HomeMy WebLinkAbout20250899.tiffCOLORADO
Department of Public
Health 8 Environment
Shannon Van Dok
svandok@civiresources.com
March 31, 2025
RECEIVED
MAR 31 202E
WELD COUNTY
COMMISSIONERS
Re: Draft Permit and Public Notice for Permit Number 24WE0907, 24WE0908, and
24W E0909.
Shannon Van Dok: •
The Air Pollution Control Division has prepared a public comment package for the permitting
action requested by HighPoint Operating Corporation regarding the emission source(s)
located at the Anschutz Equus Farms 4-62-28 NWNW facility. The public comment period will
last thirty (30) days, beginning on March 31, 2025. This publicscomment period is being
provided due to the requirements of the Colorado Air Pollution Prevention and Control Act
and Colorado Air Quality Control Commission Regulation Number 3, Part B, Section III.C.
During the thirty -day -public comment period, please review your permit and contact your
permit engineer with any questions or concerns you may have.
This: application is complete and in proper form. It meets the requirements of Regulation
Number 3, Part B, Section III.B.
Sincerely,
Diego Chimendes
Stationary Sources Program
Air Pollution Control Division
Enclosures
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.Qov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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Air Pollution Control Division.
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Notice of a Proposed Construction Permit Warranting Public Comment
Website Title: HighPoint Operating Corporation - Anschutz Equus Farms 4-62-28 NWNW - Weld
County
Notice Period Begins: March 31, 2025
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: HighPoint Operating Corporation
Facility: Anschutz Equus Farms 4-62-28 NWNW
Well Production Facility
NWNW SEC 28 T4N R62W
Weld County
The proposed project or activity is as follows:
This well production facility receives well liquids from sixteen (16) well to sixteen (16) heated 3 -
phase HP separators. Condensate from the HP separators are sent to two (2) heated LP separators
and the to five (5) Vapor Recovery Towers (VRT). Condensate is finally sent to thirteen (13)
condensate storage vessels. Produced water separated through the inlet HP separator is sent to
four (4) produced water storage vessels. Gas recovered through LP separation, VRTs, and HP
separators are further sent to two (2) 2 -phase separators. Gas from these 2 -phase separators are
sent to TEG Dehydration unit and then compressed to pipeline through 3 compressors. Condensate
recovered from the 2 -inlet separators and compressors are recovered through one heated flash
tank and one VRT, and sent to four (4) condensate tanks. Gas from the heated tank and VRT are
recycled to inlet. Condensate and water are transported from the facility through tanker trucks.
Facility emits fugitive component leaks and ROPE.
The operator is requesting to replace two engines with engines with a newer model. According to
the operator, HPOC is looking to upgrade the engines from Series 4 to Series 5. The Series 5s just
so happen to be cleaner burning. This is an acceptable reason to upgrade engines due to the newer
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.Rov/cdohe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
and lower emission standard in Regulation Number 26. Additionally, the operator is requesting to
add a new TEG dehydration system. According to the operator, the existing salt dehydration unit is
aging and will require replacement in the near future. The TEG dehy is a potential replacement.
Considering the reasons provided by the operator, the replacement of the salt dehydration unit
with a TEG dehydration unit and engines was not triggered by the same reason, projects are not
dependent on each other to be viable, and they are not .substantially related. As a result, project
should not be aggregated for the purposes of a major source review. With that said, both projects
are considered addition of new emission sources.
PTE of NOx from both engines is 18.4 tpy and PTE of VOC from both engines is 12.8 tpy. The
emissions increases are based on BAE = zero and PAE = PTE following the guidance in PS -Memo 24-
02. NOx and VOC increases are not subject to major source review because they both are below the
significant threshold (25 tpy). It should be noted; however, that the operator is requesting
federally enforceable limitation on the PTE of NOx in order to avoid major stationary and major
modification requirements (NANSR). Furthermore, uncontrolled CO emissions from both engines is
over 250 tpy and the operator is requesting federally enforceable emission limitations on the PTE
of CO in order to avoid major stationary source requirements (PSD).
PTE of VOC from the dehydration unit is 9.8 and it is below the significant threshold (25 tpy).
Following the guidance in PS -Memo 24-02, this project is not subject to major source review. It
should be noted; however, that the operator is requesting federally enforceable limitation on the
PTE of VOC in order toavoid major stationary and major modification requirements (NANSR).
The division has determined that this permitting action is subject to public comment requirements
under Colorado Air Quality Control Commission Regulation Number 3, Part B, Section III.C due to
the following reason(s):
• 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 number
24WE0907, 24WE0908, and 24WE0909 are available on the division website: Air Permit Public
Notices
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.Qov/cdohe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
The division hereby solicits submission of public comments from any interested person concerning
the ability of the proposed project or activity to comply with the applicable standards and
regulations of the commission. The division will receive and consider written public comments for
thirty (30) calendar days after the date of this notice. Comments may be submitted using the
following options:
Submit comments via web form: Form for Public Comment on Draft Permit
Submit comments via email: cdphe_apcd airpermitcomments@state.co.us
Submit comments via mail:
Air Pollution Control Division - Oil a Gas Unit
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, CO 80246-1530
NOTE: Comments submitted to the division will be uploaded to an online document repository and
will be accessible to the public. Your comment(s) and the division's response(s) are not considered
confidential and will be publicly accessible, including your name and any other personal
information you provide in your comment(s).
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.Qov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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