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Home My WebLink About20210200.tiffCOLORADO Department of Public Health Et Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 January 11, 2021 Dear Sir or Madam: RECEIVED JAN 15 2021 WELD COUNTY COMMISSIONERS On January 12, 2021, the Air Pollution Control Division will begin a 30 -day public notice period for Creston Peak Resources Operating LLC - Kugel 18H H267 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 Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director Publ: C Rev�ecA1 °I/act/2i cc : Pi..(rP)� N L(DSITR), P(J(sM/ER/c APO, oe(s►�) o1/lS/21 2021-0200 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating LLC - Kugel 18H H267 Battery - Weld County Notice Period Begins: January 12, 2021 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: Kugel 18H H267 Battery Existing synthetic minor oil and gas exploration and production facility NENE SEC 18 T2N R67W Weld County The proposed project or activity is as follows: Source is lowering permitted emissions to remain synthetic minor in the new serious non -attainment area 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 19WE0379 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: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health & Environment COLORADO I Air Pollution Control Division Department of Pt,,bec Health & Er __rent Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0379 Issuance: 2 Crestone Peak Resources Operating, LLC Facility Name: Kugel 18H -H267 Plant AIRS ID: 123/A03D Physical Location: NENE SEC 18 T2N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TANKS 001 Eight (8) 500 bbl fixed roof condensate storage tanks. Enclosed Combustor PW 002 Two (2) 500 bbl fixed roof produced water storage tanks. Enclosed Combustor LOAD -1 003 Truck loadout of condensate from tanks Enclosed Combustor BUFFER 004 Low pressure separator emissions during VRU downtime. This point does not include emissions from the downstream Vapor Recovery Tower. Enclosed Combustor 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 the specific general terms and conditions included in this document and the following specific terms and conditions. Page 1 of 13 COLORADO Air Pollution Control Division Department of Pubiic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. 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. (Regulation Number 3, Part B, Section III.F.4.) F.4. ) 3. 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 4. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section I I.A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TANKS 001 --- --- 19.3 3.3 Point PW 002 --- --- 0.2 --- Point LOAD -1 003 --- --- 2.7 --- Point BUFFER 004 --- --- 17.8 3.2 Point ote: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Page 2 of 13 COLORADO Air Pollution Control Division Depanrrent. Pub:ic Health E; £r lEonn:ert Dedicated to protecting and improving the health and environment of the people of Colorado Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. 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. 6. The emission points in the table below shall 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TANKS 001 Enclosed Combustor VOC and HAP PW 002 Enclosed Combustor VOC and HAP LOAD -1 003 Enclosed Combustor VOC and HAP BUFFER 004 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TANKS 001 Condensate Throughput 912,500 barrels PW 002 Produced Water Throughput 302,950 barrels LOAD -1 003 Condensate Loaded 912,500 barrels BUFFER 004 Natural Gas Routed to Combustor 8.5 MMscf Page 3 of 13 COLORADO Air Pollution Control Division De-.partrrent of VUhiic He.atth 6 Environment • Dedicated to protecting and improving the health and environment of the people of Colorado The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 8. Point 004: Upon commencement of operation, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. Point 003: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by an enclosed combustor. (Reference: Regulation 3, Part B, III.D.2) 12. Point 001: This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 13. Points 001, 002, 003 It 004: The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. Page 4 of 13 !COLORADO Air Pollution Control Division Departrene ot Public Health u Er vi =e-., Dedicated to protecting and improving the health and environment of the.people of Colorado 14. Points 001 £t 002: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. Points 001 Et 002: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 16. Point 003: Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) a. Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. b. Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. c. Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,800 barrels per year on a rolling 12 -month basis must control emissions from loadout upon exceeding the loadout threshold. 17. Point 003: Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 18. Point 003: The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): a. Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. e. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or Page 5 of 13 'COLORADO 1 Air Pollution Control Division Devarmert. ct Fs btic Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 19. Point 003: The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): a. The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, b. If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. c. The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. d. The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 20. Point 003: The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. a. Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. b. Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. c. Records of the infeasibility of observation of loadout. d. Records of the frequency of loadout. e. Records of the annual training program, including the date and names of persons trained. 21. Point 003: Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 22. Point 004: The separator covered by this permit is subject to Regulation 7, Part D, Section II. F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If Page 6 of 13 COLORADO Air Pollution Control Division Depart, -rent o, PLIN,,,- Health & Env ronmem Dedicated to protecting and improving the health and environment of the people of Colorado a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 23. 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 Et MAINTENANCE REQUIREMENTS 24. Points 001 - 004: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEtM) 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 25. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 26. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 27. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, 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 For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 7 of 13 COLORADO Air Pollution Control Division I Department. of Pubk: Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. GENERAL TERMS AND CONDITIONS 28. 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. 29. 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. 30. 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. 31. 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. 32. 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 Page 8 of 13 COLORADO Air Pollution Control Division Depnrtrr ent vt Pettit,: ,: Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 33. 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. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 September 9, 2019 Issued to Crestone Peak Resources Operating, LLC Issuance 2 This Issuance Issued to Crestone Peak Resources Operating, LLC Updated points 001-004 to reflect new process limits and emission factors Point 005 removed from permit Page 9 of 13 COLORADO Air Pollution Control Division Department or Pub -o Heaith b Ertuirolment 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 shall 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 shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-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 source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 1,755 88 Toluene 108883 1,465 73 Xylenes 1330207 405 20 n -Hexane 110543 14,679 735 003 n -Hexane 110543 2,011 101 004 Benzene 71432 1,794 90 Toluene 108883 1,284 64 Xylenes 1330207 320 16 n -Hexane 110543 15,861 793 Note: All non-cr ena reportable po lutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 10 of 13 COLORADO Air Pollution Control Division Departrrert of Pubtx: "leaittt 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 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.068 (lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 0.84480 0.04224 Promax 71432 Benzene 0.00192 0.00010 Promax 108883 Toluene 0.00161 0.00008 Promax 1330207 Xylene 0.00044 0.00002 Promax 110543 n -Hexane 0.01610 0.00081 Promax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.068 (lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 0.0148 0.00074 CDPHE Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.068(lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 0.1157 0.0058 AP -42 110543 n -Hexane 0.00220 0.00011 AP -42 Note: 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) = 4.0 psia M (vapor molecular weight) = 48.34 lb/lb-mol T (temperature of liquid loaded) = 525 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Page 11 of 13 COLORADO Air Pollution Control Division Department of Vub!:c Health ,E.; Environment Dedicated to protecting and improving the health and environment of the people of Colorado The controlled emissions factors for this point are based on a control efficiency of 95%. Point 004: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors Ib/MMscf Source NOx 0.068 (lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 83,708.02 4185.40 Gas Analysis 71432 Benzene 211.04 10.55 Gas Analysis 108883 Toluene 150.98 7.55 Gas Analysis 1330207 Xylene 37.61 1.88 Gas Analysis 110543 n -Hexane 1,866.05 93.30 Gas Analysis Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC and HAP NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 12 of 13 COLORADO Air Pollution Control Division Deportment of Put;'.,:.: Health 5 Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart X 0000( Page 13 of 13 Cotorada Air PermAthia Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Christopher Kest:, 437391 ?1/22/2020 1/4/2020 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: :',Exploration & Production Weil Pad What industry segment? Gil & Natural, Gas Production & Processing. Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Weld County stona Peaf:: resources:Oerienure LLC Section 02 - Emissions Units In Permit Application Leave Blank- For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) Emissions Source Type Equipment Name Emissions Control? Permit # (Leave blank unless APCD has already assigned) Issuance # Self Cert Required? Action Engineering Remarks u01 Storage Tank TANKS Yes 19WE0379 2 yes Perrnit initial ,ssuance 002 - Producer! Water Tank PW - Yes E 7 2 yes Permit Initial - issuance ..0v3 - - liquid Loading LOAD -1 - yes 19WE0379 2 - ,. yes Perm&?nitiai Issuance ?04 Separator Venting EL'.FFF..R Yes 19WE0379 2 ,yes Permit Initial issuance Quadrant Section Township Range ;ENE 67 Section 03 - Description of Project Revising process ^.. _sand emission factors to remain sytheec minor in ne Sections 04, OS & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? - Yes Ifyes, why? Reg eests ,! rPerniii Section 05 - Ambient Air knpact Analysis Requirement Was a quantitative modeling analysis required? No 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? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 NOx Co VOC PM2.5 Prevention of Significant Deterioration (PSD) DODOO Title V Operating Permits (OP) ❑ ❑ ❑- ® ❑ Non -Attainment New Source Review (NANSR) ❑ IA PMSO TSP ❑ ❑ ❑ PM10 TSP ❑ ❑ ❑ HAPs RI HAPs ❑ - Is this stationary source a major source? No If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑. Non -Attainment New Source Review (NANSR) O O Storage Tank(s) Emissions Inventory Section 01 -Administrative Information Facility AIRS ID: 123 County A036 Plant Point Section 02 -Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Storage Tank(s) Actual Throughput= Requested Perrnit Unlit Throughput= Barrels (bbl) per year S27, 0.0 Barrels (bbl) per year Requested Monthly Throughput= 77300.0 Barrels(bbl) per month Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= • Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 0 Barrels (bbl) per year 2723.0 Btu/scf 7.6 scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device 0.0 MMBTU per year 13915.7 MMBTU per year 33,915.7 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) [Condensate Throughput) (Condensate Throughput) MIIIMMIIIMMIDEMINAME "..:IIMEMIlMIES - -MIEDIMIEMEZEM MM.. ITIMIIMIEllEMIIIMEME IliMMIMIIMEMEMIIIM�`5 rn.A$t Pollutant Control Device Emission Factor source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat (Condensate combusted) Throughput) IllellEMESEINIMMEIM �} z IZI2IMy a.o IIIISM OD '® Pollutant Pilot Light Emissions Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) (Pilot Gas Heat (Pilot Gas Combusted) Throughput) ® z€ MIZIMMMIIIMEZEIMIMIINEMI "J 0 p6r 68 .: Section OS - Emissions Inventory ' Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx VOC CO 0.1 OA .: 0,1 0.1 13.1 0.1 0.0 0.0 0.1 0,1 13.1 0.D 0.0 0,0 0.0 0,0 0.0 0.7 al 0:1 --.. 0.7 119.3 395.4 0.0 0,9 335,4 _9.3 3273 6 3.2 0.3 0.3 __.. 3.20 544.2 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) . Benzene Toluene Ethylbenzene ..022.0 0.0 J0 _752 38 1469.1 0.G 0.0 1459 73 64.3 0.0 0-0 64 3 2 of 18 KAPA\2019\19WE0379.CP2 Storage Tank(s) Emissions Inventory Xylene n -Hexane 224 TMP 405.2 0.0 0.0 03 0.0 0.0 0.0 4005 20 735 2 14M1.3 14691 39.5 40 3 of 18 KAPP\2019\19WE0379.CP2 Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Part D,Section I.C, D, E, F storage tank is . subject to Regulation , it Regulation 7, Part D,Section I.G, C Storage Tanfr is not albiect,_ 4eaulae r - Regulation 7, Part D,Section II.B, C.1,C:3 Storing tank is subject to R s cation 7 n ll, I3, C.1 Sr. C.3 Regulation 7, Part D,Section II.C.2 _-oragetank is sublect to Regulation 7, 7Section II.C.2 Regulation 7, Part D,Section ll.C.4.a.(i) Storage Tank is not subject =-oF.egufatios 7. 'kart D, Section ii.C.4.aji) Regulation 7, Part PSection II.C.4.a.(ii) Storage Tank is not subject to Regulation 7, Pa=t 0, Section II.C.4.a(ii), b - r Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to "ASPS Kb Regulation 6, Part A, NSPS Subpart 0000 .storage tanit is not subject ?c'9Sin 0000. NSPS Subpart 0000a Storage Tank. is ns:t subject t_ NSPS OO00a Regulation 8) Part E, MACE Subpart HH Storage Tank is not subject to ft1AC7 HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks, does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older. site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with P5 Memo 20-02 Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only' AIRS Paint if 60t Process it 01 Uncontrolled Emissions Pollutant Factor Control % Units PM10 _.__ _ lb/1,000 gallons Condensate throughput PM2.5 _ lb/1,000 gallons Condensate throughput SOx »'Efi 0 lb/1,000 gallons Condensate throughput NOx 0,n4 0 lb/1,000 gallons Condensate throughput VOC __ 95 lb/1,000 gallons Condensate throughput CO S.17 lb/1,000 gallons Condensate throughput -Benzene 0.05 95 lb/1,000 gallons Condensate throughput Toluene 0.04 ,_ lb/1,000 gallons Condensate throughput Ethylbenzene 0.80 95 lb/1,000 gallons Condensate throughput Xylene 0.01 95 lb/1,000 gallons Condensate throughput n -Hexane C RS lb/1,000 gallons Condensate throughput 224 TMP 000 'RS lb/1,000 gallons Condensate throughput 4 of 18 Ki\PA\2019\19WE0379.CP2 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and 8-APEN and Permit ReJr uiremenm t Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)? ® Source Requires an APED. Go to 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance an grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than lOTPY or CO emissions greater than 10117Y (Regulation 3, Part R, Sertion 11.0.3)? NON -ATTAINMENT 1. Are uncontrolled eralssions from my criteria pollutants from this individual source greater than STPY(Regulation 3, Part A, Section ll.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and114 and Section 2for additional guidance on grandfather applicability)? 3. Are total fadlity uncontrolled VOC emissions greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than to TPY (Regulation 3, Part B, Section 11.0.2)? vequires apermit Colorado Regulation?. Part D. Section I.C-F 5G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Regulation 7, Part D, Section I.A.1)? 2. Is this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part 0, Section I.A.1)? 3. Is this storage tank locatedata natural gas processing plant (Regulation 7, Part D, Section I.G)? 4. Does this storage tank contain condensate? 5. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions (Regulation 7, part D, Section l.G.2)? 6. Are uncontrolled actual emssonsofthis storage tank equal to or greeerthan 2 tans er year VOL file ulation 7, Part O,Section 1.0.3.a0))? (greenguank Ls s'ui>e_°°r:iegolatinn l_ Pea `eeklenl.Cf Part 0, Section I.L2 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Part D, Section I.C.T—Emission Estimation Procedures Part D, Section I.D —Emissions Control Requirements Part 0, Section I.E—Monitoring Part D, Section I.F—Recordkeeping and Reporting Storage Tank 1s.1" s,;eject-o Regulation 7, Section 1.4 Part O, Section 1.6.2- Emissions Control Requiter.. Part 0, Section I.C.1a and b —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Colorado Regulation 7,Part D. Section II 1. Is this storagetank located at a transmission/staragefacility7 2. Is this storagetank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant° (Regulation 7, Part D, Section II.C)? 3. Does this storage talk have a fixed roof (Regulation 7, Part 0, Section lLA.20)? 4. Are uncontrolled actual emissions of this storagek equalto or greater h 2 ans per year VOC (Regulation 7, Part 0, Section ll.Gl.c)? �» , 7,Peet gagtionit. _ -.3 - Part D, Section II.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part D, Section 1I.CA - Emissions Control and Monitoring Provisions Part 0, Section II.C3 - Recordkeeping Requirements 5. Does the storage tank contain only "stabilized" liquids (Regulation 7, Part D, Section ll.C.2.h)? IS -renege,. Part 0, Section II.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or 'antedate facility that was modified on or after May S, 2020, such 6. that an additional controlled storage vessel Is constructed to receive an anticipated Increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Pan D , Section ll.C.4.a,(I)? Staraaa Tank is ne; _r:�e;; I:aittleHcn'I. per. r).5 Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or aher January 1, 7. 2021such that an additionalcont II d storage vessel is constructed to an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ll.C.4.a.(II)7 iov'x»0, Sectlnn_ 40 CFR, Part 60, Subpart Kb, Standards of Perfarmancefor Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greaterthan or equal to 25 cubic meters (m) (^472 RBIs] (40 CFR 60.110b(a))? 2. Does the storage vessel meet thefollowing exemption in 6a.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874n,'(-10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custody transfer' as defined in 60.11lb? 3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2)after luly 23,1984 (40 CFR 60.110b(a))? 4. Does the tank mexthe definition of"storage vessel"' in 60.111b7 5. Does the storage vessel store a"volatile organic liquid(VOL)"sas defined in 60.111b7 6. Does the storage vessel meet any one afthe following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ('29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 ma (-950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.11ob(b))?; or c The design capacity is greater than or equalto 75 Ms [^472 BBL] but less than 151 m' (-950 BBL) and stores a liquid wkh a maximum true vapor pressure' less than 15.0 kna(60.1306(h))? 7. Does thestorage tank meet either one of the following exemptions from control requirements: a. The design capacity Is greater than or equalto 151 m' j`950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. Thedesign capacity is greater than or equalto 75 Ms (-472 BBL] but less than 151 m' [-950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? 'Rm.. =_ rank Is,vs svv x!*a NSP5 Rb 40 CFR, Part 60.Subpat 0000/0000m Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this storage vessel located at a facility In the onshore ail and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011and September 18, 20157 3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 1g, 20157 4. Are potential VOC,emissions' from the Individual storage vessel greaterthan or equal to 6 tons per year? 5. Does thb storage vessel meet the definition of"storage vesserz per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled In accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? WOO Go to next question Source Requires a permit Source Requires an APEN. Go to Go to next question Source Requires a permit Continue - You have indicated th Continue - You have Indicated th Storage Tank is not subject to Rs Continue-Vailhave indicated th Go to the next question -Yau ha Go to the next question Source is subject to parts of Reg object to all provision, Storage Tank is not subject to Re Storage Tank is not subject NSPS [Nate: If a storage vessel Is previously determined to be subject to NSPS O000/0000a duet° emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tankloc.ed at an oil and natural gas production facility that meets either of thefollowing criteria: a. Afaciliy that processes, upgrades or stores hydroorbon liquids' (63.760(a)(2)); OR b. A faciity that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 2. Is the tank located. a facility that is major' for HAPs? 3. Does the tank meet the definition of"storage vessel. in 63.761? 4. Does the tank meet the definition of .storage vessel with the potential for flash emissions°per 63.?617 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kh or Sub art 0000? ='es MAIN Now Subpart A, General provisions per 463.764 (a) Table 2 463.765 - Emissions Control Standards 463.273 -Monitoring 463.774- Recordkeeping 463.725 -Reporting RACT Review RACT review is required If Regulation] does not apply AND If the tank is in the non -attainment area. If the tank meets bath criteria, then review RACT requirements. Disclaimer Continue - You have indicated th Storage Tank is not subject NSPS Go to the next question Storage Tank is not subject NSPS Continue -You have indicated th Storage Tank Js not subject MAC This document assists operators with determining applicability of certain requirements of the Clean Air Act, ifs implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, r any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing regulation; and Air Quality Control Commission regulation; the language of the statute or regulation will control. The use of non -mandatary language such es'recommend,""may,"°should,"and °can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'Mee and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself b Section 01- Administrative Information 'Facility AIRS ID: N tom` County Plant Point Section 02 - Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tanlets) Actual Throughput= 'Requested Permit Limit Throughput= Barrels (bbl) per year Barrels (ball per year Potential to Emit (PTE) Condensate Throughput= Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Potential to Emit (PTE) heat content of waste gas routed to combustion device= Control Device cf/bbl Requested Monthly Throughput= 251300 Barrels (bbl) per month _.0 MMBTU per year _,0744 MMBTU per year _.274.4 MMBTU per year Attributed to Condensate tanks Section 04 -Emissions Factors & Methodologies Will this storage tank emit flash emissions? Section 05 - Emissions Inventory 4.i,aN.33r* Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/yeas) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 50x NOx VOC CO 0.0 00 0.0 0.0 C0 0,7 e..., OD i)-0 0,7 .,-_ 0.0 0.0 0.0 .,.' �.. 0-0 2.2 0.0 0-0 2.2 _.__ 0.2 0.0 022 G.2 037 23.3 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) Ohs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylhenzene 96.0 _.0 0.0 96,0 4.s 05.? U-0 0.0 65.4 3.3 0,0 2,1 0,2 7 of 18 KAPA\2019\19W E0379.CP2 Storage Tank(s) Emissions Inventory xyiene n -Hexane 224 TMP 11.8 51.2 0.0 0.0 0.0 0,0 0.0 0.0 11.8 81.2 0.0 0.� 0.0 8 of 18 KAPA\2019\19WE0379.CP2 Storage TarlI((s) SIT)Ss€GE-S inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Snores regaires a P.,1,10: Regulation 7, Part D,Section I.C, D, E, F Storage tank's sable&to Raguint:on'7, =an O. Sez of 1.C -F Regulation 7, Part D,Section 1.G, C %owe .ti-„ as not sublet, to &nen:aine 7, `s_...-.,. _ Regulation 7, Part D,Section II.B, C.1, C.3 Stnnega rang f ec: to nee,.'.at=on 7, part D. Sed=er i, 11, £,1 & C.'s Regulation 7, Part O,Section ll.C.2 Stoage .r.. _a -. .1333. nz.,.-".. Pa.^, 7, 5ection:CC Regulation 7, Part D,Section II.C.4.a.(i) F...orage-,- . I, ut subject to Degaggion 7, Part D, Section 11.174.3111 - Regulation 7, Part D,Section ll,C4.a.(il) Storage Tank isnot sulbetttc-:zag_'a;(on 3, P.ut% Sebrit;=...t,Legg b•f Regulation 6, Part A, NSPS Subpart Kb Sterne Tank is not subj=_ct to SPS lie Regulation 6, Part A, NSPS Subpart 0000 Storage tank s; or, s bgeY ;o ₹:5PS 00170. NSPS Subpart 0000a StO eikgo T.,- nit. is not so infest to MIPS 0000a Regulation 8, Part E, MACE Subpart HH erodsond Water Storage tenets is oat sobiect to MAC Tits (See regulatory applicability worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks, does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? If yes, the permit will contain an ''Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted (for produced water tanks, a pressurize liquid sample must he analyzed using flash liberation analysis)? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an olde site -specific sample. If no, the permit will contain an 'Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the)permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point it 002 Process it 01 SCC Code Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.59 0 lb/1,000 gallons Produced Water throughput PM2.5 0.00 0 16/1,000 gallons Produced Water throughput SOx siREF. 0 lb/1,000 gallons Produced Water throughput NOx 0.03 0 16/1,000 gallons Produced Water throughput VOC '.35 95 lb/1,000 gallons Produced Water throughput CO ti1:3 0 lb/1,000 gallons Produced Water throughput Benzene 0.01 95 16/1,000 gallons Produced Water throughput Toluene &GI 95 16/1,000 gallons Produced Water throughput Ethylbenzene 03.10 95 lb/1,000 gallons Produced Water throughput Xylene 9.00 35 lb/1,000 gallons Ptoduced Water throughput n -Hexane 0.03 95 lb/1,000 gallons Produced Water throughput 224 TMP 0-00 5fi, lb/1,000 gallons Produced Water throughput 9 of 18 KAPA\2019\19WE0379.CP2 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B -APEN and Permit Requirements ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A,Section ll.D.l.a)7 2. Produced WaterTanks have no grandfathering provisions 3. Are total facility uncontrolled VOC emissions greater than5 TPY NOx greater than 10TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section ll.D.3)? -.gnha-re indicated tl n trir . _ahtmeut Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this indNldual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.l.a)7 2. Produced Water Tanks have no grandfathering provisions 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section 11.0.2)7 ISotirre rsquirtsa perinie Colorado Regulation 7. Part O. Section I.C-F &G 1. Is this storage tank located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Regulation 7, Part D, Section I.A.1)7 2. Is this storage tank located at oll and gas operationsthat collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part O, Section l.A.1)7 3. Isthe storage tank located at a natural gas processing plant(Regulation 7, Part D, Section Le)? 4. Does this storage tank contain condensate? 5. Does thh storage tank exhibit "Flash" (e.g.storing non -stabilized liquids) emissions (Regulation 7, part D, Section l.G.2)7 6. Are uncontrolled actual emissions of this rtaragetank equal to or teeter than 2 tons per year VOC (Re ulatlon 7, Part D, SectMn1.0.3.alii))7 sublectta RagpioCan 7. PartD, section I.t F Part 0, Section RC.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Part O, Section I.C.2—Emission Estimation Procedures PartD, Sertion I.D—Emissions Control Requirements Part D, Section I.E— Monitoring Part D, Section I.F— Recordkeeping and Reporting "ratite, i5 In the Ngn-Atloinme;n'Area !Source Requires an APEN. Go to Go to next question Source Requires a permit likoroge Tank is not -sublease, R gegarioo 7. ',Won I.G Part D,. Section 1.6.2- Emissions Control Requirements Part 0, Section I.C.S.a and b —General Requirements for Air Pollution Control Equipment= Prevention of Leakage Colorado Regulation 7. Part D. Section II 1. Is th"s storagetank located at a transmission/storage facility? 2. Is the storagetank' located at an oll and gas exploration and production operation, well production facility', natural gas compressor stations or natural gas processing plane(Regulation 7, Part D, Section ILC)? 3. Does this storage tank have a fired roof (Regulation 7, Part D, Section 11.0..20)7 4. Are uncontrolled actual emhsionsof this storage tank equai to or greater than 2 tons per year VOC (Regulation 7, Part D, Section ll.Gi.c)? 'Nigro, still= I so Se Corr k. Nan n.5 C.1 8i 5.3 Part D, Section II.B-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part D, Section I I.C.1- Emissions Control and Monitoring Provisions Part D, Section II.C.3 - Recordkeeping Requirements 5. Does the storage tank contain only "stabilized' liquids (Regulation 7, Part 0, Section ll.G2.h)7 _- . on II.C.2 PartD, Section II.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located at a facility that was modified on or after May 1, 2020, such 6. that en additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ll.CA.a(1)7 10 Sec[ an 11 Cq.a;[ is the controlled storage tank located at a well production facility, natural gas compressor dation, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified an or 7. 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase In throughput of hydrocarbon liquids or produced water (Regulation 7, Part 0, Section II.C.4.a.(137 er January 4o CFR, Part 6o, subpart Kb Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m) )"472 BB10 (40 CFR 60.110b(a))? 2. Does the storage vessel meet the following exemption In 60.111b(d)(4)7 a. Does the vessel has a design capacity less than or equal to 1,589.874 ms[ -10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was thisstorage vessel constructed,reconstructed, or modified (see definitions 40CFR, 60.2) eternity 23, 1984 (40 CFR60.11ob(a))7 4. Ones the tank meet the definition of "storage vessel' in bo.lilb7 5. Does the storage vessel store a"volatile organic liquid(VOL)"sas defined In 60.111b? 6. Doesthe sorage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [-29.7 psi] and without emissions to the atmosphere (60.110b(d)(2)17; or b. The design capacity is greater than or equal.151 ms [-DSO BBL] and stares a liquid with a maximum true vapor pressure less than 3.5 kna (60.110b(b)17; or c. The design capacity Is greater than or equal to 75 Ms [^472 BBL) but less than 151 ms [-950 BBL] and stares a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b))7 7. Does the storage tank meet either one of thef°Bowing exemptions from control requirements: a. The design capacity Is greater than or equal to 151 ms (`950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa7;'or b. The design capacity is greater than or equal to 75 Ms [-472 BBL] but less than 151 ms 1-950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPai ',torso Tank Is'not : hre-0F 433 fw 40 CFR, Part% Subpart 0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production.Transmisslon and Distribution 1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 2. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 20157 3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 20157 4. Are potential VOCemissions? from the individual storage vessel greater than or equal to 6tons per year? 5. Does this storage vessel meet the definition of"storage vessel"' per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part EDSubpart Kb or 4D CFR Part 63 Subpart HH7 lit maz Tank it not rtibie_r re 05PS ....... - [Note: If a storage vessel Is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tans per year VOC on the applicability determination date, It should remain subject to NSPS 0000/0000a per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH, OII and Gas Production Facilities 1. • Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. Afacility that processes, upgrades or stores hydrocarbon liquids? (63.760(a)(2)); OR b. A facility that processes, upgrades ardor. natural gas prior to the point at which natural gas entersthe natural gas transmesion and storage source category or is delivered to a final end user' (63.76D(a)(307 2. Isthe tank located at a facility that k majors for HAPs7 3. Does the tank meet the definition of"storage vessel"' in 63.7617 4. Does the tank meet the definition of storage vessel with the potential for flash emissions?' per 63.7617 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Sub art 00007 pa -.-Neter Otago tank k oseeskhieet rp MACT HSI Subpart A, General provisions per 463.764 (a) Table 2 §63.766 - Emissions Control Standards 463.773 -Monitoring §63.774-Recordkeeping 463.775 -Reporting RACE Review RACT review is required If Regulation] does not apply AND If the tank Is In the non -attainment area. If the tank meets both criteria, then review RACF requirements. Disclaimer vnC"WW WA, No V e Source Requires an APEN. Go to Source Requires a permit ontinue - You have Indleatedth 'ontinue - You have Indicated th forage Tank b not subject to Re Continue - You have indicated th Go to the next question -You ha Go to the next question Source 6 subject to parts of Reg, 'Source is subject to all provision, Storage Tank's not subject to Re -. Storage Tank Is not subject N5P5 I ROM 1•-.4 v Continue- You have indicated th Storage Tank b not subject NSPS Go to the next question Storage Tank k not subject NSPS ontinue- You have Indicated th Wrage Tank is not subject MAC This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event ofeny conflict between the language of this document and the language of the Clean Air Act;, its Implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation 7l control. The use of non -mandatory language such as"recommend,"`may,""should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling raquiraments under the tem. of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Hydrocarbon Loadout Emissions inventory Section 01 -Administrative Information Facility AIRS ID: County 40'3D Plant Point Section 02. Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Hydrocarbon Loadout Actual Volume Loaded= 'Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = Secondary Emissions - Combustion Device(s) f Heat content of waste gas= Actual Volume of waste gas emitted per year = Requested Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year tF Barrels (bbl) per year flip Barrels (bbl) per year Btu/scf 0 scf/year 827859 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Requested Monthly Throughput= 77500 Barrels (bbl) per month 0 MMBTU per year -58 MM BTU per year 2,258 MMBTU per year Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: scfh Btu/scf 0.0 MMscf/yr _.0 MMBTU/yr Section 04- Emissions Factors & Methodologies Does the company use the state default emissims factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46•S.P•M/T stabilised hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source 5 Saturation Factor itv50190M4 P True Vapor Pressure 4 psia M Molecular Weight of Vapors 48.34 Ih/ib-mol T Liquid Temperature 524.68. - Rankine L Loading Losses 2.255125715 lb/1000 gallons 0.11571525 Ih/bbl Component Mass Fraction Emission Factor Units Source Benzene ;F#r,!` ,^. lb/bbl Toluene �n �EFs,'w;*"{ 1Z^f" a 0 lb/bbl Ethylbenzene .^. Ib/bbl Xylene `. Ib/hhl n -Hexane !'. Ib/hhl 224 TMP 0 lb/MI Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (Ib/bbl) (16/bbl) (Volume Loaded) (Volume Loaded) Emission Factor Source VOC 0.1157143 0.0002530 0.0002200 0.0057858 0.0000132 0.0000110 0.0000005 0.0000030 0.0001100 0.0000000 Benzene Toluene Ethylhenzene Xylene n -Hexane 224 TMP Pollutant Control Device Emission Factor Source Uncontrolled (Ib/MMBtu) Uncontrolled (lb/bbl) (waste heat combusted) (Volume Loaded) PM30 PM2.S 0. GO 75 1.84E -OS 0.0075 0.0005 0.0680 0.3100 7.67E-04 SOx NOx CO Pollutant Piot Light Emissions Uncontrolled IIb/MMBtu) Uncontrolled (Ib/MMscf) (Pilot Gas Throughput) (Waste Heat Combusted) Emission Factor Source PM10 PM2.S 0.0000 0.0000 0.0000 0.0000: 0.0000 0.0000 SOx NOx VOC CO 12 of 18 K:\PA\2019\19WE0379.CP2 Hydrocarbon Loa-dout Section OS - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 SOx VOC CO s1 0 6 6,00 601 _+._2 .._.C3 0.?0 9C.0 t _1 52.63 _._., 1111 91._,. 0.35 t._.. ( 0.59 0.15 C595 s> Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Iles/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 243 r 2'd 12 201 3 9 2C1 10 ;5 291.8 3 0 2008 1&J Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B -o_.._.ecuPes P -PP Regulation 7 Part D Section II.C.5. (See regulatory applicability worksheet for detailed analysis) n I(,C.5_ Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section OS - Technical Analysis Notes Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point # 003 Process # 01 SCC Code 4-9S-001-2.2 Crvdc ?P: 5-cL- -et5,99 1,ading Normal 8s , . Uncontrolled Emissions Pollutant Factor Control% Units PM10 3.00 lb/1,000 gallons transferred PM2.5 0,00 0 lb/1,000 gallons transferred SOx 0,00 C lb/1,000 gallons transferred NOx 0,00 0 lb/1,000 gallons transferred VOC Zfi 5 lb/1,000 gallons transferred CO "..02 c lb/1,000 gallons transferred Benzene 3.-01 95 lb/1,000 gallons transferred Toluene i'.07 95 lb/1,000 gallons transferred Ethylbenzene 0.0a 95 lb/1,000 gallons transferred Xylene ..CP SS Ib/1,000.gallons transferred n -Hexane .._u 55 lb/1,000 gallons transferred 224 TMP C Cr3 PS lb/1,000 gallons transferred 13 of 18 KAPA\2019\19WE0379.CP2 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below ore determined based an requested emissions and throughput. Colorado Regulation 3 PartaA and 8-APEN end Permit Requirements Son -isMMe Non'Aaalnment Area ATTAINMENT 1. Are uncontrolled actual emissions Iram any.criteria pollutants from this individual source greater than 2TPY(Regulation 3, Part A, Section 11.0.102 2. Is the tlot lo.Wc1 at an exploration andproducinn site (e.g., well pad)(Reeulatian 3, P.O.'S...nib:11V 3. Is the loadout operation loading less than 10,000 gallons 1230301st of crude dl per day on an annual average basis] 4. Is the loadoutoaerationloadirg less than 6,]50 bbls per year of condensate via splash file 5. Is the loadout operation loading less than lb 308 Ws per year of condensate via submerged fill procedure, 6. ar total foolryuncontrolled VO I Mans Nox greater Than to TPYaCO emissions greaMthan to TPl (Regulation 3, van B,Soceon 0311 Iron, hive Indiw.Mat .2 he -.r, aamam Area NON.ATTAINMENT I. Are uncontrolled emissions from any criteda pollutants from this individual source ereaMr than l TPY(Regulation 3, PartA, section 11.0.14)3 2. Is the loadout located at an exploration andproduction site (e.g., well pad) (Regulation 3, Part e, Section 11.0.1.1)? 3. is the laadoutoperation loading less Man 10,080 gallons (238 8801 of crude all per day on an annual average basis? a.. h the loadout operation loading lass than 6JSebbls per year ofcondensa le via splash fill Is the loadout operation loading less than 16,308 bbis per year of condensate via submerged RII procedure, 6. Are total facility uncontrolled VOC emissions from the greater than ?TOY NOR greater than 5 TPI or CO emissions greater than to TPY(Reguladen 3, Part @,Section 11.0.21? It Colorado Regulation ] Pert O Section II.C5. . Is this condensate storage tank hydrocarbon liquids Iwdoutloramd at a well production facility, natural gas compressor station or natural gas processing plant] 2. Does Me facility have a throughput of hydrocarbon liquids loadout M transport vehicles greater than or equal to 5,000 barrels] Ilrlulds to .. tlen'r 4ad 0Se•nor. riC5. Section s.a.li 1- Compliance Schedule section ii c 5.a.liil - Operation without Venting Sec.5.a.liiil-loadout Equipment Operation and Mainterce Section S.a(iv)-hoodoutoMervationsand operaMrTaMing Section II.C.54.(v)- Records Section 11.e5.a.IWI-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requirements date Clean Air Act, its implementing regulations, end Al, Quality Control Commission regulations. This document is not e ruk ormmaeHrt, end the analysis If cont.,. may..Poly to a particular situation based wart the Individual facts and circumstances. This document does not change orsubstitute for any lety, .3We /on, on any other legally hinoi g regalrement and is not legally enforceable. In the event &any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, acrd Alr Quality Centrd Commission regulation, the language of the statute or regulation will control. The usedncnmendstmy language such as"recommend—may,""should,"enecan,"is Intended fo tlescnbe APCD interpretations and mecomme dagmx Mandatay terminology such es'must"end'mequlred" are Intended controlling requirements under the toms o'the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish*tatty binotg requirements in and olitself. Go to next question. Go to the next question Go to negt question Go. next question Go to next question The loadout requires a permit Coto next question. Source Is subject to Regulation ] Part [(Section II.C5. Separator Venting Emissions inv:,-into = Section 01 - Administrative Information Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = MMscf per year !MMscf per year Requested Monthly Throughput= 0,7 MMscf per month MMscf per year Requested Permit Limit Throughput = Potential to Emit (PTE). Throughput = Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL liquids throughput: Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: Btu/scf scf/bbl T �( scfh Btu/scf 0,0 MMscf/yr Section 04 - Emissions Factors & Methodologies MW Weight Helium CO2 N2' methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane ;. cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene .,_. Toluene Ethylbenzene ' 40 Xylenes C8+ Heavies d Total VOC Wt Ib/Ib-mol Displacement Equation Ex=Q*MW'X%/C ( 15 of 18 K:\PA\2019\19WE0379.CP2 Separator Venting Emissions inventor/ Emission Factors Separator Venting Emission Factor Source Pollutant Uncontrolled Controlled (Ib/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 2 4165 q0 iS is psis a's anaq..rs 4 mh'�Cga=- c Benzene _.... 10.55 Toluene 150.98 7.55 Ethylbenzene 6.08 0.30 Xylene 37.01 1.38 n -Hexane 1856-05 93.30 224TMP ., 0.00 Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0 0075 17.8675 - AP 42a}E,z} 4 2 (PM10f PM2.5 0 0 75 17,8675 SO x 00006 1.4i0B ss' �G;td - NO s ,. OA.;.,O 168.0640 CO 9:x100 783.3800 ; "' AP -A2 Ci`s � �tnil sCrlakl• :,:.. � Pollutant Pilot Light Emissions Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) (Pilot Gas Throughput) PMSO•� _ 0.0000; a §( ' -' -' r a xe PM2.5 � '�OA000 SOx'.l's'-. '0 f - z` 0.0000 NO - 0.0000,r�. VOC 0,0000 CO 0.0000 Section OS - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tans/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx VOC CO 0.1 0.0 0.0 0.1 0.1 13 0.1 0.0 0.0 0.1 0.1 13 0.0 0,0 0.0 0.0 0.0 1 0.7 0.0 0.0 0.7 0.7 11.8 355.8 0.0 0.0 355.8 17.8 3022 3.2 0.0 0.0 3.2 3.2 537 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM P 1794 0 0 1794 90 12'83 0 0 1283 64 52 0 4 52 3 320 0 0 320 16 15851 0 0 15861 793 C 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Part D, Section 11.8, F Regulation 7, Part D, Section 11.8.2.e (See regulatory applicability worksheet for detailed analysis) NOt enough information Not enough information Not enough information 16 of 18 KAPA\2019\19WE0379.CP2 Separator Venting Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no,•the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Ya, If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids -throughput" (scf/bbl) value in section 03. . Does the company request a control device efficiency greater than 95% for a flare or combustion device?''�. If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 d is 7 -:.,s vrnt-cl.'hs foilo c..estann Section 08 - Technical Analysis Notes AIRS Point # 004 Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only). Process # SCC Code 01 3-19-001-50 Flares Pollutant Uncontrolled Emissions Factor Control % Units P M10 `.7,9 PM2.5 _. 5Ox 1_4 NOx 153.1 VOC 83798.0 CO 743.4 Benzene 211.0 Toluene 151.0 Ethylbenzene -5.1 Xylene 37.'0 n -Hexane 1£55.1 224 TMP 0.0 O Ib/MNISCF O Ib[ WINISCP O ib/EAPASCF O Ib/MMSCIF 95 3b/NIMSCF 0 Ib/ A/11,15CP 95 lb/M MKT= 95 INIVIIVISCF 95 Ib/MMSC= 95 Ib/MMSCF 95 INIVIN7SCF- 95 INIVINISCF 17 of 18 K:\PA\2019\19WE0379.CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements >>v:ce is In the NornAttainmem Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)7 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)7 Ilou have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from thls individual source greater than 1TPY(Regulation 3, Part A, Section ll.D.l.a)7 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? I; -dot enough information Colorado Regulation 7, Part D Section II 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? Not enough Mfg mutton Section II.B.2— General Provisions for Alr Pollution Control Equipment used to Comply with Section II Section II.F - Control of emissions from well production facilities Alternative Emissions Control (Optional Section), a. Is this separator controlled by a back-up or alternate combustion device (I.e., not the primary control device) that is not enclosed? tot enough i,formation Section II.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any otherlegally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'recommend,"'may,"should,"and "oan,"is intended to describe APCC interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of Itself. Condensate Storage Tank(s) APEN o cr Form APCD-205+tvw Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum 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: 19WE0379 AIRS ID Number: 123 / A03D /001 Section 1 - Administrative Information Company Name1: Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Battery Site Location: NENE SEC 18 T2N R67W Mailing Address: (Include It!) Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 Site Location County: Weld NAILS or SIC Code: 1311 Contact Person: Sabrina Pryor Phone Number: (303) 774-3923 E -Mail Address2: sabrina pryor@crestoneprcom 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. 4.)7886 COLORADO Page 5 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / Ao3© / 00'1 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a,General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $353.13 must be submitted along with the APEN filing fee. • OR ❑ MODIFICATION to existing permit (check each box bercw thot apphes: ❑ Change in equipment ❑ Change company name; ✓❑ 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 - 12] APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info 13 Notes: Providing revised throughput and a site -specific emission factor. 3 For company name change, a completed Company Name Change Certification Form (Form APCD• 106) must be submitted. " 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: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate storage tanks TANKS 2/23/2020 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tankls) located at: El Exploration E Production (EEPI site weeks/year ❑ Midstream or Downstream (non EEO) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No Are Flash Emissions anticipated from these storage tanks? 0 Yes No ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? 0 Yes No ■ If "yes", identify the stock tank gas -to -oil ratio: 0.0014 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD• 105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ p ti,. COLOR•DO rw r zr Page 6 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / A03D / 001 Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) ICondensate Throughput: Average API gravity of sales oil: 50.2 NIA Tank design: 0 Fixed roof N/A Requested Annual Permit Limits (bbll year) degrees ❑ Internal floating roof 912.500 RVP of sales oil: 8.8 ❑ External floating roof I Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank bbl (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) g ( y ) Date of First Production (month/year) TANKS 8 4.000 12/2019 12/2019 I Wells Serviced by this Storage Tank or Tank Battery6 (EBP Sites Oniy) I API Number Name of Well Newly Reported Weil 05 - 123 37853 Kugel 1A -18H -H267 ❑ 05 i • 123 • 49480 Kugel 1B -18H -H267 ❑ 05 123 • 37846 Kugel 1C -18H -H267 ❑ 05 - 123 37842 Kugel 1D -18H -H267 • 05 123 37852 Kugel 1E -18H -H267 ■ 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 The EEtP Storage Tank APEN Addendum (Form APCD•212) should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (LatitudelLongitude or UTM) 40.143420. -104.927340 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: Icheck one) ❑ Upward ❑ Honzontal Downward ❑ Other (describe): ❑ Upward with obstructing ramcap Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter trnches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): c Oloiteao Page 7 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / Ao3D / 001 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: NA MMBtu/hr Type: Enclosed Combustor Make/Model: NA Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 96 Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: r❑ Yes ❑ No Pilot Burner Rating: 2,728 0.025 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - 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)? 3 psig Describe the separation process between the well and the storage tanks: Wellhead production to high -low pressure three-phase separator, high-pressure gas to sales, low-pressure gas to sales through VRU or enclosed combustor during VRU downtime. Bulk condensate from separators to VRT and then to storage tanks battery. Produced water to storage tank battery. ,41,,, COLORADO Page 8 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / A03D i 001 Section 8 - 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? El Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) YOC ^Lcse0 Con , Astor iECO1 95°. NOx CO HAPs Erc _sed r.!rmus or tECD Other: N/A 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, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions$ (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC I C 8445 iti ni Sne Specd:c 335 1977 5 Requested values will became 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. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - 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' QQ Yes ❑ No 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 (Ibs/year) Controlled Emissionse (Ibs/year) Benzene 71432 192E•o3 carob, 5teSp.o',c 1;55 8774 Toluene 108883 161E-os 'WM, s4e Spe^,t=c ,a6s .3 24 Ethylbenzene 100414 7 05E C5 tbirobt Site sp !ft: 54 34 s 2 Xylene 1330207 444_-C, ,b0b01 saesperric 455 ( 2css n -Hexane 110543 16,E -0C. Vtoi Site Speak 145;9 ~34 2,2,4-Trimethylpentane 540841 4 3.4E ^5 ib%btt Site Specdic 3s ss 1 ss ' Attach condensate liquid laboratory analysis, stack test results. and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 1403. a Annual emission fees wilt be based on actual controlled emissions reported, If source has not yet started operating, provide projected emissions. . COLORADO Page 9 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / Ao3D 001 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 GP01 or GP08. I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 11/12/2020 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: Q Draft permit prior to issuance Q 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, ILC. for revised APEN requirements. Send this form along with $216.00 and the General For more information or assistance call: Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303)692-3175 OR (303)692-3148 APCD Main Phone Number (303) 692-3150 beffh,z, COLORADO 1-7.::":17.7', .,,»m.,H7' y.a Page 10 of 94 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Source Name: Emissions Source AIRS ID2: i 123 / A03D / 001 I Crestone Peak Resources Operating. 1.LC" j Kugel 1811-11267 Batter) Condensate Tanks Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37850 Kugel 1F -18H-11267 ❑ 05 - 123 - 37851 Kugel 1G -18H-11267 ❑ 05 - 123 - 49486 Kugel 111-181-1-1267 ❑ 05 - 123 - 49482 Kugel 11-18H-11267 ❑ 05 - 123 - 49483 Kugel 1J -18H-11267 ■ 05 - 123 - 49485 Kugel 1K-1811-11267 � 05 - 123 - 49484 Kugel IL -181141267 ❑ 05-123-49481 Kugel 1M-181141267 • 05 - 123 - 49479 Kugel IN -181141267 • - - ■ _ ❑ - ❑ - - ❑ - - ❑ - - ❑ i ❑ - _ ❑ _ _ ❑ ❑ Footnotes: ' Attach this addendum to associated APEN form when needed to report additional wells. If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter A Form APCD-212 B l .b.-APEN FORM 212 - TANKS - Welisite Addendum Page 11 of 94 Produced Water Storage Tank(s) AP Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-2OO) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum 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: 19WE0379 AIRS ID Number: 123 / A03D /002 Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Battery Site Location: NENE SEC 18 T2N R67W Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Sabrina Pryor (303) 774-3923 sabnna pryor@crestoneprcom I 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. 437887 COLORADO Page 12 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / A03D / 002 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $353.13 must be submitted along with the ADEN filing fee. OR ❑ MODIFICATION to existing permit (check each box betow tnar apvlles) ❑ Change in equipment ❑ Change company name3 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 - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Providing a revised throughput and a site -specific emission factor. 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-1041 must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water PW 02/23/2020 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: Q Exploration Et Production (EEtP) site weeks/year ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? O Yes ■ No Are Flash Emissions anticipated from these storage tanks? 0 Yes No ■ Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes 0 No Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? Yes No ■ El Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes ❑r No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ❑ Yes El No OLORADO Page 13 of 94 Permit Number: 19VUE0379 AIRS ID Number: 123 / A03D / 002 Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) N/A Requested Annual Permit Limits (bbl/year) 302,950 Tank design: Q Fixed roof N/A ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Installation Date of Most Storage Tank Recent Storage Vessel in (bbl) Storage Tank (month/year) Date of First Production (month/year) PW 2 1,000 12/2019 12/2019 I Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37853 I Kugel 1A -18H -H267 [] 05 - 123 - 49480 Kugel 1B -18H -H267 gg 05 - 123 • 37846 , Kugel 1C -18H -H267 ❑ 05 • 123 • 37842 . Kugel 1D -18H -H267 ❑ 05 - 123 • 37852 ! Kugel 1E -18H -H267 IN 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 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) t 40.143420.-140 927340 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. l Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (fUsec) I Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing ramcap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): y+r„ COLORADO }. N Page 14 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / A03D / 002 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 , Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: NA MMBtu/hr Type: Enclosed Combustor Make/Model: NA Requested Control Efficiency: C3$ Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: NA Waste Gas Heat Content: 2,728 Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: 025 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? $7 psig Describe the separation process between the well and the storage tanks: Wellhead production to high -low pressure three-phase separator, high-pressure gas to sales, low-pressure gas to sales through VRU or enclosed combustor during VRU downtime. Bulk condensate from separators to VRT and then to storage tanks battery. Produced water to storage tank battery. co�Lo Raoo Page 15 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / Ao3D / 002 Section 8 - 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?❑ Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed wa+nGus!cr fECD, 55=: NQx CO HAPs Enclosed Comb,,-ster E.CO, 95.; Other: N/A 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 I Source Units (AP -42, Mfg., etc.) i Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VQC A5E •02 icIttI Sae Speofic - 2 24 NO„ CO 8 31 tiv.OSr,r AP42— 3e 55E-©3 'ENNIS- +P-42 -- -. -- 182E C2 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. ' Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14.03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions, Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria ❑ Yes 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 (Ibs/year) Controlled Emissions8 (ibs/year) Benzene 71432 317E -G4 inioN Sae Speac Toluene 108883 216E-_4 inroci Stespeanc Ethylbenzene 100414 s 93E -ac VIZI Sae Speca c Xylene 1330207 38SE-:-6 !MCI SaeSpecd-c n -Hexane 110543 1 55E- 4 'MEI Ste Speahc 2,2,4-Trimethyipentane 540841 C ioiott Site SpeaGc No ' Attach produced water laboratory analysis. stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. 4I. COLORADO '1" '47`,7:17;1',.';:'—', Page 16 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / A03D / 002 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 GP05 or GP08. I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 11/12/2020 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: Q 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 $216.00 and the General For more information or assistance call: Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246.1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303)692-3175 OR (303)692-3148 APCD Main Phone Number (303)692-3150 ,p„ COLORADO r..i .,_..n.. Page 17 of 94 E&P Storage Tank Air Pollutant Emissions Notice (AMEN) Addendum Form' Company Name: Source Name: Emissions Source AIRS ID': 123/:103D/002 Crestone Peak Resources Operating, II(' Kugel 1811-1267 Battery Produced Water Tanks Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37850 — Kugel 1F-1811-11267 ❑ 05 - 123 - 37851 Kugel 1G-181141267 �� ❑ -__ 05 - 123 - 49486 Kugel III -1811-11267 ❑ 05 - 123 - 49482 Kugel 11-1811-11267 ❑ 05 - 123 - 49483 Kugel I.I-18H-11267 ❑ 05 - 123 - 49485 Kugel 1K-1811-11267 ❑ 05 - 123 - 49484 05 123 - 49481 r Kugel 11.-1811-H267 ❑ Kugel 1\1-1811-H267 ■ 05 - 123 - 49479 Kugel IN -1811-11267 ■ - - ■ - - ❑ - - ❑ - - ❑ - - ❑ � ____ ___..___ - - ■ _ ❑ - - ❑ ■ - ■ Footnotes: Attach this addendum to associated APE:N form %%hen needed to report additional wells. If this is a newl) report source that has not been assigned an AIRS ID by the APCD. enter `A Form APCD-212 B2.b.-APE\ FORM 212 - PW - Wellsite Addendum Page 18 of 94 Hydrocarbon Liquid Loading APEN Poi i r Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 o new filing fee. This APEN is to be used for hydrocarbon liquid loading only. 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, glycol dehydration unit, 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: 19WE0379 AIRS ID Number: 123 / Ao3D / 003 Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Battery Site Location: NENE SEC 18 T2N R67W Mailing Address: . (Include Zip Code) 10188 East I-25 Frontage Road Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Sabrina Pryor Phone Number: (303) 774-3923 E-Mait 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. i Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 437888 �o4ok.00 v' Page 19 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 /A03D/003 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $353.13 must be submitted along with the APEN filing fee. -OR- Q MODIFICATION to existing permit !check each box below that applies; ❑ Change fuel or equipment ❑ Change company name3 O 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: Requesting a revised throughput and site -specific emission factor. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. d 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: Truck IOadout of condensate from tanks Company equipment Identification No. (optional): LOAD -1 For existing sources, operation began on: 02/23/2020 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes ❑ No IS Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No ■ p Does this source load gasoline into transport vehicles? ❑ Yes No • Is this source located at an oil and gas exploration and production site? ❑ Yes No ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annualEl average? Yes No ■ Does this source splash fill less than 6,750 bbl of condensate per year? Yes No p ■ Does this source submerge fill less than 16,308 bbl of condensate per year? ❑ Yes 0 No COLORADO Page 20 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 /A03D/003 Section 4 - Process Equipment Information Product Loaded: Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 912,500 bbl/year Actual Volume Loaded: This product is loaded from tanks at this faci ity into: Tank Trucks (e.g. "rail tank cars" or "tank trucks") bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0 6 Average temperature of bulk liquid loading: 65.01 F True Vapor Pressure: 4.0 Psia @ 60 F Molecular weight of displaced vapors: ^ Q � 48 4 tb!lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl /year Product Density: Load Line Volume: lb/ft' fN/truckload Vapor Recovery Line Volume: ft'/truckload 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. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40 143420,-104-927340 Check box if the following information is not applicable to the source because emissions will not be emitted frorn 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): Interior stack diameter (inches): Interior stack width (inches): ❑ Upward with obstructing raincap Interior stack depth (inches(: fir.. COLORADO Page 21 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 /A030/003 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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: °b ❑ Combustion Device: Used for control of: vs. HAPs Rating: NA Type: Enclosed Combustor MMBtu/hr Make/Model: NA Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NA F Waste Gas Heat Content: 2.728 Btu/scf Constant Pilot Light: Yes ❑ No Pilot Burner Rating: 0.025 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: 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? El Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SO. NO. CO VOC Ent,,...ti m,bustor,.ECO, 95-, _ HAPs Enclose -I Combustor tECO 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL N/A Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)s Uncontrolled Oasis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SO. NO. s oM ate AP -42 541E•02 CO 0 31 ItNMMBtu ,4P-42 3 43 VOC r,t 15 IOtbtv Sile SPeuGc � 0 2.64 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, a a�..C0L0RAD0 % �.� .... .z, ... F..,. Page 22 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 //21/403D/ 003 Section 8 - Nan -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria 0 Yes ❑ No 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 -41, Mfg., etc.) Uncontrolled Emissions fibs/year) Controlled Emissions (tbs/yeor) Benzene 71432 267E-04 lb/bbi S4eSpecoc 240 !zaz Toluene 108883 220E.04 Ib:bt: s?eSoe:fr.: 201 1003 Ethylbenzene 100414 9FxE oe 1c;tti Sae Speofic 891 044 Xylene 1330207 6c6E-05 tblbbi saeSaec:{ic 5648 27, n -Hexane 110543 2 2CE Ga 4h,bc 54eSeeceic 2011 1e1 2,2,4-Trimethylpentane 540841 s 94E.ce ,o/be .54e Spec. c 5 42 c 2- Other. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - 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 GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. 11/12/2020 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: []✓ Draft permit prior to issuance Q 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 $216.00 and the General For more information or assistance call: Permit registration fee of $353.13, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303)692-3175 OR (303)692.3148 APCD Main Phone Number 1303) 692-3150 „2„,„ COLORADO nP, , n � Page 23 of 94 Gas Venting APEN - Farm APCD-211, Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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/tiquid 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, ILC, for revised APEN requirements. Permit Number: 1 9WE0379 AIRS ID Number: 123 / A03D / 004 RECEIVED I1D 41220 AVC tai Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Site Location: NENE SEC 18 T2N R67W Mailing Address: (include lip Code) 10188 East I-25 Frontage Road Site Location County: Weld NAICS or SIC Code: 1311 Firestone, CO 80504 Contact Person: Sabrina Pryor Phone Number: (303) 774-3923 E -Mail Address2: Sabrina pryor@crestoneprcom I 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. 437889 wy COLOR 00 Page 24 of 94 Permit Number: 19WE0379 AIRS ID Number: 123 / Ao3© / 004 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source -OR- ® MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company namel O Add point to existing permit O 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 & Notes: emission factor. Providing a revised throughput and site -specific a For company name change, a completed Company Name Change Certification Form (Form APCD• 1€161 must be submitted. ' 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 Low pressure separator emissions during VRU downtime controlled by enclosed combustor. Company equipment Identification No, ioptionor): Buffer For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 02/23/2020 ❑r Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 Will this equipment be operated in any NAAQS nonattainment area? hours/day 7 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 52 Yes Yes Yes weeks/year EI No EI No ❑ No 'COLORADO Page 25 of 94 Permit Number: 1 9WE0379 AIRS ID Number: 123 / A03D / 004 Section 4 - Process Equipment Information Ej Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: Blowdown Events of Events/yeas: ❑ Other Description: Serial >: of Pistons: Volume per event: Capacity: Leak Rate: gal/min Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy far 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 Parameters5: Vented Gas Properties: No Vent Gas Heating Value: 2 398 BTU/SCF Requested: 8.5 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl /year Actual: bbl/year Molecular Weight: 41.9201 voc (weight %) 75.6805 Benzene (weight `.) 0.1908 Toluene (weight %) 0,1365 Ethylbenzene (weight ib) 0.0055 Xylene (weight .%) 0,0340 n -Hexane (weight %) 1.6871 2,2,4•Trimethylpentane (weight %l 0.0007 Additional Required Documentation: Attach a representative gas analysis (including BTEX a n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX i3 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. COLOR A DO Page 26 of 94 Upward ❑ Horizontal Permit Number: 1 9WE0379 AIRS ID Number: 123 / A03D / 004 Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.143420.-104.927340 ❑r 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 Ground Level (Feet) Temp. (.F) (*F) Flow Rate (ACFM) Velocity (ftlsec) r i Indicate the direction of the stack outlet: (check. oe) ❑ 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: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑ Combustion r Device: Pollutants Controlled: V©Cs, HAPs Rating: N/A MMBtu/hr Type: Enclosed Combustor Make/Model: N/A Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ® Yes ❑ No Pilot burner Rating: 2,398 0.025 Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: cacoR*rc Are Page 27 of 94 Permit Number: 1 9WE0379 AIRS ID Number: 123 / A03D / 004 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? ✓[� Yes ❑ No If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SO. NO. CO VOC E^c+used Corrbusior 55'. HAPs Enclosed C ustor 95% Other: i N/A 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, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SO. NO. CC68 ,blMMEitu AP 42 -. .. .. 069 CO 03' Ib,MM6tu i AP 42 - 3'6 VOC 83'08 TAIMscf 5,1e spa&,, - 358 1?'a 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 Yes 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 (Ibs/year) Benzene 71432 211 1sc, Sde sped5c 1794 8989 Toluene 108883 151 m,vrasa site scec,nc 1284 84 19 Ethylbenzene 100414 6,04 ttirh4Hsc1 Sde speak 5936 257 Xylene 1330207 376'. IbtMMSU S,tespeu!;c 320 1598 n -Hexane 110543 1866 b1MMse S4espec* 1586' 753 2,2,4-Trimethylpentane 540841 0 82 mrr rM5r, Site specific 6 98 0 35 Other: No 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. ^, COLORADO g w. rY w Page 28 of 94 Permit Number: 19 y v E0379 AIRS ID Number: 123 r Ao3D i 004 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 11/12/2020 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: Draft permit prior to issuance Q 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 S216.00 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 4y;, COLORADO Page 29 of 94 Hello