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HomeMy WebLinkAbout20203824.tiffCOLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 9, 2020 Dear Sir or Madam: RECEIVED DEC 18 2020 WELD COUNTY COMMISSIONERS On December 10, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Crestone Peak Resources Operating, LLC - lone NW2H 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 & 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;ew 01/04/21 Gc .pLoP), HL#S/rR) pW(3-k/ER/cN/cl, oG(sK) 12/21 /2O 2020-3824 440 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating, LLC - lone NW2H Battery - Weld County Notice Period Begins: December 10, 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 NW2H Battery Well production facility SWNW 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 20WE0590 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 Zia COLORADO Department of Public Health 6 Environment g44.00 ,tz- COLORADO Air Pollution Control Division Department of Public tfealfh 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0590 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: lone NW2H Battery Plant AIRS ID: 123/9BFC Physical Location: SWNW 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 nine (9) 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 Heatth b 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 NO, VOC CO Buffer 006 --- --- 1.8 --- Point N Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve (1,2) month total,By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and demonstrate compliance with the limits in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health b 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 nine (9) high/low pressure (HLP) separators are routed through the buffer house to enclosed combustor(s) during vapor recovery unit (VRU) downtime. VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section I I.A.4. ) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Buffer 006 Liquids throughput of condensate tanks during VRU downtime 51,100 bbl The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. 10. The owner or operator must use monthly VRU downtime records, monthly condensate oil throughput records, calculation methods described in the OEtM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 3 of 10 r 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 &t MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7. ) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or Page 4 of 10 • '?ag 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 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 V.A.7.6). 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: Page 5 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 AIRS Point Equipment Description r Pollutant Emissions - tons per year Threshold Current Permit Limit (permit - required points only) 001 Condensate storage tanks VOC NOx 50 50 12.6 0.4 005 Condensate loadout 006 Separator flaring 007 Condensate storage tanks -- Insignificant Sources (APEN- and/or permit -exempt) Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. Page 6 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 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. 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 Er 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 115.25 5.76 Toluene 108883 50.73 2.54 Ethylbenzene 100414 1.07 0.05 Xylenes 1330207 10.04 0.50 n -Hexane 110543 865.50 43.28 2,2,4-Trimethylpentane 540841 0.13 0.01 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab a and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 006: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 1.4108 0.0705 Gas Analysis (4/22/2020) 71432 Benzene 0.0023 0.0001 110543 n -Hexane 0.0169 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 4/13/18. The weight % values and molecular weight (32.4874 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 gas heat value of 1821.8 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 MACT 63.600-63.1199 Subpart AA - Subpart DDD Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1200-63.1439 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 q: Received Date: Review Start Date: For Division Use Only Andy Gruel 431307 6/16/2020 11/18(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 segmentiOli& Natural Gas Production & Processing , Is this facility located in a NAAQS non -attainment area? Yes - If yes, for what pollutant? Ozone (NOx& VOC) Crestone Peak Resources Operatic LLC 123 9BFC lone NW2H Battery Weld County Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRS Point if (Leave blank unless APCD has already assigned) Emissions Source Type Equipment Name Emissions Control? Permit # (Leave blank unless APCD has already assigned) Issuance 4 Self Cert Required? Action Engineering Remarks 006 . ..- .: SeparatorVentting Buffer ... Yes 20WE0590 1 Yes Permit Initial. Issuance Quadrant Section Township Range SWNW 2N 66 Section 03 - Description of Project Crestone Peak Resources Operating; L LC (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 permit the flaring of natural gas from the low pressure separators. The application brings the facility to synthetic minor status for Title V for VOC (under 50 toy). Public comment is required for this application because the permit establishes a new synthetic minor limit on VOC below 50 tpq and the NANSR threshold. Sections 04, 05 & 06 - For Division Use Only Section 04- Public Comment Requirements Is Public Comment Required? If yes, why? Reques0ng Synthetic MinarPe mil Section 05 - Ambient Air Impact Analysis Requiremer Yes new syn minor limiifor VOC for NANSR 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: 502 Prevention of Significant Deterioration (PSD) 00000 Title V Operating Permits (OP) 0000 Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: 502 Prevention of Significant Deterioration (PSD) 00000 Title V Operating Permits (OP) 0000 Non -Attainment New Source Review (NANSR) ` ' : I Yes ' NOx CO VOC ❑ Q No NOx CO VOC ❑ O PM2.5 PM10 TSP HAPs ❑ ❑ 000 PM2.5 PM10 TSP HAPs ❑ ❑ DOD Section 01 -Administrative Information Facility AIRS 10: Count 98FC Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission control Deuce Dwcnpton Enclosed Conhuai'ar(s) Requested Overall VOC Pr HAP Control Efficiency %: Limited Process Parameter as°0I tad from the low pressu ,de of n(ne (g}h gh/I presauca sep ngvapor recovery unit W50) downtime Section 03 -Processing Hate Information forEmissions Estimates Primary Emissions - Separator Actual Throughput 'r 41V.'. Ba rels(bbl) per year pis androuted through the buffer house. Requested Permit Ulnh Throughput =_t_1,1 A.51,10.0 Barrels (WI) per year Requested Monthly Throughput= 154e.2 Barrels (HA per month Potential to EM1 iPTE) Throughput= 51154.; Barels(bbI) per year Secondary Emissions -Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas ernatad per BBL of liquidsthraughput: 3341.3 etu/scf rob scf/bbl from s,teepecific gas sample wellected4/13/18 Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: Description Wells produce tonine (9)high/low pressure (HLP) separators The high pressure gas from the high pressure side of the HLP separators is routed to the sales lne via yap. recovery units. The four pressure gas from the tow pressure side of the HIP separatoreis typically muted through a buffer house (liquids knockout) and then to the les line vie vapor recovery untr ring vapor recovery unit dovn0me the low. pressure gas vented from the low pressure side of the IMP separators Is routed through a buffer houm(liquids knockout) and then to the enclosed combistorts). In order to develop the site specific emission rate(scf/bbll using Prom, the operator wed site-specificsaies gas sample and a pressurizedlquid sample collected on 4/13/2018. Theoperator*. used Prom.. to mer. the LP gas production rate erf/bblcondensate). The operator collected tespecfc sample of the vented gas. on 4/13/18 to use the gas composition for emission factor development. These samples are "over a year old from•he date of application su.nitral, but they are acceptable and representative because no new wells have come online through this point snce the sample was taken. Promax modeled gas flow rate � ., -. 0.00422822IMMscro Promax model basis Modeled gas rate 4olbarrels per day of condensate production .� ._ scUbbl Molecular weight 32.4824 Weight% Oxygen/Argon CO2 N2 methane ethane propane isobutane n -butane 0.1966 3.7200 0.7502 19 22.1392 24.4461 5:6601 :0841 3'.9402 4.1064 opentane n -pentane cyclopentane .Hexane ryclohexane Other hexanm Mot.. methylryclohexane 224-rMP Benzene Toluene Ethylbenxene Xylenes C8e Heavies 0.466 0.1124 1.2520 0.1960 0.0598 0.0001 0.0379 0.0008 0.0025 0.0688 is ion Facto Total UDC W % Pollutant Deroene Toluene Ethylbenrene %ylene mole one 224 TMP Pollutant eparator Ven Uncontrolled (lb/bbl) (Liquid Throughput) ng Controlled (lb bbl) (Liquid Throughput) Primary Control Dev Uncontrolled (Ib/MMatu) (Waste Heat C- ombusted) .0.0025'- - 0.0025 0.0006 0.0680 0.0054 0.3100 ()noonvaned Ib/hhl (Gas Throughpu Emission Factor Source Emission Factor Source 2 of KARL\202°\2DWE0590.CP1 Sepa ator Vent ng Emissions Inventor/ SecBan OS Emissions Inventory Cr... Pollutants Potential to Emit Uncontroled Dons/year) Actual Emissions Uncontrolled Controlled Itons/ycad (tons/year) Requested Permit limns Uncontrolled Controlled (tons/year) (tons/year) RWumted Monthly limns Controlled 0bs/month) PM10 PM25 sox NMI VOC —CO 0 1 0513 otr11 0011 0 O 0011 2 Oml o Ol 0001 0 0 04 0104 01 1R >G v..B 3C 049 003 00 0475 0415 0475 it Hatardous AU Polbutants Potential to Enid Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled ohs/seer) Ohs/teal Requested Permit Limos Uncontrolled Controlled O6s/xad Ims/year) J Monne Toluene Ethylbenlene Kylene n -Hexane 226 TMP 1 S25 1 s2 5 l 01J ra /3 Ss 107 107 _ _ 005 1004 1001 80> 2 SRS SO 3_B o_ 013 903 / Section 06 Regulatory Summary Analysis 1 Regulation Parts ArB Regulation 7 Part D Section II B F Regulation 7 Part D Section II B 2 e (See tegulatory applicability worksheet for detailed analysis) Sour e [Min, rain I $a5r<snot urect.c ularlan7l ^L S ttan Ile the ono. I ocvlce fort, 'aerator s rat ubntt to Ye a0-nl PartD Sec inn II 0 2 e Section 07_ 'War and Pedalo Sampling and Testing Requirements Using Uquld Throughput b Monitor Compliance Does the company uses. speed's emsson factors based on a pressureed liquid sample (Sampled upstream of the ,y„yt equipment covered under this Alfts ID) and process simulation to estimate emissions? The sample should have been collected within one year of the application received date However if the faalny has not been modified (eg no new welb brought on line) then it maybe appropnate to use an older sltespecllic sample If no the permit will contam an Initial Compliance testing requirement to collect a 'Ile -specific liquid sample 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 Does the company request a control device efficiency greater than 9S% for a flare or combustion device? if yes the permn will contain initial and periodic compliance testing in acaardance wrth PS Memo 1002 Section 08 Technical Analysts Notes _ __ _ __ �1 The wells were producingpdor to August 2014 and have not been'iefraetured or reoampleted and so the separators covered by this poem are not subject to Rgulatron T Part D Section ll FF� }� 1' ` 4 %/ lr'iv n R..' I-. l.}r, s - r l.v nr rr< s a- pv _ i ➢ / r c > i zr ", i A h � a r/r`t/r 2 The extendedgasanalas&used 0 estatilah emtss(on factors In this application was obtainedfrom the outlet of the bukr house(Iljuids knockout for lower sure gas vented frordthe low presHire side of the HlP separators)at Mrsfaciht As a result it is repnsematwe of only low pressure gasthat is vented to and controlled by the enclosed combustors ` ,, r 3 NOa and CO emissom from this source are below ADEN reporting tZmholds As a result OmAs and emssion feelers are not included in the permit for !Mx nor CO ^ Sr V 3 v / r r ,. 4 During normal operations IOW -pressure gas tented from the low pressure side of theHIP separators 6 captured using vapor recovery un �RUs) and rooted to the saleslune During VRU downtime the low pressure gas is touted through tthe /Ja t biter house(hqufs's knockout)andthen to the enclosed combustors VRU downtime tracking is required in the permit to quantity the volume of gas vented from the separators and routed to the enclosed rombustar(s)u , s w( ^ i a S Initial and penodo visible emissions sheds forthe scribal deice arrethe*O&M addressed by th6M plan As a result, the permn does not contam retrain periodic epee.), testing _ Section 09 SCC Coding and Emissions Fa -tors Dar Inventory Use Only( AIRS Perota 006 i Process SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 01 310 001 29 Cd i G s Pr a non Ga In- Ild ,pare ion PM10 0 15 ] WILCO h.rtoi t r PM25 01 SOx 004 b/30o0� mrs nllaw a.,t-Is NOa I nd h/1000 Vaorls VOC 141087 b/1uMlnnels CO 19 9 b/i COO oarr Benzene L G b/3000 b-mels Toluene 035 h/ 0001ar I Ethylbenzene DO h/10.6u eels Kylene 070 b/10JOnnonl< n Hexane 1094 6/10.0 hoods 224TMP 000 9 b/1UC3b T I J j 3 of S K\PA\2020\20WE0590 CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Crestone Peak Resources Oneratine. LLC County AIRS ID 123 Plant AIRS ID 96FC Facility Name lone NW2H Battery History File Edit Date Ozone Status 11/18/2020 Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 2.3 690.2 0.0 10.4 35.1 0.0 0.0 0.0 0.0 2.3 49.8 0.0 10.4 1.8 Previous taken from April 2018 tab Previous Permitted Facilit total 0.0 0.0 0.0 0.0 2.3 690.2 0.0 10.4 35.1 0.0 0.0 0.0 0.0 2.3 49.8 0.0 10.4 1.8 Points 001-002 &O05 included in previous total. 001 GP01 Twenty-one (21) 400 bbl fixed roof condensate storage vessels 0.3 165.1 1.5 6.3 0.3 10.0 1.5 0.3 June 2020 updated SSEF; adjusted GP01 limit down to 10 tpy 003 GPD2CN SI R(MGC415dCFFk+w0,5,7L NA, 4SR6, 92HP.,,SNdq'}(MM211150070:.. �. _ - - _ - - - ` - 0 0 - - _ �.. ' - - - 0.0 Cancellation received 06/01[15. Source no longer exists at the facility. 004 GP02.CN SI RfCfl' GM7VZrtec 5:7L NA 4SRB, 92 HP, SNI 10CHMM211150064 _ -,.,. - 0.0 .. _ 0,0 Cancellation received 06/01/15 Source no longerexists at the facility ', - - - 005 13WE2871 Condensate Loadout 16.9 0.6 0.8 0.0 No change 006 20WE0590 Separator venting "Buffer" 0.0 0.0 0.0 0.1 36.0 0.5 0.5 0.0 0.0 0.0 0.1 1.8 0.5 0.0 June 2020, new point 007 GP01 Condensate tanks (800 bbl) 0.0 32.5 0.2 0.6 0.0 0.2 0.0 June 2020: new GP01; formerly 123-3704-001 APEN-Exempt / Inslonficants 002 XA Produced water tanks (1645 bbl) 0.7 0.1 0.7 _ 0.1 June 2020: Cancellation reed (below reporting threshold) Hi -Low Separators (9) 0.1 0.1 2.0 0.1 1.7 0.0 0.1 0.1 2.0 0.1 1.7 0.0 From June 2020 Form 102 Fugitive component leaks 0.9 0.1 0.9 0.1 From June 2020 Form 102 FACILITY TOTAL 0.1 0.1 0.0 0.0 2.5 251.3 0.9 3.9 8.1 0.1 0.1 0.0 0.0 2.4 13.4 0.9 3.9 0.6 VOC: Syn Minor (NANSR and OP) NOx: True Minor (NANSR and OP) CO: True Minor(PSD and OP) HAPS: True Minor HH: no requirements Permitted Facility Total 0.0 0.0 0.0 0.0 0.5 250.5 0.0 2.2 7.9 0.0 0.0 0.0 0.0 0.4 12.6 0.0 2.2 0.4 Excludes units exempt from permits/APENs (0) Change in Permitted Emissions 0.0 0.0 0.0 0.0 -1.8 -37.2 0.0 -8.2 Pubcom required due to new syn minor limit for NANSR for VOC Note 1 Total VOC Facility Emissions (point and fugitive) (D) Change in Total Permitted VOC emissions (point and fug tive) 14.4 Facility is eligible for-GP02 because < 90 tpy Project emissions less than 25 tpy -37.2 Note 2 Page 4 of 5 Printed 12/7/2020 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 9BFC Facility Name lone NW2H Battery Emissions - uncontrolled (Ibs aer vear POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP HP8 TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Twenty-one (21) 400 bbl fixed roof condensate storage vessels 1144 1672 'A 523 9173 79 6.3 003 GP02.CN SI RICE GM Vortec 5.7L NA, 4SRB, 92 HP, SN: 10CHMM211150070 0.0 004 GP02.CN SI RICE GM Vortec 5.7L NA, 4SRB, 92 HP, SN: 10CHMM211150084 0.0 005 13WE2871 Condensate Loadout 316.9 785.5 0.6 006 20WE0590 Separator venting "Buffer" '1'15 51 7 10 866 0 0.5 007 GP01 Condensate tanks (800 bbl) 1'14 996 0.6 0.0 APEN-Exempt / Insignficants 0.0 002 XA Produced water tanks (1645 bbl) 38 120 0.1 Hi -Low Separators (9) 3 71 0.0 Fugitive component leaks 7 31 3 38 54 0.1 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.9 0.9 0.0 0.3 6.0 0.0 0.0 0.0 0.0 8.1 ol Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text, uncontrolled missions < 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 (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Twenty-one (21) 400 bbl fixed roof condensate storage vessels 57 84 3 26 459 1 0.3 003 GP02,CN SI RICE GM Vortec 5.7L NA, 4SRB, 92 HP, SN: 10CHMM211150070 20./ 55.2 0.0 004 GP02.CN SI RICE GM Vortec 5.7L NA, 4SRB, 92 HP, SN 10CHMM211150084 0.0 005 13WE2871 Condensate Loadout 16 39 0.0 006 20WE0590 Separator venting "Buffer" 6 ., 0 1 43 0 0.0 007 GP01 Condensate tanks (800 bbl) 6 50 0.0 0.0 APEN-Exempt / Insignficants 0.0 002 XA Produced water tanks (1645 bbl) 38 1]20 0.1 Hi -Low Separators (9) 3 7'I 0.0 Fugitive component leaks 7 31 ., 38 54 0.1 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.6 5 20 W E0590. CP1 12/7/2020 Gas Venting APEN - Form 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/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C, for revised APEN requirements. Permit Number: AIRS ID Number: 123 9BFC / 006 Section 1 - Administrative Information Company Name': Site Name: Site Location: Mailing Address Crestone Peak Resources Operating, LLC lone NW2H Battery SWNW, Section 2, T2N, R66W (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 -Mail Address2: sabrina.pryor@crestonepr.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. ((3 (36 7 !COLORADO 1 x°�rmr Page 19 of 74 Permit Number: AIRS ID Number: 1 23 / 9BFc / Section 2 - Requested Action Q NEW permit OR newly -reported emission source -Oa- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name; ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info 13 Notes: 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: 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: 07/01 /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 days/week weeks/year 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? Fo; r -.l. _0 9 Page 20 of 74 Yes ❑ Yes ❑ Yes ❑ No ❑� No El No COLORADO Z I-awma..ar.ar ' N..FA b [n..gne4M Permit Number: AIRS ID Number: 123 / 9BFC / Section 4 - Process Equipment Information El 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? ❑ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 51 100 1 bbl/year Actual:• __ bbl/year Molecular Weight: 32.4874 VOC (weight %) 53.8602 Benzene (weight %) 0.0861 Toluene (weight %) 0.0379 Ethylbenzene (Weight %) 0.0008 Xylene (Weight %) 0.0075 n -Hexane (weight %) 0.6466 2,2,4-Trimethylpentane (Weight %) 0,0001 Additional Required Documentation: Q Attach a representative gas analysis (including BTEX £t n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & 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. Form -21 GJls hiptiiatik,coLopAoo 3 I air tie n.,.K.. ..a.o wle Heart 1.. slew Page 21 of 74 Permit Number: AIRS ID Number: 123 / 9BFC / Section 5 - Geographical/Stack Information Geographical Coordinates (LotitudelLongitude or UTM) 40.170130 / -104.750446 0 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 ❑ Downward ❑ Horizontal ❑ 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: NA Type: Enclosed Combustor MMBtu/hr Make/Model: NIA Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 % Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: 1,822 0.025 Btu/scf MMBtu / hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Fo a'COlOR•00 4 j Department outer a Intanannent Page 22 of 74 Permit Number: AIRS ID Number: 1 23 / 9BFC / 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 collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) PM SO, NO, CO VOC Enclosed Combustor i00% 95% HAPs Enclosed Combustor 100% 95% Other: From what year is the following reported actual annual emissions data? NA Use the following table to report the criteria pollutant emissions from source: ll Poutant 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 (tonslyear) Controlled Emissions (tons/year) PM SO, NO, CO VOC 0.068 0.31 1.41 tb/MMEItu IbiMMBtu Ibft,bl AP -42 AP -42 Site specific — — — — — — — — 36.05 0.10 0.47 1.80 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 ibs/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 -4<2, Mfg., etc.) Uncontrolled Emissions (lbs/year) Controlled Emissionsb (Ibs/year) Benzene 71432 2.26E-03 ILAN Site specific 115 5.8 Toluene 108883 9.93E-04 Ibibbl Site specific 51 2.54 Ethylbenzene 100414 2.10E-05 lb/bbl Site specific 1.07 0.05 Xylene '1330207 1.96E-04 IbibbI Site specific 10.04 0.50 n -Hexane 110543 0.02 Iblbbl Site specific 866 43.28 2,2,4-Trimethylpentane 540841 2.62E-06 Ibrbbl Site specific 0.13 6.69E-03 Other: 0 Yes ❑ No 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. .COLORADO o�,....Muwswr ' ewttA 62emton0ent Page 23 of 74 Permit Number: AIRS ID Number: 123 / 9BFC, Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. (.7 06/16/2020 Signature of Legally Authorized Person (not a vendor or consultant) Sabrina M. Pryor Date Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance Qr 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 ADEN is required 30 days prior to expiration of the five year term, or when a, "reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environmenvt 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 i iCOLORADO oq..n�.nuaruub ,. Ne+hnbAmronment Page 24 of 74 Hello