Floating Roof: Actual While Controls Operational: 159,87(1•-.bbliyear RVP of Sales Oil 8.1 External Floating Roof: ❑ r-- —__ Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank r 1 otal Volume of Storage Tank (bbl) - , Installation Date of most recent storage vessel in storage tank (Mouth/Year) — Date Of First Production (Month/Vear) 001 .An three storage 401) 04/2015 002 tanks are in series & 400 04/2015 003 manifolded together. a 400 - 04/2015 a Wells Serviced by this Storage Tank or Tank Vatte.ry (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 41540 Drake 8N ►2{ - - ❑ - O - - ❑ - - ❑ FORM APCD-205 1 Page 1of2 / 21 I 2015 7 days! 52 weeks/ week year Yes ❑ No 0.0164 rn'/liter Yes ❑ No Yes ❑ No Colorado Department of Public Health and Environment Air Pollution Control Division (APCD}This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fud type, etc) Mail this Form along with a check for S152.90 per APEN for nun- E&P, midstream and downstream sources or $152.90 for up to five (5) APENs for E&P sources and $250 for each general permit registration to: Colorado Department of Public Health & Environment APCD-SS-B1 43011 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN fonu- Aiir Pe nuti:on Control Division: (303) 692-3150 Small Business Assistance Program (SBAP). (303) 692-3148 or (303)692-3175 APEN forms: litto://www.colotadom:ly,cdplic nilgasAF'E_N.S Applicatigh status. littyi:l nov.ccd.p1.- Uemlitstatus •r Drake_AP_Form-APCD 255 -Condensate -Tank.¢ -A PEN. clue 343832 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit Condensate Storage Tanl:(s)' Permit Number: 1(, Section 05 —Stack information (For Midstream sites only) +-,sr -'ti-` w•4. • Y`^Y�' i w t'f L, .r': '�;Y: .-�.-:::�•t•, Fir ^' )>:•;v�:� :a'. 'D � c.: ytL :1 F -, • 't - :mi.., di' !ti n: r;: .�, ':'lt'• t ',1--• - �'' ♦ -yam ,,$��^�,'yy�} `�fy; �,.{.;.,•'.�Y.7GY�_ �`�I-"��iW. ♦ .f:..� n :•: :. iK Y • a ..,,. '.'k�'tr.^\ i.. jit�. T. .. '^,:'•'�'yab.„ ♦ :. s' - ID .[ �W�(�. s�.r�. _(u. n•!'„\'. •J \ J it :t x a-♦'+ :z t. I Vii, n .-w\�'�.Y .i�:.- • •�-�l •Ido hate t6i {.' _ F..r •i'N• .. .• -. milimmis Direction of stack outlet (check one): ❑ Vertical ❑ Vertical with obstructing ;aincap Exhaust Opening Shape & Size (check one): ❑ Section 07 --Control Device Information Circular Inner Diameter (inches) — Emission Source AIRS ID: / 2.3 / 946 5 / 003 Section 06 —Stack (Source, if no combustion) Location (Datum & either Lau'Long or UTM'i) Flonioiriat Datur» (NADV h1AD83, - •r: t"" WCifi84'} :: - . . VMS . Y ' . (1 'cic1.3) :, Fasting or :'. .... . Longitude ;:: (meters or degreit) UNorthing or VMS Latitude :: 1 (meters or degrees) - • .:. Method of Collection for , ''.`I.otalion Data (e.g. reap,'..:' , , GPS, Googlefirdt) . 40.028998°N 104.627883°W Vapor Recovery Unit (YRU) used for control of the Storage Tank(s) Stze: Make/Model Requested VOC & HAP Control Efficiency: % Annual time that VRU is bypassed (emissions vented) ❑ Closed loop system used for control of die storage tank(s) Description: ❑ Horizontal D Down ❑ Other. Length (inches) = ❑ Other (Describe)' Width (inches) = Combustion Device used for control of the Storage Tanlc(s) Rating: 2.86 MN 113tu/ltr Type: Emission Control Device MakeiModel Cimarron Energy lnc-/ECA-2-48-210 VOC & f EAP Control Efficiency Requested:i9S 0/ Manufacturer Guaranteed: 98 Minimum temp to achieve requested control: 500 'I' Waste gas heat content 1,020 Bttvscf Constant pilot light? ® Yes ❑ No Pilot bunter rating.. 0.5 tvEyEBtuihr O Describe Any Other. Section 08 — Gas/Liquids Separation Technology information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 155 psig Please describe the separation process between the well and the storage tanks: 3 -phase separator (heater treater) separates gas, condensate, and water. Section 09— Emissions Inventory information & Emission Control information Emission Factor Documentation attached Data near for actual calendar yr. emissions below & throusbptt in See. 04 (e_,g. 2007): Pollutant' . 2..-1. .:•- '• • • • . :.. .. Emission Factor • • :.� ` ' .:. Actual Requested Permitted Emissions Emission Factor r Uncontrolled Bain' Uriitti-• . Uncoritrolfed (Tonssifeisr) � . Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) Data 8ourt:a NOx N/A N/A N/A N/A N/A N/A N/A VOC X5.35-�.� mod' . � r 982.63• 35.G5• 1966.iS1 �)�js X439-- 1 Cl , E& P Tanks CO NIA N/A N/A N/A N/A N/A N/A Betnzene r '0.39- Q rot i 1 0,65- 8.01. -Kt 0 ,"5— *At, Q , ( E&P Tanks Toluene -0.14 0ION 44. _ 441 0.7F .&o+ a , ( E&P Tanks -0.38 a 3 - Ethylbeuzene 09+ 0%001 4,0si 509 13:e4 0 , % 51.00- 0. O E&P Tanks xyleoes 8.03 o ,00uf Ph' .0.1S 0 r t o>00 0 . Q E&P Tanks t1.I0 0.00' n -Hexane %;R3 0 , t 3 ti 9fr 3.57- (:419 6.1A 1.0 043. 6 .2.. E&P Tanks 2,)_,4-Trimethylpentane 0:'09•' O ,0% j' f 0,81. 0 8.(1t- 0 , I E&P Tanks 030- -1.56- , 3 Please use the APCD Nun -Criteria Reportable Air Pollutant Addendum form to report pollutants not:listed above. Section 10 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this applicaltoots complete, true and correct. If this is a registration for coverage under general permit GP01 or GP08, 1 further certify that this source is and will he operated in full compliance with each condition of the applicable general permit %/1 tra.ttr� ,16 Arthur Bceeherl Vice President of Operations D . e.. , _-, , ,;, l Name of Legally Authorized Person (Please: print) ' Title antie8alt�'_�tzfhor�od to SuPPy. Bata.:............ ...� _ ...... _. .. - ... You may be charged an additional APEN fee for APEN re -submittal due to incorrectly filled -out APEN or missing information ` Annual emissions fees will he based on actual emissions rcoorted here. Additional Information Required: N ❑ Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses Attach a pressurized pre -flash condensate extended liquids anajysis. RVP & API analysts or the post -flash oil Attach E&P Tanks input & emission estimate documentation (or equivalent simulation report/test results) ® '''Check hax to request copy of draft pernitprior to issuance. ! ® t Check box to request copy of draft permit prior to oublic noricel FORM APCD-205 Page 2of2 Drake: AP_Furm-APCD-20S-Condensato-Tanks-APEN.doc Permit Number: /6 14/60,337_, [Leave blank unless APCD has already assigned a permit & AIRS ID] Facility Equipment 113: Condensate Storage Tanks [Provide Facility. Equipment ID to identify now this equipment is referenced within your organization.) AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1 Emission Source AIRS ID; /Z3 , 19£a' 063 Section 01 — Administrative Information Company Name: Verdad Oil and Gas Corporation Source Name: Young 8N Source Location: NENE S28 TIN R65W Mailing Address: 5950 Cedar Springs Road, Suite 200 Person To Contact E-mail Address: Dallas, TX NAICS, or 1311 S 1C Code: County: Weld Elevation: 5,073 Fect ❑ Change process or equipment O Changc company name ZIP Code: 75235 Section 02 — Requested Action (Check applicable request boxes) Arthur Beecheri Phone Number: ABeecherl(?%'erdadOil.com Fax Number: Section 03 — General Information For existing sources. operation began on. This Storage Tank is Located at: Will this equipment be operated in any NAAQS nonattainment area? Bj Yes O No Are Flash Emissions anncipated at these tanks Is actual annual average hydrocarbon liquid throughput y 500 bbl: day? ❑ Yes ® No If "yes", identify the stock tank gas -to -oil ratio: Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Fonn APCD-105. I► Are you requesting ? 6 ton/yr VOC emissions, or are uncontrolled actual emissions ? 6 ton%yr? General description of equipment purpose: 3 x 400 bbl steel welded tanks manifolded together for storing condensate until transported off -site Section 04 — Storage Tank(s) Information 5t{9 -CU Condensate Requested Permit Limit: 2254580 hbl/year Throughput: Actual: +8(456 bbl/ycar Actual Wane Controls Operational: RV'P of Sales Oil Exploration & Production (E&P) Site (214) 728-1840 D Midstream or Downstream (Non-E&P) Site Request for NEW INDIVIDUAL permit Request for coverage under GENERAL PERMIT ❑ GPOI ❑ GP08 ❑ Request MODIFICATION to existing INDIVIDUAL permit (check boxes below) ❑ Change permit limit ❑ Transfer of ownership ❑ Other APEN Submittal for Permit Exempt/Grandfathered source APEN Submittal for update only (Please note blank APEN's will not be accepted) Addl. Info. & Notes: For new or reconstructed sources, die projected startttp date is. 4 24 hours/ day Normal I lours of Source Operation: / 22 / 2015 days/ week 52 weeks/ year Yes ❑ No 0.0176 m°,niter Yes [i No Yes ❑ No Average APE Gravity of Sales Oil: 48.78 degrees Tank Design. Fixed Roof: Internal Floating Roof: 170,055 bbl/vcar 8.6 ❑ External Floating Roof: ❑ Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of most recent storage vessel in storage tank (Montla/Y'ear) Date Of First Production (Month/Year) 001 _ MI three storage 400 '•, 04/2015 002 tanks are in series & 400 04/2015 003 _ manifolded together. 400 I 04/2015 Wells Serviced by 4itis Storage Tank or Tank Flattery (TAP Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 40511 Young 8l; ►2� - 1 • - l ❑ - ■ FORM APCD-205 Page 1 of 2 Colorado Department of Public Health and Environment Air Pollution Control DivisionlAPCD)This notice is valid for five (5) years. Submit a revised APE!' prior to expiration of 5ve-year term, or when a signifi:ant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 per APEN for non- E&P, midstream and downstream sources or S152.90 for up to five (5) APENs for E&P sources and $250 for each general permit registration to: Colorado Department of Public Health & Environment APCD-SS-BI 4300 Cherry Creek Drive South Denver.' CO 80246-1530 For guidance on how to complete this API :N form. Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303)692-3175 .APEN forms: hugs.'/w'ww.colorado.eovcJ.phe:oilaasAPENS Application status: Imp /`w wµ . co1 orado. so t__c dpl i _ : pcnmitctatus • Young_.4P—Forrri-APCD-205-Condensale-Tanks-APFN.doc 343840 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 16WE0332 Verdad Oil and Gas Corporation Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Drake 8N, located in the SESE, S22, T1 N, R65W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description RICE 001 One GM 92 HP natural gas RICE (SN 10CHMM502250018) with emission controls Condensate Storage Tanks 003 Three 400 barrel condensate storage tanks controlled by an enclosed flare Loadout 004 Hydrocarbon loadout to tanker trucks with no control Point 001: This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another GM FX10Q 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation 3, Part B, Section III.G.5). 2. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after commencement of operation or issuance of this permit, whichever comes later, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe_state.co.uslapldownloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section lII.G.1 and can result in the revocation of the permit. AIRS ID: 123-9E66 Page 1 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 3. Within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 4. 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.) 5. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 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 x VOC CO RICE 001 0.9 0.6 1.8 Point Condensate Storage Tanks 003 0.9 11.6 4.0 Point Loadout 004 -- 4.9 -- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The 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 I!I.E.) AIRS ID: 123-9E66 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Facility Equipment ID AIRS Point Control Device Pollutants Controlled RICE 001 Catalytic Reduction and Air to Fuel Ratio Controller NOx, CO Condensate Storage Tanks 003 Enclosed Flare VOC 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 rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit RICE 001 Consumption of natural gas as a fuel 9.81 MMscf Condensate Storage Tanks 003 Condensate Throughput 43,800 bbl Loadout 004 Condensate Loaded 43,800 bbl Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 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. Point 001: 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) AIRS ID: 123-9E66 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 13. Point 001: This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XV1I.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A - N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ?500HP July 1, 2007 July 1,2010 2.0 1.0 4.0 2.0 1.0 0.7 i 1 Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. 14. Point 003: This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 15. Point 003: The condensate storage tanks covered by this permit are subject to Regulation 7, Section XV1I.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. 16. Point 003: The flare(s) covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: 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. AIRS ID: 123-9E66 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. Point 003: The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(a) Control requirements of Section XVII.C.1.b. must be achieved within ninety (90) days of the date that the storage tank commences operation. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XV1I.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; XV1I.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; XV1I.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 XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. AIRS ID: 123-9E66 Page 5 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 XI I. 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. XV1I.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: 123-9E66 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XV1I.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. 18. Point 004: This source is located in an ozone non -attainment or attainment - maintenance area and is subject to the Reasonably Available Control Technology AIRS ID: 123-9E66 Page 7 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division (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) 19. Point 004: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, Ii1.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 20. Point 004: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 21. Point 001 and 003:Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III_G.7.) 22. Point 004:This source is not required to follow a Division -approved operating and maintenance plan. . COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 23. Point 003: The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) Periodic Testing Requirements 24. Point 001: 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 25. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) AIRS ID: 123-9E66 Page 8 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 (NCO 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. 26. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 27. 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 l I. B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 28. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final AIRS ID: 123-9E66 Page 9 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 29. 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. 30. 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. 31. 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. 32. 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. 33. 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: Kirk Bear Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Verdad Oil and Gas Corporation AIRS ID: 123-9E66 Page 10 of 18 Colorado Department 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 Al Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.govics/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (ib/yr) Reportable? Controlled Emissions (Ib/yr) 001 Formaldehyde 50000 191 No 191 003 Benzene 71432 1314 Yes 66 n -Hexane 110543 7008 Yes 350 Toulene 108883 767 Yes 38 224 TMP 540841 602 Yes 30 004 Benzene 71432 22 No NA n -Hexane 110543 197 No NA 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors - Uncontrolled Emission Factors — Controlled Source NOx 14.0 g/hp-hr 1.0 g/hp-hr Manufacturer CO 11.0 g/hp-hr 2.0 g/hp-hr Manufacturer VOC 0.7 g/hp-hr 0.7 g/hp-hr Manufacturer Formaldehyde 0.0205 ib/MMBTU 0.0205 lb/MMBTU AP -42 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 6334 Btu/hp-hr, a site -rated horsepower value of 92, and a fuel heat value of 950 Btu/scf. Point 003: Pollutant Emission Factors Uncontrolled Source AIRS ID: 123-9E66 Page 11 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division lb/bbl Condensate Throughput VOC 8.45 E&P TANK n -Hexane 0.128 E&P TANK Benzene 0.024 E&P TANK Toluene 0.014 E&P TANK Ethylbenzene 0.001 E&P TANK • Xylenes 0.004 E&P TANK 224 TMP 0.011 E&P TANK Note: The controlled emissions for this point are based on the flare control efficiency of 95%. Point 004: Pollutant Emission Factors Uncontrolled Iblbblloaded - Source VOC 0.18 AP -42 Benzene 0.0004 PS 14-02 n -Hexane 0.0036 PS 14-02 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*MfT S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.87 psia M (vapor molecular weight) = 50 Ibllb-mol T (temperature of liquid loaded) = 520 °R 6) 1n 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: http://ecfrgpoaccess.qov/ Part 60: Standards of Performance for New Stationary Sources AIRS ID: 123-9E66 Page 12 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ-- Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123-9E66 Page 13 of 18 Colorado Department of 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 O, 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 ADS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, ll.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed and the permanent language should be removed; also change every instance of 90 in this paragraph to 270. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other AIRS ID: 123-9E66 Page 14 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing compressor engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so 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. Ail portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: http://www.colorado.qovics/Satellite/CDPHE-AP/CBON/1 251596520270. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation AIRS ID: 123-9E66 Page 15 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements If the facility is a major stationary source for NANSR/PSD and this engine does not have limits below significance levels in Reg 3, part D, II.A.42 (e.g., 39 tpy NOx limit, etc.), permanent replacements are not allowed 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: AIRS ID; 123-9E66 Page 16 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NO X CO VOC 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 500≤Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section l.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, § LB (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. AIRS ID: 123-9E66 Page 17 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123-9E66 Page 18 of 18 PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Cate: Section 01- Facility Information Kiri: Bear 02 February 20,tfi:; :..: :....: 3U June 2016 . ...... . Company Name: County AIRS ID: Plant AIRS 1O: Facility Name: Physical Address/Location: Type of Facility: W'iat industry segment? Is th;s facility located :n a NAACZS non-artainment area? ii ; B3cFi i If yes, for what pollutant? ❑ Carta n Monoxide (CO) O Particulate Matter (7,m) VerdadOil and Gas Corgi oraUon- 123 9E66 . Young RN ............. .. NENE,S2R, TiN, R65W.. • xpin ratiiii:&:F,iott'u'ctictiti3YEil:Wad:::::::::::::::::::::::::::::::::::::::::''''' ::. %)if Fc NatEFFdl u;Pft5iUsct(4ii4 __' .:: ::. Section 02 - Emissions Units in Permit Application Dion (Nth & vCC AIRS Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 •:::::::::c::...:... ......... ........... .::;:i:;.. Natural;Gas RtCE`,;a:' .'' ::.:::x.x :::::: ....... . 1 :.• ,.......... ,.,...,. Y- " """ :Pe.rxnit itt'ti afi;;s: rsstrance.,:.,:.:, 'operator::#ravides�:' ' proof at:enging HP:: •:: 002 :.::,:fugitive r3arrspeJrtenC:L*~afFs ":16tnfE0392.:: 1 '". """ '`i`j -,•:: • 'as: ' fi riefiatibrt;'.::•: :..:.. 003 ::...°. ............................................................... 16WE03.32 ...........,.:.... 1..' °:° ...:;:::, "::::Y' 3 ...,.. . r�:. Parfxrit J itial:::Giperatar . ,.. .�sr 3tia ...\.HHH6,' (r ckianged:. . ..:.: r 004 ::::::: ::.............. .O,10000Hti ,: .J;) .. ..,...,.,.,�,.,.. ,.:: .:::a��Y dtipgat§,,,iViiitio in ... , ,1: ,,. .................. :-:::":no,,,,,,,,, .. . Y6',A,E0332'.: .. ° 1 ::' :.: .. ,,,:a�la• ...„. :::::: ,.,., EJ7rik t ::::: fssrraxrce, •..... , ,... . . , ...,.. ... . • ...:... ..:i... . ::::;:.i :iii': ....... - ........... ..::. • .... ..... .. 7MifJ� k1U ...,.O0( 1. 1Hc3 , :.••:;:::•••••••." .:. .,.,,, • . � ................ ..... 1. .. • • ,.. .....,. .. .. ::'� ..' :..,.,. ; ;C ^.O'...: •'::Y•:Y•..,..... Section 03 - Description of Project :;.iog?ratar:has awe##hit :corriixcessionaa site wii}ti separfIPA:'occurring: ir&the heater, treater ste is �a n a e:tanb, fu impwarid (csi. adou ; :RI.CE:far _.•,._• . :.Stibmitted.ealeulaiibetia3 • • it5ttUced vvater need'siE4Pli3lIF'ridl'ie:suk3lrlEfr.* =:l:i'.etjuegFeirt::::::::•::::::::::;::'::: •.:::',::ist:':..... , • fJpratac;has't th?#St c.brf:Coktt• o,lla#es €e u#atiamot aEidulatiiiii6E #i,6,, }iri • Section 04 - Public Comment Requirments is Public Comment Required? tf yes, why?1 *null rig:§frakti'e iilihur itQrwrif`;`;";" ;;`;;;;:; ;;;;'s Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 ;Mb,, .. If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modelirg results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, explain what progEams.and which pollutants here: TfiIO& .pasting;pa S t?3% c e p.,.,.: :.::::::::::.:::::a.. .Ar t ir+il? N.c urr e.Revet6t t # R ft Is this stationary source a major source? If yes, explain what programs and which pollutants here: • • Division Information Engineer: Kirk Bear Control Engineer: Chris Laplante _ Review Date: 07/05/2016 Application Date: 02/02/2016 Facility Identifiers Permit No. 16WE0332 AIRs County # 123 Weld Facility # 9E66 Potentially located in ozone nonattainment area Facility Type: exploration and production facility El Located in the 8 -hour non -attainment area? Administrative Information O True Minor Synthetic Minor for: voc r NOx F CO Company Name: Verdad Oil and Gas Corporation Source Name: Young 8N Source Location: SIC: NENE, S28, TIN, R65W 1311 Mailing Address Address 1: Address 2: ity, State Zip: Verdad Oil and Gas Corporation 5950 Cedar Springs Road, Suite 200 Dallas, Texas 75235 Person To Contact Name: Phone: Fax: Email: Arthur Beecherl 214 728 1840 Abeecheri@VerdadOil,corn i _ Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the Young 8N, located in the NENE, S28, TIN, R65W, Weld County, Colorado. Point Name Type Control Action 003 Condensate Storage Tanks Condensate Tanks None Newly reported source 004 Condensate Loading Loadout None Newly reported source 001 Compressor Engine None Newly reported source p S 001 Verdad Engine Information Engine date of m 2/1;2015 Manufacturer: GM Model Number: FX"CO Serial Number 10CHMM5022E•0018 RPM' 2000 Site -rated RPM: 2000 Engine Functicn Compressior Young 8N berating Mfg's Max. Rated Horsepower @ sea :eve': 92 Horsepower used for calcuations: 92 BSCF g 100% Load (btu/hp-hr): 6334 Site - Rated BSCF g 100% load (btufhp-hr): 6334 Other Parameters Engine Type 4SRB Aspiration naturally aspirated Electrical Generator Max Site Rating (kw) 0 Max hrs/yr of Operation 8760 Calculations Fuel Use Rate @ 100% Load 1119.863014 scf/hr ACTUAL A,rnr.al Fuel Consumption 0 MMscf/yr MAX POTENTIAL Annual Fuel fnne, unntinn 9.810 MMscf/yr REQUESTED Annual Fuel Consumption 9.810 MMscf/yr Fuel Heating Value 950.25 btu/scf Emission Control Information This engine shall be equipped with a con -selective catalytic reduction (NSCR) system and ax -fuel ratio control. Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 1=.0'00 g/hp-hr 0.980 g/hp-hr 12.4 tpy 0.9 tpy Manufacturer CO 11.000 g//hp-h: 1.980 giho-hr 9.8 toy 1.8 tpy Manufacturer VOC v 0 700 c/hp-hr 0 700 grhp-hr 0.6 tpy 0.6 tpy Manufacturer Formaldehyde 0.021 Ib/MMBTU 0.021 Ib/MMBTU 191 lb/yr 191 lb/yr AP -42 Acetaldehyde 0.003 Ib/MMBTU 0.003 Ib/MMBTU 26 ib/yr 26 lb/yr AP -42 Acrofein 0.003 lb/MMBTU 0.003 Ib/MMBTI.! 24 lb/yr 24 lb/yr AP -42 Benzene 0.°002 lb/MMBTU 0.002 Ib/MMBTU 15 lb/yr 15 lb/yr AP -42 Regulatory Requirements Ambient Air ImpsSo_rce is not required to model based on D!v:s•on Guidelines/No NAAQS violations expected (see details of Public Comment Public Comment not Required MACT 7777 Facility is an area source of HAPs. so engine is not subject to major source requirements. Engine is new Reg 7 XVII. E.2 Standards (g/hp- hr) The engine is nct subject tc Reg 7 because max engine rating is less than 100 ho: it was constructed after 1/1P008 and it is not subject to MACT Z777 or NSPS JJJJ Reg 7 XVII.E.3 The engine is nct subject to Reg 7 XVII.E.3 because the engine is •rated'ess than 500 hp Reg 7 XVI.B (Ozone NM requirements) applies? located in NAA so subject to Reg 7 XV I. B MACT ZZZZ {area source) Is this engine subject tc MACT ZZZZ area scurce requirements? Yes NSPS JJJJ Is this engine subject tc NSPS JJJJ? I I No Note: JJJJ requriements are not currently included as permit conditions oecause the reg has not been 16WE0332.CP1.xlsm 003 Three 400 barrel condensate storage tanks verdad young 8N Requsted Throughput 54750 Control Flare Efficiency 95.00% Emissions Summary Table bbl Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 8.456 Ib/bbl 231.5 tpy 11.6 tpy E&P TANK Benzene 0.024 lb/bbl 1314 lb/yr 66 lb/yr E&P TANK n -Hexane 0.128 lb/bbl 7008 lb/yr 350 lb/yr E&P TANK 224 toulene 0.011 Ib/bbl 602 lb/yr 30 lb/yr E&P TANK 0.014 lb/bbl 767 lb/yr 38 lb/yr E&P TANK xylene 0.004 lb/bbl 219 lb/yr 11 Ib/yr E&P TANK e benz 0.001 lb/bbl 55 lb/yr 3 lb/yr E&P TANK Tank emissions have ECD emissions added on to these totals. 18 ton VOC, 507 n -hex, uncontrolled, 0.9 ton VOC, 25 n -hex controlled Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) Regulation 2 — Odor Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7123184. This source is not subject because each tank is less than 19,800 gallons (471 bbl) NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing segments. This source is subject because each tank emits greater than 6 tpy VOC. Regulation 7._ Volatile. Organic Compounds: • XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non -attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are > than 20 tpy of VOC.) 0.66 3.50 0.30 0.38 0.11 0.03 0.03 0.18 0.02 0.02 0.01 0.00 004 Hydrocarbon Loadout to Tanker Trucks Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded The table of inputs below enables you to calculate the loading loss emissions factor "L". If you choose to use a state default emissions factor, you may enter is directly into cell R14 in units lb/1,000 gallons which will overwrite Factor Meaning Value Units Source S Saturation Factor 0.6 ' AP -42 P True Vapor Pressure 5.8692 psia Sales Oil A M Molecular Weight of Vap 50 lb/lb-mole AP -42 T Liquid Temperature 519.67 deg. R Field Data L Annual requested Throughput Annual requested VOC emissions Control: None Efficiency: 0.00% NCRPs Component Mass Fraction 4.22 lb/1000 gal 0.18 lb/bbl Benzene 0.0025 n -hexane 0.0135 Toluene 0.0190 Xylenes 0.0050 224 TMP 0.0150 e benz 0.0010 Source: 54750 bbl/yr 2299500 gal/yr 9708 lb/yr 4.9 tpy alysis If the operator provides HAP speciation from a stable "sales oil" analysis, enter the mass fraction from this data. Alternatively, if the operator modeled a pressurized oil to develop a site specific emissions factor, enter the modeled mass fraction for the Pressurized oil or Stable Sales Oil Analysis Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1773 lb/bbl 4.9 tpy 4.9 tpy wt % Benzene 0.0004 lb/bbl 22 lb/yr 22 lb/yr wt % n -Hexane 0.0036 lb/bbl 197 lb/yr 197 lb/yr wt % Regulatory Review Regulation 3 - APEN and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.I Does this operator unload less than 6,750 bbis per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II. D.1.1 No Yes No 005 One 400 barrel produced water storage tank verdad, young 8N Permit exempt Emissions Calculations Requsted Throughput 1 21900 bbl Control Flare Efficiency 95.00% Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.262 lb/bbl 2.9 tpy 0.1 tpy CDPHE Benzene 0.007 Ib/bbl 153 lb/yr 8 lb/yr CDPHE n -Hexane 0.022 lb/bbl 4821$b/yr 24 lb/yr CDPHE Regulatory Review Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (only needed if using flare) Regulation 2 :Odor Section l.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. MR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1 Permit Number: II, W€ o?? 3Z Section 05 — Stack Information (For Midstream sites only) C ( l .. ,K` G('.�1� t'• `]yam$ gitir.%:1' -k&'1 : �4: it", .` .t. .A .�+ ✓'. N�[+�'v?•s:�..� ,w . h. 'd%:? .t; .. .: ,(!Y�'y.4/\- �H..: • 'ahlatstwe, • a I►,0 " •� .,,, ♦" �,♦, r � .�'I, ` .1 iii�r "L'IL-Tr.--7"..-•! �� ., sit r,' 1,:.'*ti* �. s • Direction of stack outlet (check one): Exhaust Opening Shape & Sin (cheek one): Section 07 — Control Device Information ❑ Vapor Recovery Unit (VRIJ) used for control of the Storage Tank(s) 1 Size: Make/Model: Combustion Device used for control of the Storage Type: Emission Control Device Tank(s) Make/Model -98—C Rating. 2.89 MV{Btuflur ►5 Cimarron Energy lnc./ECD-2-48-210 Requested VOC & HAP Control Efficiency: °.'o % VOC & HAP Control Efficiency: Requested: Minimum temp. to achieve requested control. Constant pilot light? Yes ❑ No Manufacturer Guaranteed: Waste gas hearcontene: 1,020 98 Annual time that VR(,1 is bypassed (emissions tented): S00 °F Rru/scf D Closed loop system used for control of the storage tank(s) Descnption: Pilot burner ratin_: 0.5 ivlAlBtrv'hr III Describe Any Other: ❑ Vertical ❑ Vertical with obstructing roineap O Circular: Inner Diameter (incites) = Emission Source AIRS ED: / 2.3 / ?ea' 003 Section 06 Stack (Source, if no combustion) Location (Datum & either Latit.onc or UTM ._...,. .. titt[tmb ` e.. + .... ,. } sri J tM:, . ld j1 • at.. . x -F .:...• U1M Fasting or ' •-;:.;' .Langitede '; - aeeters or t: degrees}' -' [UM Northing or :'.t;_�> tulle ( rrietetra or degrees) . { - ... - ) Method of Collection for . LorctionData (e.& mdp..:: OrPS Goo eEarth . ...6l 40.05816°N 104.62438°W Horizontal L I Down ❑ Other. Length (inches) - Other (Describe): Width (inches) - Section 08 — Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 145 Please describe the separation process between the well and the storage tanks. 3 -phase separator (beater treater) separates gas, condensate, and water. Section 09 — Emissions Inventory information & Emission Control Information prig attached Data year for actual caleadarjr, emissions below & throughput in Sec. 04 (e.g. 2007): I 2015 I _ ►it Emission Factor Documentation - Finission Factor Actual Calendar Yeai$11,Ssion2 Requested Permitted Emissions Emission Factor PtAutant '•. ' • Data Source Uncontrolled Basis. Units Uncontrolled (Tons/Year) Controlled (TonsfYear) Uncontrolled (Tons/Year) Controlled (Tons/Year) NOx N/A N/A N/A N/A N/A N/A N/A VOC ¢5.39• if lc •44 1%i 7(19.82. 4.4tifr 1d55.39-« Pels" 27.13 (1. (air E&P Tanks CO NIA N/A N/A N/A N/A N/A N/A Benzene 0.20-mi., 44 844. *et 1: 0 ,-}^ E&P Tanks 0.02 O 3 Toluene P`^ A38 .0:02 Ori3 Q , 4 t of 0 ‘1 E&P Tanks 012• p.Qttl Ethylbenzene '°1b (H$1 Q:t1OU 9:03 O c 1 8:00 0 _ O E&.P Tanks 4101 01001 Xylenes et) 0,0($ Air 4)rl 0100 0.19- O , t 0-00 O. p E&P Tanks n -Hexane 1:09- 0 Oi W Siio 0:19- 6755. i . is, $}3- O %Its E&P Tanks 3:43- 2,2,4-Trimethylpentane No li do- L04 6 0:04— 6 . 1 . E&P Tanks 0.09 0,61 I 0.57 r . 1. IPlease use the APCD Nan -Criteria Reportable Air Pollutant Addendum form to report ollutants not listed above. e , _ I Section 10 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. if this is a registration for coverage under general permit GPO] or GPOS, !further certify that this source is and will be operated in full compliance with cash condition of the applicable general permit. r'= Arthur Beecherl >t _ss_ttti; 4 P .14S41Y. t1 ?d4o4. to, Sapply Data . ! Authorized Person (Pleasq,„print) . _ You may be charged an additional APEN fee for APEN re -submittal due to incorrectly filled -out APEN or missing information. h:. 2 Annual emissions fees will be based on actual emissions reported here. Additional Information Required: rFORM APCD-205 Attach a pressurized pre -flash condensate extended liquids analysis, RVP & APT analysis of the post -flash oil Attach E&P Tanks input & emission estimate documentation (or equivalent simulation report/test tesutts) Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses Page 2 of 2 2 xis Vice President of Operations Title Check box to request copy of draft permn prior to issuance Check box to request copy of draft permit prior to public notice. Young.-AP_Form-APCD-205-Condensate-Tanks-APEN-doc Hello