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HomeMy WebLinkAbout20203884.tiffCOLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150OSt PO Box 758 Greeley, CO 80632 December 21, 2020 Dear Sir or Madam: RECEIVED DEC 2 8 2020 WELD COUNTY COMMISSIONERS On December 22, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Crestone Peak Resources Operating, LLC - State 1 HZ Battery. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Potis, Governor I Jitl Hunsaker Ryan, MPH, Executive Director PLA2 I ; G Re v;e Gi cc: pl-(TF) HL(DS/TR)' PW(m/ER/GN/GK, O6 63-1-O DI�II�;t.l of/o5/2-1 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating, LLC - State 1 HZ Battery - Weld County Notice Period Begins: December 22, 2020 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: Crestone Peak Resources Operating, LLC Facility: State 1 HZ Battery Well production facility SENE Section 16, T3N R68W Weld County The proposed project or activity is as follows: The permittee submitted an application to modify a well production facility located in the ozone non -attainment area. With this application, the operator is requesting to permit flaring of natural gas from the tow pressure separators when the VRU is down. The application brings the facility to synthetic minor status for Title V for VOC (under 50 tpy). The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 20WE0625 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health ft Environment r COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0625 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: State 1 HZ Battery Plant AIRS ID: 123/9C34 Physical Location: SENE Section 16, T3N R68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Buffer 015 Flaring of natural gas vented from the low pressure side of seven (7) high/low pressure (HLP) separators and routed through the buffer house during vapor recovery unit (VRU) downtime. Enclosed Combustor(s) 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 this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado certify compliance as required by this permit may be obtained online at www.colorado.Qov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must 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. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section I I.A.4. ) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Buffer 015 --- --- 1.1 --- Point ote: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria pollutants must 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 must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and demonstrate compliance with the limits in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Equipment ID AIRS Point Control Device Pollutants Controlled Buffer 015 Emissions from the low pressure side of seven (7) high/low pressure (HLP) separators are routed through the buffer house to enclosed combustor(s) during vapor recovery unit (VRU) downtime. VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section I I.A.4. ) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Buffer 015 Liquids throughput of condensate tanks during VRU downtime 21,900 bbl The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits. must 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 must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. 10. The owner or operator must use monthly VRU downtime records, monthly condensate throughput records, calculation methods described in the OEtM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 3 of 10 .» r C COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. 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. (Regulation Number 1, Section II.A.5.) 14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator must 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 the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Current AIRS Equipment Pollutant Permit Limit Point Description Threshold (permit - required points only) 002 Condensate storage tanks 003 Condensate loadout 010 PSI 5.7L VOC 50 15.7 NOx 50 5.3 011 PSI 5.7L 012 PSI 5.7L 013 PSI 5.7L Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit (permit - required points only) 014 PSI 5.7L 015 Separator flaring - Insignificant Sources (APEN- and/or permit -exempt) Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health !; Ennronment Dedicated to protecting and improving the health and environment of the people of Colorado 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ob initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC. Permit for flaring of low pressure gas vented from the low pressure side of HLP separators at an existing well production facility. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health E Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Buffer 015 Benzene 71432 138.48 6.92 Toluene 108883 106.23 5.31 Ethylbenzene 100414 5.61 0.28 Xylenes 1330207 24.91 1.25 n -Hexane 110543 1028.49 51.42 2,2,4-Trimethylpentane 540841 0.55 0.03 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab a and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 015: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 1.9785 0.0989 Gas Analysis (4/17/2020) 71432 Benzene 0.00632 0.0003 110543 n -Hexane 0.0470 0.0023 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The VOC and HAP emission factors listed above are based on a site specific extended gas analysis obtained 4/17/20. The weight % values and molecular weight (35.0197 lb/lbmol) from the sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10) were used to determine the emission factors. NOx and CO emissions are based on a site -specific gas heat value of 1979.0 Btu/scf, and are below the APEN reporting threshold. Actual emissions are calculated by multiplying the emission factors in the table above by the total throughput of liquid from the condensate tanks white the VRU is down. 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 must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU 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 Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer Package # Received Date Review Start Date Andy Gruel ,. 433183 7/7/2020 12/3/2020 Section 01- Facility Information Company Name Creston Peak Resources Operating, LLC County AIRS ID 123 Plant AIRS ID 9694 Facility Name State 1 HZ Battery Physical Address/Location County 'Weld County - Type of Facility Exploration & Production Well Pad What industry segment 'Oil & Natural Gas Production & Processing Is this facility located in a NAAQ5 non attainment area? Yes 1 If yes for what pollutant? LLOzone (NOx & VOC) i 5ENE quadrant of Section 16 Township 3N Range 68W Section 02 - Emissions Units In Permit Application Leave Blank For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) i Emissions Source Type Equipment Name Emissions Control? Permit # (Leave blank unless APCD has already assienedl Issuance # Self Cert Required? Action Engineering Remarks 015 Separator Venting Buffer E Yes , 20WE0625 1 Yes Permitlnttial Issuance I _ 1 Quadrant Section Township Range SENE -16 3N Section 03 - Description of Project Crestone Peak Resources Operating, LLC (Crestone) submitted an application to modify a well production facility located in the ozone non -attainment area With this application, the operator is requesting to modify the existing condensate storage vessel source in addition to permitting flaring of natural gas from the low pressure separators This analysis only evaluates the separator venting source The application brings the facility to synthetic minor status for NANSR and Title V for VOC (under 50 tpy) i j Public comment is required for this application because new synthetic minor limits are being established in order to avoid other requirements Sections 04 05 & 06 For Division Use Only Section 04 - Public Continent Requirements Is Public Comment Required? _ If yes why? Requesting Synthetic Minor Permit , Section 05 - Ambient Air Impact Analysis Requiremer Yes - —I new VOC syn minor limit for NANSR Was a quantitative modeling analysis required? No If yes, for what pollutams? If yes, attach a copy of Technical Services Unit modeling results summary Section 06 - Facility -Wide Stationary Source Classification 1 Is this stationary source a true minor? Is this stationary source a synthetic minor? _ If yes, indicate programs and which pollutants SO2 Prevention of Significant Deterioration (PSD) ❑ Title V Operating Permits (OP) ❑ Non Attainment New Source Review (NANSR) Is this stationary source a major source? _ ^ If yes, indicate programs and which pollutants SO2 Prevention of Significant Deterioration (PSD) ODOOD Title V Operating Permns (OP) ❑ Non Attainment New Source Review (NANSR) No _ Yes NOx ❑ ❑ ❑ No NOx ❑ 0 CO ❑ ❑ V CO ❑ VOC ❑ ❑� ❑' - VOC ❑ ❑ PM2 5 PM10 TSP HAPs ❑ ❑ ❑ ODD PM25 PM10 TSP HAPs ❑ ❑ DOD Section 01 - Administrative Information F acility AIRS ID: 123 County 9034 Plant 015 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Flaring of natural gas vented from the low pressure side of seven (7) high/low pressure separators and routed through the buffer house. Enclosed Combustor(s) during vapor recovery unit (VRU) downtime Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency °h. limited Process Parameter liquid Throughput Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput Barrels (bbl) per yea! 95 Requested Permit Limit Throughput = 21,900.0 Barrels (bbl) per yew Requested Monthly T hroughput Barrelsibbl) per month Potential to Emit (PTE) Throughput - Barrels (bbl) per year Secondary Emissions -Combustion Devices) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Control Device 1979.0 Btu/sit from 4/17/2020 gas sample 34.2 scf/bbl from Promax Pilot Fuel the Rate: Pilot Fuel Gas Heating Value: 25 scfh 1000 Btu/scf MMscf/yr MMBtu/yr Section 04 - Emissions Factors & Methodologies Description Seven (7) wells produce to seven (7) high/low pressure (HLP) separators. The high pressure gas from the high pressure side of the HLP separators is routed to the sales line via vapor recovery units. The low pressure gas from the low pressure side of the HLP separators is typically routed through a buffer house (liquids knockout) and then to the sales line via vapor recovery units. During vapor recovery unit downtime, the low pressure gas vented from the low pressure side of the HLP separators is routed through a buffer house (liquids knockout) and then to the enclosed combustor(s). In order to develop site specific emission factors, the operator used a site -specific sales gas sample and a pressurized liquid sample collected on 4/17/20. The operator then used Promax to model the LP gas production rate (scf/bbl condensate). The composition of the gas is taken from a site -specific gas sample collected 4/17/20. Promax modeled gas flow rate 0.002052 MW of gas (from sample) 35.0197 Promax model basis 60.0 MMSCFD Ib/Ibmol barrels per day of condensate production Modeled gas rate scf/bbl Oxygen/Argon 0.1717 CO2. 2.3489 N2 0.8100 methane 16.9344 ethane 17.1232 propane 25.3174 isobutane 5.2384 n -butane 15.5437 isopentane 4.3184 n -pentane 5.4866 cyclopentane 0.3424 n -Hexane 1.4862 cyclohexane 0.3778 Other hexanes 2.3759 heptanes 0.8230 methylcyclohexane 0.3127 224- TM P 0.0008 Benzene 0.2001 Toluene 0.1535 Ethylbenzene 0.0081 Xylenes 0.0360 C8+ Heavies 0.5909 Total VOC Wt % Fmisslon Factors Separator Venting Emission Factor Source Pollutant uncontrolled Controlled (lb/bbl) (lb/bbl) (Liquid Throughput) (Liquid Throughput) VOC Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Benzene Toluene Fthylbenzene Xylene Extended gas analysis Extended gas analysis n -Hexane 224 TMP Extended gas analysis Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 AP -42 Table 1.4-2 (PM10/PM.2_S) AP -42 Table 1.4-2 (PM1O/PM.2.5) AP -42 Table 1.4-2 (50x) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 _ SOx 0.0006 NOx 0.0680 CO 0.3100 Pollutant Pilot Light Emissions Emission Factor Source Uncontrolled Uncontrolled (Ih/MMBtu) Ib/MMscf (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0075 AP -42 Table 1.4-2 (PM1O/PM.2.5) AP -42 Table 1.4-2 (PM10/PM-2.5) AP -42 Table 1.4.2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Table 1.4-2 (VOC) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 SOx 0.0006 NOx 0.0680 VOC 0.0054 CO 0.3100 KAPA\1020\20W E062S.CP1 Separator Venting E^,iss(ons Iraentory Section 05 Emissions inventory n Crnena Pollutants Potential to Emrt Uncontrolled (mns/yeed Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permrt Umns Uncontrolled Controlled Uonshear) Ronshoad Requested Monthly limns Controlled (bs/month) PMto PfdL5 SOx NOx VOC CO r Ceb o 006 0 Dta 00th CLOLG Ou06 1 00001 0001 n col 0 0058 0058 0066 J 2 cG 21 tG5 1 084 184 Olo4 0-04 026, 45 Hazardous Alr Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/Wml Ohs/war) Requested Permrt Uncontrolled fibs/year) Umas Controlled Ilbs/yead r Benzene Toluene EUrylbemene xylene reHexane 134 TMP 13.6- 16 lie 45 592 Jl033 Irk 13 Sal 5 ul 5 bl U 28 2.91 2491 125 102843 103349 142 05 O 003 i Section 06 Regulatory Summery Analysis Regulation Parts D Regulation? Part Section II F Regulation 7 Pan D Section II B 2 e (See regulatory applkablliry worksheet for detailed analysis) Sot rte is not ub,ect roR eulvnon7 Part0 5 enm11 R7 F The runtr Id rc forth,s aerators not sub, In go ftl.Mo7 Part rl a Iol119 e Section 07 In,tlel and Periodic Samol ne and Testing Requirements Using Liquid Throughput to Monitor Compliance Don the company use site speofic emnsmon factors based on apressurized liquid sample (Sampled upstream of the equipment covered under the Allis ID) and process simulation to estimate emeslons7 - Thusampleshouldhavebeencoltected wrth,n one year of the application received date However If the fealty has not been modified (e g. no ill nwells brought on line) then it may be appropriate to use se older sae -specific sample oo the permit w ll contain an Indust Compliance testing requirement to collect a site-specdk liquid sample and conduct se emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions (actors establehed wrth this application Does the company request a control dewce efficiency greater than 95% for a Dare or combustion device? If yes the permit will contain 'nasal and periodic compliance testing in accordance with PS Memo 2602 Sec -Ronan Technical Analysis Notes I I Because the wells began productionbefore08/01(2O14 and have not been recompleted the separators revered by this point are NOTsublect to Regulation 7 PartD Section HY - 3 r f 7 -The extended gas analysts used no establish emission factors in this application was obtained from the outlet of the buffer house(hgmds knockout for law pressure gas vented from the lose pressureskle of the HIP separators) at this k facility As a result rt is representative of only low pressure gasthat is vented to and controlled by the enclosed combustors r ^ ,. 3 NOx and 00 emuslons fromthu source are below APEN reportingthresholds As a result emmlon Inds are not included in the permrtfor NOx s nor CO -. r6.s O During normal operations low pressure gas r vented from the low pressure ode tithe HIP separators b coptured using vapor recovery ununits(VRUs)rand routedte, thesales One During VRU downtime the low pressure gas is routed through the buffer house (liquids knockout) and then to the enclosed combustors VRU downtime tracking es required in w the pewit to quaetdy the volume of gasvented from theseparztdrs and routed to the enclosed combustor(s)hsed i on thebqu,ds throughput to thestmage tanks` 4° '' —� r < _ 43 ''r' a oat > ^ s G 7 1 f t s � 5 r�henne a theonly reportable RAP As aresuh rthlhe myHAP/orwhilch an emission factor a Included In the permit r 9 .( s 'f r7} f v' f 5 vX F3 ` '/ r rx I'` ` Y_L. tat'' r 6 It should be noted that anemuslon factorfor VOC =mated with pilot light combustion a not incorporated into the permit This Is due['lithe fact that the p,bt light nlyiesulcsin a negligible contribution of VOC Thls minimal amount of emissions does not impact the totaiVOCllmrt for MI/source and thereforecan be ignored ' Irt! 4 , t 5'> a A z > s r w... .1_. r n. k r Section 09 SCC Coding and Emissions Factors (For Inventory Use Only( AIRS Pointe Ja •L y<j^ Process¢ SCC Code Pollutant Uncontrolled Emissions Factor Conwl% Units 015 OS 1040129 Oil sProduction G. home ...Amnon PM10 J6 0 lb/1000 barrels I PM25 Jo 0 lb/1000 borrcls SOx c0 0 Ih/1.3barrtl NOx _3 lb/100,1,a r Is VOC 1678E 95 16110,0 harrels CO 2 0 1.1.Ob rat I _ Benzene 63 95 lb/ IVO barrel Toluene 19 95 61'O. hart Is Ethylbenzene 02n 55 lb/1000 barrel Xylene s IlytC.,0 berm II Hexane 47 0 95 14110[0 harrels 224TMP 03 05 lb 1000barr it C 1 1 J 3 e(5 K \PA\2020\30W E0625 CPI '1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Crestone Peak Resources Operating, LLC County AIRS ID 123 Plant AIRS ID 9C34 Facility Name State 1 HZ Battery History File Edit Date 12/17/2020 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM 10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM 10 PM 2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.4 0.4 0 0 0.0 47.7 1,564.1 0.8 91.0 57.2 0.4 0.4 0.0 0.0 8.7 82.0 0.8 26.4 3 5 Previous taken from Oct 2018 tab Previous Permitted Facility total 0.4 0.4 0 0 0_0 46.8 1.563.7 0.0 89.2 57.2 0 4 0.4 , 0.0 0.0 7.8 81.6 0.0 24.6 3.4 001 XA Seven (7) 235 bbl fixed roof produced water storage vessels 0.1 0.0 0.1 0.0 July 2020 — cancel recd, emissions below AFL., threshold (still operating) 002 r P01 -Twenty-one (2'1) 400 bbl fixed root t:qndensate storage vessels 0.2 116.7 1.0 4 6 0 2 10 0 1.0 0.2 July 1020 -- convert to GP01 from 14WE0137, new SSEFS 003 14WE0138 Condensate Loadout 20.7 12 ': 1 0.1 No Change 004 14WE0139.CN SI RICE Compressco GJ230R, 4SRB, 46 HP (SN: FP20247) 0.0 0.0 Cancellation received 06/16/15. Source no longer exists at the facility. 005 14WE0140.CN SI RICE Compressco GJ230R, 4SRB. 40 HP (SN: FP -61057) 0.0 0.0 Cancellation recd 12/17/20 -- source no longer exists at facility. 006 14WE0141.CN SI RICE Compressco GJ230R. 4SRB. 46 HP (SN: FP627721 0.0 0.0 Cancellation received 07/24/17. Source no longer exists at the facility. 007 GP02.CN SI RICE Arrow A -62T (VRG 380 TA), 4SRB, 115 HP, SN: 6B12G012392 0.0 0.0 Cancellation received 07/24/17. Source no longer exists at the facility. 008 GP02.CN SI RICE Doosan D146L, 4SRB, 402 HP. SN: EEZ06200241 0.0 0.0 Cancellation received 07/24/17. Source no longer exists at the facility. 009 GP02.CN SI RICE Doosan D111L, 4SRB, 302 HP, SN: EE10H100945 0.0 0.0 Cancellation received 10/21/15 Source no longer exists at the facility. (See Record #123-9C34-15 in RM) An additional cancellation was submitted on 07O4/17 010 GP02 SI RICE PSI 5.7L NA, 4SRB. 94 3 HP. SN: 5.7L0008915 0 1 0 1 8.8 0 7 14 8 0.1 0.1 0.1 1.0 0.7 1 9 0.1 No Change 011 GP02 SI RICE PSI 5 7L NA, 4SRB. 94 3 HP, SN. 5.7L0010395 0.1 0.1 8.8 0.7 14.8 0.1 0 1 0.1 1.0 0.7 1.9 0.1 No Change 012 GP02 SI RICE PSI 5.7L NA, 4SRB. 94.3 HP. SN: 5.7L0010400 0.1 0.1 8.8 0.7 14.8 0.1 0.1 0.1 1.0 0.7 1.9 0.1 No Change 013 GP02 SI RICE PSI 5.7L NA. 4SRB. 94_3 HP, SN: 5 7L0010406 0.1 0.1 8.8 0.7 14 8 0.1 0.1 0.1 1.0 0.7 1.9 0 1 No Change 014 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP. SN: 5.7L0010403 0.1 0 1 8_8 0.7 14_8 0 1 0.1 0.1 1.0 0.7 1.9 0.1 No Change _ O'NE062!.; `Thr)3catot verrtIng HY 0.0 0.0 0 0 0 1 21.7, 0 3 0.0 0.0 0.0 0.0 0 1 1.1 0 3 0.0 July 2020. newpotnt, SSEFS accepted XA Fugitives 0.6 7.2 0 6 1.0 From July 2020 Form 102 XA Hi -low separator burners 0 1 0.1 1 5 0.1 1.3 0 0 0.1 0.1 1.5 0.1 1.3 0.0 From July 2020 Form 10.2 FACILITY TOTAL 0.5 0.5 0.0 0.0 45.8 162.8 0.6 76.6 13.7 0.5 0.5 0.0 0.0 6.8 15.9 0.6 12.0 2.0 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Minor HH: Area source 7777: Area source Permitted Facility Total 0 4 0.4 0_0 0.0 44_3. 162.6 0 0 75.3 6 5 0.4 0.4 0 0 0.0 5.3 15.7 0.0 10.7 0.9 Excludes units exempt from pennits/APENs (0) Change in Permitted Emissions 0.0 0.0 0.0 0.0 -2.5 -65_9 0 0 -13.9 Pubcom required due to new syn minor limit for NANSR for VOC Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 16.5 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25 tpy -65.9 Note 1 Note 2 Page 4 of 5 Printed 12/17/2020 COLORADO DEPARTMENT OF PUBUCHEALTH AND ENVIRONMENT AIR POLLUTION DMSION FACILITY EMISSION SUMMARY -HAPs Company Name Creston Peak Resources Operating. LLC County AIRS 10 123 Plant AIRS ID 9034 Facility Name State 1 HZ Battery Emissions - uncontrolled (Ibs pet Year POINT PERMIT Description Fonnndenyde Acetaldehyde Acrolein Benzene Toluene Elhylbenzene Xylenes n -Hexane McOH 2.T. H23 TOTAL spy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 XA Seven (7)235 bbl fixed roof produced water storage vessels _. I', 00 002 GPM Twenty-one (21) 400 bbl Fixed roof condensate storage vessels 936 643 31 166 7479 i 1 4 6 003 14WE0138 Condensate Loadout 389 688 29 302 965 1.2 004 14WE0139 ON SI RICE Compressoo GJ230R, 4SRB, 46 HP:(SN FP20247) 0.0 005 141/VE0140,CN SI RICE ComPressco GJ230R, 4BRB, 40 HP (SR FP -610571 - _ - 0.0 006 14WE0141-CN SI RICE Compress. GJ230R, 4SRB, 46 HP (SN: FP62772) 0.0 007 GP02.CN SI RICE Arrow A62T(VRG 380 TA), 4SRB, 115 HP, SR( 68120,012392 0.0 008 GP02,CN SI RICE Doosan D146L, 45R6, 402 HP, SN' EEZ06200241 - 0.0 009 GP02.CN St RICE Doosan OWL, 4SRB, 302 HP SNUEE10H100945 0.0 010 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP SN: 5.710008915 16'12 222 909 126 244 0.1 011 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP SN: 5710010395 1032 222 209 126 244 p.1 012 GP02 SI RICE PSI 5, 7L NA, 4SRB, 94.3 HP SN. 5710010400 1632 222 209 12.6 244 0.7 013 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP SN'5710010406 1632 __. 209 126 244 O1 014 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP SR(5.7L0010403 1612 ... 209 126 .44 01 015 20WE0625 Separator venting "Buffer 135 106 F 1028 07 XA Fugitives 5 to 2 15 41 00 XA Hflow separator bumers 2 0.0 TOTAL Apo) 0.4 0.1 0.1 0.8 0.7 0.0 0.3 4.8 0.1 0.0 0,0 0.0 7.2 ea Reportsble = all HAPs where uncon[rolletl emissions> de minis us values Red Text unconn tied ennss'lans da arum. Emissions With controls (Ibs per year POINT PERMIT Description Fonnatpenoe Acemmenyde Acrolein Benzene Toluene Mylb ..a Xylenes n -Hexane McOH .4 TMs H2S TOTAL hprl Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 - XA Seven (7)235 bblfizegroofproduced water storage vessels - - - - 21 15 0,0 002 GP01 Twenty-one (21) 400 bbl fixed roof condensate storage vessels 47 32 5 374 1 0.2 003 14WE0133 Condensate Lcadout 19 34 15 48 0.7 004-14WE01394N St RICE Compress. G.f23(R,4SR8, 40. HP 1511:. FP20247) - 0.0 005 14WE0140,CN SI. RICE Compass. GJ230R, 4SRB, 46 HP (SN: FP -61057) 0.0 006 14WE0141.CN SI RICE Comressco G,1230R, 4SRB, 48 HP (SN: F12627721 0.0 007 GP02.CN SI RICE Arrow A62T(VRG 380 TA), 4SRB, 115 HP, SN: 6B126012392 - - 0,0 008 GP02:CN SI RICE Doosan D1461_, 4SRB, 402 HP SN: EEZ06200241 0.0 009 GP02.CN SI RICE Doman 01114, 1SRB,302 HP, SM. EE1'OH10094S 0,0 010 GP02 SI RICE PSI 5.7L NA, 45RB, 94.3 HP SN: 57L0008915 1632 _22 209 I 2 6 t44 0.1 011 GPM SI RICE PSI 5.7L NA, 4SRB, 94.3 HP SN: 5.7L0010395 1432 _._. 20.9 I 2 9 244 0,1 012 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP SN: 5710010400 1331 22 205 126 244 01 013 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP SN. 5740010406 1932 2_. 205 126 ;44 0,1 014 GP02 SI RICE PSI 5.7L NA, 4SRB, 94.3 HP, SN: 57LOOI0403 163d _._ 205 12a _44 0,1 015 20WE0625 Separator venting "Buffed 7 S 1 51 0.0 XA Fugitives a id _ IS 41 0.0 XA Hi -low separator burners -h 0.0 TOTAL(tpy) OA 0.1 0.1 0.1 0.0 0.0 0.0 0.3 0.1 0.0 0.D 0.0 1.0 20WE0625.CP1 12/17/2020 Cif Air Pollutant Emission Notice (APEN) and Application for Construction Permit Gas Venting APEN - Form APCD-211 All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 / 9C34 / li Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: State 1 HZ Battery Site Location: SENE Section 16, T3N, R68W Mailing Address: 10188 East I-25 Frontage Road (Include Zip Code) g Site Location County: Weld NAICS or SIC Code: 1311 Firestone, CO 80504 Contact Person: Sabrina Pryor Phone Number: (303) 774-3923 E -Mail Addressz: sabrina.pryor@crestonepr.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. � 433181 COLORADO Hc.,N� S Ennmrm.e�, Page 12 of 66 Permit Number: AIRS ID Number: 123 / 9c34 / Section 2 - Requested Action Q NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership° ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Buffer (separator) gas venting controlled by enclosed combustor. Company equipment Identification No. (optional): Buffer For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 08/01/2020 ❑Q Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G?. days/week weeks/year ❑✓ Yes ❑ Yes ❑ Yes ❑ No ❑✓ No 0 No 401%,�* COLORADO Szmnmen, .N ih..bl:e Page 13 of 66 Permit Number: AIRS ID Number: 123 /9c34/ Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters: Vented Gas Properties: El No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 21,900 bbl/year Actual: __ bbl/year Molecular Weight: 35.0197 VOC (weight %) 62.6118% Benzene (weight %) 0.2001% Toluene (weight %) 0.1535% Ethylbenzene (weight %) 0.0081% Xylene (weight %) 0.0360% n -Hexane (weight %) 1.4862% 2,2,4-Trimethylpentane (weight %) 0.0008% Additional Required Documentation: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX li n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations'or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. COLORADO Caw�nnm� y Tb��c 4 W'n n Er. �vnm-n� Page 14 of 66 Permit Number: AIRS ID Number: 123 /9c34/ Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.227993;-105 001430 p Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground level (Feet) Temp. (.F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device Pollutants Controlled: VOCs, HAPs Rating: NA MMBtu/hr Type: Enclosed Combustor Make/Model: N/A Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: El Yes ❑ No Pilot burner Rating: 1,979 0.025 Btu / scf MMBtu / h r Other: Pollutants Controlled: Description: Requested Control Efficiency: COLORADO ,,,,i7"e � ,64:c Page 15 of 66 Permit Number: AIRS ID Number: 123 /9C34/ Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? QQ Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Descri Description p Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) PM SOX NO. CO VOC Enclosed Combustor 100°h 95% HAPs Enclosed Combustor 100% 95% Other: '.fro repel ' d OCCi Ci art : r/ fTions data? NA Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP-42,Emissions Mfg., etc.) Uncontrolled (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SO. NO. 0 068 Ib/MMBtu PP 42 -- — -- 5 78E-02 CO 0.31 Ib/MMBtu AP -42 — — 0.26 VOC 1 98 lb/bbl Site specific 2167 1 08 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (lbs/year) Controlled Emissions6 (lbs/year) Benzene 71432 6.32E-03 Ib/bbl Site specific 138 69 Toluene 108883 4.85E-03 Ib/bbl Site specific 106 5.3 Ethylbenzene 100414 2 56E-04 lb/bbl Site specific 5.61 0.3 Xylene 1330207 1.14E-03 Ibrttbl Site specific 24 92 1.2 n -Hexane 110543 4 70E-02 lb/bbl Site specific 1,029 51.4 2,2,4-Trimethylpentane 540841 2.39E-05 lb/bbl Site specific 0.52 2 62E-02 Other: Yes ❑ No 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. arga. COLORADO lt c.l.h ci f me Page 16 of 66 Permit Number: AIRS ID Number: 1 23 / 9C34 / Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 07/07/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Sabrina M. Pryor Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ID Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303)692-3175 OR (303)692-3148 APCD Main Phone Number Make check payable to: (303) 692-3150 Colorado Department of Public Health and Environment COLORADO 6 wig !®24, Page 17 of 66 Hello