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HomeMy WebLinkAbout20203834.tiffCOLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 16, 2020 Dear Sir or Madam: RECEIVED DEC 2 1 2020 WELD COUNTY COMMISSIONERS On December 17, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Crestone Peak Resources Operating, LLC - lone NE2H 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 Pubs ;c Izev,e(A) o l/O6 /21 Cc: Pl.(TP) HL(Ds i R) Pw(rm/ER/cH1cK) O6(514) iz/n/2o 2020-3834 CDPHE Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating, LLC - lone NE2H Battery - Weld County Notice Period Begins: December 17, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Crestone Peak Resources Operating, LLC Facility: lone NE2H Battery Well production facility NWNE Section 2, T2N R66W Weld County The proposed project or activity is as follows: The permittee submitted an application to modify a well production facility located in the ozone non -attainment area. With this application, the operator is requesting to permit flaring of natural gas from the low pressure separators when the VRU is down. The application brings the facility to synthetic minor status for Title V for VOC (under 50 tpy). The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0666 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.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health 6 Environment COLORADO Air Pollution Control Division Department cf Pubhc Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0666 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: lone NE2H Battery Plant AIRS ID: 123/9BB4 Physical Location: NWNE Section 2, T2N R66W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Buffer 006 Flaring of natural gas vented from the low pressure side of six (6) high/low pressure (HLP) separators and routed through the buffer house during vapor recovery unit (VRU) downtime. Enclosed Combustor(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section I I.A.4. ) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Buffer 006 --- --- 0.6 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve (12) month total.By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and demonstrate compliance with the limits in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 CliP,tter COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Equipment ID AIRS Point Control Device Pollutants Controlled Buffer 006 Emissions from the low pressure side of six (6) high/low pressure (HLP) separators are routed through the buffer house to enclosed combustor(s) during vapor recovery unit (VRU) downtime. VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Buffer 006 Liquids throughput of condensate tanks during VRU downtime 39,785 bbl The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelvemonths' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. 10. The owner or operator must use monthly VRU downtime records, monthly condensate throughput records, calculation methods described in the OItM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (OftM) 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 oam plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. PeriodicTestingRequirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health b Envirorment Dedicated to protecting and improving the health and environment of the people of Colorado For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit (permit -required points only) 001 Condensate tanks VOC NOx 50 50 27.6 0.3 005 Condensate loadout 006 Separator flaring -- Insignificant Sources (APEN- and/or permit - exempt) Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. Page 6 of 10 COLORADO Air Pollution Control Division Department cf Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC.' Permit for flaring of low pressure gas vented from the low pressure side of HLP separators at an existing well production facility. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Buffer 006 Benzene 71432 69.68 3.48 Toluene 108883 68.29 3.41 Ethylbenzene 100414 2.19 0.11 Xylenes 1330207 18.63 0.93 n -Hexane 110543 625.83 31.29 2,2,4-Trimethylpentane 540841 0.16 0.01 Note: All non -criteria reportable pollutants 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 8 of 10 g,tz- COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 006: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 0.5596 0.0280 Gas Analysis (4/20/2020) 71432 Benzene 0.00175 0.0001 110543 n -Hexane 0.0157 0.0008 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The VOC and HAP emission factors listed above are based on a site specific extended gas analysis obtained 4/20/20. The weight % values and molecular weight (28.7389 lb/lbmol) from the sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10) were used to determine the emission factors. NOx and CO emissions are based on a site -specific gas heat value of 1562.4 Btu/scf, and are below the APEN reporting threshold. Actual emissions are calculated by multiplying the emission factors in the table above by the total throughput of liquid from the condensate tanks while the VRU is down. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Andy Gruel 433699 7/22/2020 12/8/2020 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploration .& Production Well Pad What industry segment.0i1 & Naturat Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) 123 9BB4 lone NE2H Battery Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NWNE 2 2N 66 Leave Blank - For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) 006 Emissions Source Type Separator Venting Equipment Name Buffer Emissions Control? Yes Permit if (Leave blank unless APCD has already assigned) 20W E0666 Issuance a 1 Self Cert Required? Yes Action Permit Initial Issuance Engineering Remarks Section 03 - Description of Project Creston Peak Resources Operating, LLC (Crestone) submitted an application to modify a well production facility located in the ozone non -attainment area. With this application, the operator is requesting to modify the existing condensate storage vessel source in addition to permitting flaring of natural gas from the low pressure separators. This analysis only evaluates the separator venting source. The application brings the facility to synthetic minor status for NANSR and Title V for VOC (under 50 tpy). Public comment is required for this application because new synthetic minor limits are being established in order to avoid other requiremen Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Yes " new VOC syn mirror limit for NANSR Section 05 - Ambient Air Impact Analysis Requiremer 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? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: SO2 Prevention of Significant Deterioration (PSD) 000000 Title V Operating Permits (OP) 00000 Non -Attainment New Source Review (NANSR) Is this stationary source a major source? - If yes, indicate programs and which pollutants: SO2 Prevention of Significant Deterioration (PSD) 000000 Title V Operating Permits (OP) 00000 Non -Attainment New Source Review (NANSR) No Yes VOC ❑' VOC 0 PM2.5 PM10 TSP HAPs 000 PM2.5 PM10 TSP HAPs 000 NOx CO ❑ No NOx CO " 0 �i`-tI Y1 _:ons I; Section 01.- Administrative Information (Facility AlRs ID: 123 County 0,06 Point Section 02- Equipment Description Details Flaring of natural gas vented from he law pressure side of six (6) high/low pressseparators and routed through the buffer fro Detailed Emissions Unrt Oes<ripton Emission Control Device Description: Requested Overall VOC & HAP Control Efficienry %: Limited Process Parameter Enclosed Comburtor(s) during vapor reca Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Separator Actual Throughput Barrels(bbl) per year ry unit (VRU) downtime 95 Requested Permit limit Throughput= 39,785.0. Barrels (bbl) per year Requested Monthly Throughput= __...: Barrels (bbl) per month Potential to Emit(PTE)Throughput= 397..7 Barrels (bbl) per year Secondary Emissions -Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: 1562.4 Btu/scf 17.7. scf/bbl from 4/20/2020 gm sample from Prom. Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: 26 sdh 1000 Btu/sof Mmed/yr ... J MMatu/yr Section 04 -Emissions Factors & Methodologies Description Six (6) wells produce to six (6) high/low pressure (HLP) separators. The high pressure gas from the high pressure side of the HLP separators is routed to the sales tine via vapor recovery units. The law pressure gas from the low pressure side of the HLP separators is typically routed through a buffer house (liquids knockout) and then to the sales Iirm via vapor recovery units. During vapor recovery unit downtime, the low pressure. gas vented from the low pressure side of the HLP .parators is routed through a buffer house (liquids knockout) and then to the enclosed mbustor(s). Inodrto develop site specific emission factors, the operator used a sitesp ecHic sales gas sample and a pressurized liquid sample collected on 4/20/20. The operator then used Pram.. model the LP gas production rate(scf/bhl condensate). The composition of the gas is taken from astespeclHc gas. sample collected 4/20/20. Prom. modeled gas flow rate MW of gas (from sample) Promax model basis 0.001929 28.7389 109:0 Modeled gas rate Weight% /./ .04787A oxygen/Argon CO2 N2 methane ethane propane sobutane n -butane Isopentane n -pentane ryclopentane n -Hexane cyclohexane Other hexanes heptanes metnylryclohexane 224-TMP Benzene Toluene Ethylbenzene Kylenes CB+ Heavies ,TT/G4;3058 28.3848 21.6300 16.9934 3.7702 8.5147 3.4008 3.7229 0.1585 1.1721 0.2662 1.9802 0.6867 0.2582 0.000.3 0.1305 0.1279 0.0041 0.0349 0.4749 Total VOC Wt % MMSCFD b/Ibmol barrels per day of condensate production scf/bbl Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/bbl) (Ib/661) (Liquid Throughput( (Uquid Throughput) Emission Factor Source VOC Benzene Toluene Ethylbenzene xylene ',Hexane 224TMP 0,.0006 0.000601;2 Extended gas analysis :Extended gas analysis .tended gas analysis nded gas analysis nded gas analysts nded gas analysis nded gasanalysts Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) Ib/bbl (Waste Heat Combusted( (Gas Throughput) Emission Factor Source PM10 PM2.5 SOK NOx CO 0.0075 0 006 0 0.Un19 0.926 0.3100 Emission Factor Source Pollutant Pilot Dght Emissions Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) (Pilot Gas Throughput) PM10 PM2.5 0:0075 0.0075 0.0006 0.0680 NOx VOC Co 0.3100 2 of - K:\PA\2020\20WE0666.CP1 Separator Venting Emissions Inventory Secilon OS Emissions venton Cmerla Pollutants Potential to Emit Uncontrolled (tons/yew) Actual Emissions Uncontrolled Controlled itons/Yearl Dons/year) Requested PermR Limits Uncontrolled Controlled (Moshe.) DmsAmar) Requested Monthly Limas Controlled Ilbs/manthl PM30 PNRS SOx NOx VOC ` CO 0015 0005 0005 1 0 Lid O 00 0 OS 1 Dow 0000 00.4 0 OCnS 0045 004 8 I1132 11133 054/ 05 041 0004 0201 31 Hazardous Alr Pollutants Potential to Emit Uncontrolled (lbs/yearl Actual Emissions Uncontrolled Hbs/yearl Controlled Ms/xar) Requested PermR Umrts Uncontrdled Controlled fibs/year) Ill,s/war) eenlene Toluene Ethylbentene %ylene nflexane 224Th1P 69 68 69 64 3 48 49'29 fie 19 3 91 219 013 011 18.65 1863 003 52, 63 62S 83 3 29 010 010 001 Section 06 Regulatory Summary Malys Regulation Pans 8 Regulation? Part Section II F Regulation 7 Part D Section 1183 e (See regulatory eppllcabllity worksheet for detailed analysis) Source retain s a permit sot c Is nor abject to Re:eta-017 Part° Xdi n IR2 F The canoe d vice for this,varat0r is not wbc,ct r q Sul Mon' Pr D SKtion Il 82 Section 07 Initial and Periodic Sampling and Testing Requirements Using Llyddlluaughput to Monitor Compliance i Does the company use slte specific emsslon factors based on apressurized liquid sample (Sampled upstream of the equipment covered under the AIRS ID) and process simulation to estimate emhslons7 es f, This sample 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 an line) then rt may be appropriate to use an older site -specific sample If no the permit will contain an Initial Compllarse carting requirement to collect asne-specific liquid sample and conduct an emission factor analysis to demonstrate that the mission factors are less than or equal to the emissions (actors established wrth this application Does the company request a control device efficiency greater than 95% for a flare or combustion dente? If yes the permit will cantata mrtlal and periodic compliance testing in accordance with PS Memo 2002 Section 08 Technical Analysis Notes_ _ _ _ __ _ _ _ 1 Betiusethewells began production before 08/01(1010 and have not ban recompleted the separators covered bythispolm a tNOTsubiect to Regulation) PartD SMion IIF — , 2. The este ed gas analyss used to establish emssionfactors In this application was obtained from the outlet of the buffer hone iliquWs knockout for low pressuregasvemedfrom(he low pressuresde of the HLP separators) at Om t s, I.faNlty As a result it Ft representative of only low pressure gas that rsvented to and coARrolled by the enclosed combustors f 'r V y a '2 C v-' i t/ r ' i T x/ ' - F. 3 NOx and Q3 emissions from the source are below APEN rep6rtingthresholdi'Asa result emission limits are not included In the permrtior NOa nor CO ' 2 1 / _ '`�a 14 During normal operations- low pressure gas vented from the tow pressure side of the HLP separators Is captured usingvapor recovery units BMW) and routed to the sales brie During VRU dOWntric the low pressiireens h routedT through the buffer house (liquids knockout) and'herr to the endosed combustors VRU downtime trading h required m the permit to quantify the volumeo( gas vented from the separators and routed to the enclosed combustoris) bored a on the liquids throughput to the storage tanks 2f, 3 r .. r- _ ' y r r 3 19. y ss 74', 3. .. �:,o. 303 rr at"r L 3- ' J v n 1' /T m " er'• r') fFss+c'r� { S. n hexane s the only reportable HAP As a result rs theonly HAP forwhlch anemissionfactors included to the permit t/r'� /� 7 ^ pr.#t yc I/ , f�: h. 'i,(� r,a/tr c / S t liuv.nv e fir, -/ f 'yr' 'G`-,t,a 1 'G tT,_779 r2' wx 6 It should denoted that an emsslon fadorfor VOC associated with pilot light combustion'. not incorporated into the permit This s due to the fact that the plot fght only resuRs m a negligible contribution of VOC The minimal amount of emission does not impact the total VOC limit for this source and thereforecan be ignored - v r Fs r rc w r P4 a' f a. 2. 4 Y - 1 - x Section 09 SCC Coding a nd Emissions Factors (For Inventory Use Only). ( AIRS PointR Processor SCC Code Pollutant Uncontrolled Emissions FactorControl% Units Ol 10.001 9 Cris G..s PM10 02 la/ COO bar,. rs - PM2.5 0 _ 0 CCO artea SOa 00 0 Ile/IS/ 000 hi arrris i NOx 1.3 lb/1000 ba 4 VOC b5n6 95 6/1000barr Is CO 103 0 b/1000 burr Is Benzene 19 95 ./1000 barrels Toluene 1 35 h/1000h rrcls Ethylbentene 0Co a5 ha.°barrels Xylene 0 Y. 1 Ib 10L0 barrels n Hexane 157 95 lb/1000 harm's 224 TMP O0 e5 to/10,0 bar.I 1 I 1 i 3 of 5 K \PA\2020\20WE0666 CP1 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 ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 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 II. D.3)? NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 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)? Yes Yes Colorado Regulation 7, Part D, Section II 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? No Section 11.8.2 — General Provisions for Air 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? Source Requires an APEN. Go to the next question Source Requires a permit Source is not subject, do not go to next question *ti"�� llgk`�r The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e _ startl,�. � P j 8 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 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 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 "can," is intended to describe APCD 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. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Crestone Peak Resources Operating, LLC County AIRS ID 123 Plant AIRS ID 9BB4 Facility Name lone NE2H Battery Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate storage tanks, total 7200 bbl capacity 1000 1197 27.73 337 8791 24.8'2 5.7 002 XA Six (6) fixed roof produced water storage vessels. (Total Capacity: 1 410 bbls) 31 96 0.1 .,.. 003 ... _. GP02.0N_ SI RICE GM Vortec 5.7L NA, 4SRB, 92 HP, SN TBD _.... ... 0.0 004 GP02,CN SI RICE GM Vortec 5,7L, NA, 4SRB, 92 HP SN: TBD 0,0 005 13WE2520 Condensate Loadout 792 319 564 24 248 1.0 006 20WE0666 Separator venting "Buffer' 70 68 2 19 626 0 0.4 0.0 0.0 APEN-Exempt/Insignifcants 0.0 Fugitives 4 12 1 14 31 0.0 Hi -Low Separators (5) 2 39 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.9 0.8 0.3 0.2 4.9 0.0 0.0 0.0 0.0 7.2 `Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissmns < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (iPY) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate storage tanks, total 7200 bbl capacity 49.99 59.83 1.39 16.83 440 1.24 0.3 002 XA Six (8) fixed roof produced water storage vessels. (Total Capacity: 1 41.0 bbls) 31 06 0.1 003 GP020N SI RICE GM Vortec 5,7L NA, 4SRB, 92 HP, SN TBD 0.0 004 GP02 CN SI RICE GM Vortec 5.7L NA, 4SRB, 92 HP, SW TBD _. _.. 0,0 005 13WE2520 Condensate Loadout 792 319 564 24 248 1.0 006 20WE0666 Separator venting"Buffer" 3 3 0 1 31 0 0.0 0.0 0.0 APEN-Exempt/Insignificants 0.0 Fugitives 4 '12 1 14 31 0,0 Hi -Low Separators (5) 2 39 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.4 0.2 0.3 0.0 0.4 0.0 0.0 0.0 0.0 1.4 5 20WE0666.CP1 12/15/2020 jig 2 2 2020 Gas Venting APEN - Form APCD- 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/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO) 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: 2C)vvEQ)f la,6 AIRS ID Number: 123 / 9BB4 / (-)0(, Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: lone NE2H Battery Site Location: NWNE Section 2, T2N, R66W Mailing Address: 10188 East I-25 Fronts a Road (Include Zip Code) 9 Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Sabrina Pryor (303) 774-3923 sabrina.pryor@crestonepr.com 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. ''.PC 2020 1 � 433697 COLORADO '• h�...... d naE m+aa..-...e Page 12 of 65 f Permit Number: !r _ AIRS ID Number: 123 / 9BB4 / Section 2 - Requested Action 0 NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Buffer (separator) gas venting controlled by enclosed combustor. Company equipment Identification No. (optional): Buffer For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 09/01/2020 • Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year 0 Yes ❑ Yes ❑ Yes ❑ No O No O No I aw COLORADO 2 ew.h Invoomr Page 13 of 65 Permit Number: AIRS ID Number: 123 / 9BB4 / Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ Yes El No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 39,785 bbl/year Actual: __ bbl/year Molecular Weight: 28.7389 voc (weight %) 41.6966 Benzene (weight %) 0,1305 Toluene (weight %) 0.1279 Ethylbenzene (weight %) 0,0041 Xylene (weight %) 0.0349 n -Hexane (weight %) 1.1721 2,2,4-Trimethylpentane (weight %) 0.0003 Additional Required Documentation: 0 Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX it n -Hexane, temperature, and pressure) 5 Requested values wilt 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. CD 11 v 3 I n COLORADO Aqsartnt.At inAk it* s c.,.`ran.e.ne Page 14 of 65 Permit Number: AIRS ID Number: 123 / 9BB4 / Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or U7'M) 40.173261/-104.737972 El Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (. F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 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 Device: Pollutants Controlled: VOCs, HAPs Rating: N/A MMBtu/hr Make/Model: NIA Type: Enclosed Combustor Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 % Minimum Temperature: NSA Waste Gas Heat Content: Constant Pilot Light: El Yes ❑ No Pilot burner Rating: 1,562 0.025 Btu /scf MMBtu / hr Other: Pollutants Controlled: Description: Requested Control Efficiency: I� coLon:oo 4 maw •Is ..rear Page 15 of 65 Permit Number: AIRS ID Number: 123 / 9BB4 / 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 Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? 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 �1, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (ionslyear) Controlled Emissions (tons/year) PM SO, NO), 0.068 b/MM81u AP -42 - - - CO 0.31 b/MMBtu AP -42 - - - VOC 0.56 brobl Site specific — — 11.13 0.56 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide - projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -41, Mfg., etc.) Uncontrolled Emissions (tbs/year) Controlled Emissionsb (tbs/year) Benzene 71432 1.75E-03 lb/bbl Site specific 69.7 3.5 Toluene 108883 1.72E-03 b/bbl Site specific 68.3 3.4 Ethylbenzene 100414 5.56E-05 brow Site specific 22 0.1 Xylene 1330207 4.68E-04 blbbl Site specific 18.6 0.9 n -Hexane 110543 1.57E-02 bfbbl Site specific 626 31.3 2,2,4-Trimethylpentane 540841 3.93E-06 lb/bbl Site specific 0.16 7.82E-03 Other: Yes ❑ No 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. o_ CD -211 COLORADO 5( Page 16 of 65 Permit Number: AIRS ID Number: 123 i 9BB4 i Section 9 - Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. - r 07/22/2020 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 5216.00 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 __ 211 �',�., fi'�1T1 .� _�! _ DI. COLORADO 6 ....d...lk omrt - wz...r.....n Page 17 of 65 Hello