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Home My WebLink About20203838.tiffCto COLORADO 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 21 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 - Vogt Geist McCoy 5H -F267 (East). 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.cotorado.gov/cdphe Jared Potis, Governor I Jill Hunsaker Ryan, MPH, Executive Director Publ;G ReV;ew oI/o6/21 cc., n(rP) H1.051TR),Pt,3(shrERIakicb9 06(14) 12. /as /2O 2020-3838 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating, LLC - Vogl Geist McCoy 5H -F267 (East) - 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: Vogl Geist McCoy 5H -F267 (East) EEtP Well Production Facility SENW SEC 5 T2N R67W Weld County The proposed project or activity is as follows: Applicant proposes the permitting of condensate tanks under an individual construction permit, replacing the existing GP01 coverage for that point (001), and the permitting of a new point (013) under an individual construction permit. 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 20WE0485 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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 (COLORADO Department of Public health t3 Em Amamcm je. COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0485 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: Vogl Geist McCoy 5H -F267 (East) Plant AIRS ID: 123/9D9B Physical Location: SENW SEC 5 T2N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TANKS 001 Twenty-four (24) 500 barrel fixed roof storage vessels used to store condensate 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 the 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 - certify compliance as required by this permit may be obtained online at Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. 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 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section "II.A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO TANKS 001 --- --- 12.3 2.2 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air 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. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Enwronment Dedicated to protecting and improving the health and environment of the people of Colorado 8. 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TANKS 001 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. 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, II.A4.) Process Limits Facility Equipment ID AIRS Point Process Process Parameter Annual Limit TANKS 001 01 Condensate throughput 47,450 barrels 02 Combustion of pilot light gas 1.8 MMscf 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and Page 3 of 10 to COLORADO Air Pollution Control Division Department of Public Health b Enwonment Dedicated to protecting and improving the health and environment of the people of Colorado • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0aM) 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 OItM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point New Emission Point GP01 123/9D9B/001 123/9D9B/001 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C. • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or 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. Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado 22. The requirements of Colorado Regulation No. 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 (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 23. 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. 24. 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. 25. 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 only for the equipment and operations or activity specifically identified on the permit.` 26. 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. 27. 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. 28. 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 of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 29. 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: DRAFT Ben Fischbach Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC Point 001 was previously permitted under GP01 Page 7 of 10 > COLORADO Air Pollution Control Division Department of PubIto Health El Enwonment 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 source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 1,423 71 Toluene 108883 1,169 58 Ethylbenzene 100414 52 3 Xylenes 1330207 375 19 n -Hexane 110543 11,198 560 2,2,4- Trimethylpentane 540841 28 1 vote: All non cnterta reportable pollutants in the tablea ove with uncontrolled emiss'on rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Process 01: Natural gas vented from the condensate storage tanks and routed to the enclosed combustor(s): CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0178 0.0178 AP -42 Page 8 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 CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source CO 0.0810 0.0810 V0C 10.38 0.5190 Promax 71432 Benzene 3.00 * 10"Z 1.50 * 10"3 108883 Toluene 2.46* 10-2 1.23 * 10-3 100414 Ethylbenzene 1.10* 10-3 5.48 * 10-5 1330207 Xylene 7.90 * 10"3 3.95 * 10-4 110543 n -Hexane 2.36 * 10"t 1.18 *10-2 540841 2'2'4- Tnmethylpentane 5.86 * 10-4 2.93 * 10"5 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on a GOR of 95.43 scf/bbl predicted by a Promax model of the facility. The GOR was estimated using a site -specific pressurized liquid sample analysis modeled through the low-pressure side of the separator at a temperature of 80 °F and pressure of 25 psig, and then through the condensate storage tanks at ambient conditions. Combustion emissions are based on a higher heating value of 2,737.5 Btu/scf. Process 02: Combustion of pilot light gas: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source N0x 68 68 AP -42 CO 310 310 Note: The pilot light gas combustion emissions factors for this point are based on emission factors from AP -42 Chapter 13.5, and were calculated by assuming a pilot light heating value of 1,000 Btu/scf and a pilot light fuel rate of 200 scf/hr (total rate for eight pilot lights at 25 scf/hr each). Monthly pilot light gas throughput must be determined by multiplying the hourly pilot gas throughput by the enclosed combustor monthly hours of operation. There is one (1) enclosed combustor equipped with a single pilot light used to control emissions from the low-pressure side of the high/low-pressure separators. Total actual emissions are obtained from the sum of emissions resulting from the natural gas vented from the condensate storage tanks and routed to the enclosed combustor(s) (process 01) and the combustion of pilot light gas (process 02). 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 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 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://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 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 ,i mow/ tyliiil-� COLORADO Air Pollution Control Division Department of Publtc Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 20WE0486 Issuance: 1 Crestone Peak Resources Operating, LLC Facility Name: Plant AIRS ID: Physical Location: County: Description: Vogl Geist McCoy 5H -F267 (East) 123/9D9B SENW Section 5 T2N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Buffer 013 Flaring of natural gas vented from the low pressure side of seven (7) high/low pressure (HLP) separators and routed through the buffer house during vapor recovery unit (VRU) downtime. Enclosed Combustor(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - Page 1 of 10 COLORADO Air Pollution Control Division Department of Public 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 complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. 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 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Buffer 013 --- --- 7.2 1.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air 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. Page 2 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 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. 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.) Equipment ID AIRS Point Control Device Pollutants Controlled Buffer 013 Emissions from the seven (7) high/low pressure (HLP) separators are routed through the buffer house to enclosed combustor(s) during vapor recovery unit " (VRU) downtime. VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. 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, II.A.4. ) Process Limits Equipment ID AIRS Point Process Process Parameter Annual Limit Buffer 013 01 Natural gas vented from the low pressure side of the HLP separators and routed through the buffer house to the enclosed combustor(s) 4.07 MMSCF 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. 10. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the low pressure side of the HLP separators and routed through the buffer house to the enclosed combustor(s) using an operational continuous flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and 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 schedule. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 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) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d ` 14. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operationby air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 15. 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 16. Upon startup of these points, 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 0£tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health b £nironment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or 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. Page 5 of 10 COLORADO Air Pollution Control Division Department of Publio Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. Page 6 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 26. 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. 27. 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: DRAFT Ben Fischbach 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 013 Benzene 71432 1,708 85 Toluene 108883 1,453 73 Ethylbenzene 100414 45 2 Xylenes 1330207 246 12 n -Hexane 110543 14,204 710 2,2,4- Trimethylpentane 540841 8 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable 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: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 148.90 148.90 AP -42 CO 678.81 678.81 VOC 70,609.74 3,530.49 Gas Analysis 71432 Benzene 419.58 20.98 108883 Toluene 357.06 17.85 100414 Ethylbenzene 11.08 0.55 1330207 Xylene 60.49 3.02 110543 " ;n -Hexane 3,489.94 174.50 540841 2'2'4 Trimethylpentane 1.93 0.10 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 from the outlet of the buffer house (liquids knockout for low pressure gas vented from the low pressure side of the HLP separators) on 01/28/2020. The weight% values and molecular weight from the sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10) were used to determine the emission factors.: The CO and NOx emission factors listed in the table above were obtained by multiplying the AP -42 Chapter 13.5 CO and NOx emission factors by a higher heating value of 2189.7 Btu/scf. Actual emissions are calculated by multiplying the emission' factors in the table above by the total metered low pressure gas vented from the low pressure side of the HLP separators and routed through the buffer house to the enclosed combustor(s). 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, n -Hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Page 9 of 10 COLORADO Aix Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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,Rov/ 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 MALT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT = 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 I 't5 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Ben Fischbach 429472 4/24/2020 10/16/2020'a-` Section 01- Facility Information Company Name: Crestone Peak Resources Operating, LLC County AIRS ID: 123 Plant AIRS ID: 9098 Facility Name: Vogl Geist McCoy 5H-F267(East) Physical Address/Location: County: Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Ozone (NOx & VOC) Weld County Section 02 - Emissions Units In Permit Application Yes Quadrant Section Township Range SENW 5 2N 67''+ Leave Blank- For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) Emissions Source Type Equipment Name Emissions Control? Permit # (Leave blank unless APCD has already assigned) Issuance # Self Cert Required? Action Engineering Remarks 001 Storage Tank TANKS Yes 20WE0485 1 Yes Permit Initial Issuance ReplacesGP01 013 Separator Venting - Buffer Yes 20WE0486 1 Yes Permit Initial Issuance New Section 03 - Description of Project Applicant proposes the permitting of condensate tanks under an individual construction permit, replacing the existing GPOS coverage for that point (001), and the permitting of a new paint (013) under an individual construction permit: Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes " If yes, why? Requesting Synthetic Minor Permit Buffer has uncontrolled emissions of 143.5 tpy and is therefore requesting a synthetic minor permit. Section OS -Ambient Air Impact Analysis Requireme m 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) V Operating Permits (OP) 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) V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx _ ,,,,, NOx .,.., No Yes CO _ No CO r--- VOCE VOC --1p ,.....4T PM2.5 PM10 J J J PM2.5 PM10 T5P HAPs --Title TSP HAPs U El Storage Tank(s) Emissions Inventory Section 01 -Administrative Information Facility AIRS ID: 123 County 9D9B Plant 001 Point Section 02 - Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Twenty-four (24) 500-bbi Condensate storage tanks. Description: Emission Control Device ECD Description Requested Overall VOC & HAP Control Efficiency %: 95.0 Limited Process Parameter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Storage Tank(s) Actual Throughput = - Requested Permit Limit Throughput= 39,386.0 Barrels (bbl) per year 47,450.0 Barrels (bbl) per year Requested Monthly Throughput= 40.30.0 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 47,450.0 Barrels (bbl) per year 2737.5 Btu/scf 95.4 scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device .0.289.0 MMBTU per year 12.3+5.3 MMBTU per year f -2.305.6 MMBTU per year Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: 200 scfh 1000 Btu/scf 1.3 MMscf/yr ?52.0 MMBTU/yr Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bbl) (Condensate Throughput) (Condensate Throughput) VOC 10.38 Site Specific E.F.(includes flash) Site SpecificEF (includes. flash) Site Specific E.F.(Includes flash) Site Specific E.F.(includes flash) She Specific E.F.(includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 3.00E-02 Toluene 2.46E-02 Ethylbenzene 1.10E-03 d d'E Xylene 7.90E-03 7.95E-04 n -Hexane 2.36E-01 1.18E-07 224 TMP , 3.86E-04 2 3273,05 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat ombusted) (Condensate Throughpu₹) PM10. 00000 AP -42 Chapter 135 Industrial Flares (N10,21 AP -42 Chapter 13.51ndustrfat Flares (C0)-_,,.'... PM2.5 7000E SOx C.0000 NOx 0.0680 32173 CO 0.3100 0.0'10 Pollutant Pilot Light Emissions Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) (Pilot Gas Heat Combusted) (Pilot Gas Throughput) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial. Flares (CO) PM2.5 0,1,73 5Ox 0.000='3 NM 0.0680 58,0000 VOC 0.0000 CO 0.3100 310,00^_® 200 scfh is based on a individual pilot lights fed at a constant fuel rate of 25 scfh Promax Results VOC Vapors (Flash, WB) . 56.2480487216/h Flow sgpm 3.79167 gpm Flow bbl/h 5.416671429 bbl/h 2 of II K:\PA\2020\20WE0485.CP1 Storage Tank(s) Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tans/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tans/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOK NCB( VOC CO 0.0 0.0 0,0 0.-ri 0. 3 6 0.0 0-0 _-J 0.-0 J 0 0.0 0.0 0.0 0.0 .,... 2.0 0.0 Overall Combustion Emission Factors 0.020274739 lb/bbl 0.0924289581b/bbl '.; 64 0.4 .-._ ... 31 7 74673 204.3 0.2 .._;-'. - 26015 ., 1.9 7.-_ ..... 377.5 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/Year) DP_... ';8.3.322:3ACTDAt5 Or. oR_t,lOUS_ 4PPROT",,; 2,3CTORS Benzene Toluene Ethylbenzene Xylene n-Henane 224 TMP _-_-.9 1181.2 -_._ 1423 .. _-.._ 970.5 43.5 11-S9 -.-._ 43.2 22 52 _ _ 311.2 15.6 3r_ 19 11193.2 9-295,1 €54.8 11193 560 _,-a 21.1 12 23 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A; B Porte - - r_s a permit Regulation 7, Part D,Section I.C, D, E, F S.v- *Yis subject to Replatfon 7. Part D. Section C -F Regulation 7, Part D,Section I.G, C Storage Tank not sublectto Regulation T, Section!'' Regulation 7, Part D,Section 'LB, C.1, C.3 Storage tang is subject to Flop,- ion 7, ?art 0, Section IL P C.1 w C.3 Regulation 7, Part D,Section ll.C.2 Storage tank is spiked to Regulation 7, Part 0, Section ii...._ Regulation 7, Part D,Section II.C.4.a.(i)Storagea r not subject To Re cation 7. Part D Sect C...4 C 4.all) Regulation 7, Part D,Section lLC.4.a.(ii) Prase Tani: Inot subject to Regulation 7 Part D, Section ll.C 4 slot_ 0.f Regulation 6, Part A, NSPS Subpart Kb Storage Tank is net subject taleSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage. Tank is not subject tc NSPS OOOO NSPS Subpart 0000a Storage tank is not suk;ect to klOP5 OOOOs. Regulation B, Part E, MACi Subpart HH atotaaa Tank i5 not suelecs To MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 -Initial and Periodic Sampling and Testing Requirements For condensate or crude oll tanks, does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? If yes, the permit will contain an "Initial Compliance.' testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, lithe facility has not been modified (e.g., no new wells brought on-line), then It may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 3 of 8 K:\PA\2020\29WE0485.CP1 t7l Csypu':15 Section 08 -Technical Analysis Notes Original mode{ used a. pressurized liquid sample and a,gas sample both taken from the HP side of the HPLP separators at this facility and recombined at a higher pressure to simulate the inlet to the HP side of the separators as an inlet; for the entire facility process Atmy request, the operator update the model to directly input the pressurized liquid sample to the LP side of the HPLP separator modeled in Promaz. Updated model from operatorefsoinmBporated a change to the W&Remissions stencil which the liquids type Was changed from crude to light organics, and an update in meteorological data, both of which are acceptable. Section 09 - SCC Coding and Emissions FactorefFor Inventory Use Only). AIRS Point it it"1 Process ft 01 SCC Code Isj Uncontrolled Emissions Pollutant Factor Control% Units PM10 00 0 lb/1,000 gallons Condensate throughput • PM2.5 _..,., 0 lb/1,000 gallons Condensate throughput SOx EF! 0 lb/1,000 gallons Condensate throughput NOx 0.48 0 lb/1,000 gallons Condensate throughput VOC 24'711, 99 - lb/1,000 gallons_Condensate throughput CO 2"20 a lb/1,000 gallons Condensate throughput Benzene O.T 9S 1b/1,000 gallons Condensate throughput Toluene O:S9 9S lb/1,000 gallons Condensate throughput Ethylbenzene 0.09 95 lb/1,000 gallons Condensate throughput Xylene 0.19 95 lb/1,000 gallons Condensate throughput n -Hexane 5:52 95 lb/1,000 gallons Condensate throughput 224 TMP 0,01 95 lb/1,000 gallons Condensate throughput 4 of 8 KAPA\2020\20W E0485.CP1 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Goloracrion 3 Parts A and B- APEN andPermit Requirements ATTAINMENT 1. Are uncontrolledactual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3, Part A, Section ll.D.1.a)? Source Requires an APEN. Go to 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 32/31/2002 (see PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility ancontrolled VOC emissions greater than 5TPy, NOx greater than 10TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? -mu hamInd:noted fhat snorcc.s in _,-Non—nitro m Ama NON-ATTAINMEW 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Par. A, Section ll.D.1.a)? 2. Is the construction date (service date)prior to 12/30/2002 and not modified after 12/31/2032 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Aretotal facility ancontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.2)? Colorado Regulation], Part D. Section I.C-F & G 1. Isthis storage teak located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenancearea (Regulation 7, Part D, Section I.A.1)? 2. Is this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced waterAND that are located at or upstream of a natural gas processing plant (Regulation 7, Part D, Section I.A.1)? 3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section I.G)? 4. Does this storageMnk contain condensate? 5. Does this storage ank exhibit "Flash.. (e.g. staring non -stabilized liquids) emissions (Regulation 7, part D, Section l.G.2)? 6. Are uncontrolled actual emissions of this storagetank eq ual to or greater than 2 tons per year VOC (Re Marton 7, Part D, Section l.D.3.a(Fijl? ion .c< Part D, Section 12.1 - General Requirements for Air Pollution Control Equipment -Prevention of Leakage Part D, Section IL.2 - Emission Estimation Procedures Part 0, Section 131- Emissions Control Requirements Part D, Section IE- Monitoring Part 0, Section IF-Recordkeeping and Reporting Part D, Section IG.2- Emissions Control Requirements Part O, Section IC.1.a and b -General Requirements for Air Pollution Control Equipment -Prevention of Leakage Colorado Regulation. Part D. Section II 1. Is this storage tanklocated at a transmission/storage facility? 2. Is this storagetenkr located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant (Regulation 7, Part D, Section Ii.C)? 3. Does thisstorage tank have a fixed roof (Regulation 7, Part 0, Section ll.A.2017 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section lLGLc? I. 13. C.1 & Cog Yes No Yes Yes Yes Go to next question Source Requires a permit Source Requires an APEN. Go to Go to next question Source Requires a permit Continue -You have indicated th Continue - You have indicated th Storage Tank is not subject to Re Cominue - You have indicated th Coto the nut question- You ha Go to the next question Source is subject to parts of Reg Part 0, Section 'LB —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part O,Section ILC.1- Emissions Control and Monitoring Provisions Part 0, Section ILC.3 - Recordkeeping Requirements 5 Does the ti rag k contain only "stabilized.. liquids (Regulation 7, Part D, Section II C.2.b)? rINo . 'Source ssubject to all provision: ISto -mote .11:Intto Re.t lot: : r. ., II - G2 I Part D, Section ILC-2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment Is the controlledstorage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located M a facility that was modified on or after May 1, 2020, such 6. that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D,Section ll.G4.a.(i)7 N - Storage Tank's not subject to 0.a is the controlledstorage tank located at a well production facility, natural gas compressor station, or natural gas prucess:ng plant constructed on or after lanuan/ 1, 2021 or located. a facility that was modified on or after -January 1, 7. 2021, such that an additional controlled stoagevessel is constructed to receive an anticipated increase in throughput ofhydromrbonliquids or produced water (Regulation 7, Part D, Section ll.C.4.a.(ii)7 - I5e - .l re Regale -ion a_ oar, qaqtrian g.a.arol -_ 40 CFR, Parte%Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual rtorage vessel capacity greater than or equal to 75 cubic meters (m) ["472 RBIs] (40 CFR 60.110b(a))? 2. Does thestorage vessel meet the following exemption in 6o.111h(d)(4)? • a. Doesthe vessel has a design capacity less than or equal to 1.,589.874 ms (`10,000 BBL] used for petroleum' o. condensate stored, processed, or treated prior to custody transfer' as defined In 60.1116? 3. Was this storagevessel constructed,reconstructed, or modified (see definitions 40CFR, 60.2) after July 23, 1984 (40 CFR60.l1ob(a)17 4. Does the tank meet the definition of "storagevessel' in 6o.111b? 5. Does the storage vessel store a"volatile organic liquid(VOL)"sas defined in 50.111b7 6. Does the storage vessel meet any one of thefollowingadditional exemptions: Ye Go to the next question Storage Tank is not subject NSPS a. Iethestorage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi] and without emksions to the atmosphere (6o.110b(d)(2))7; or b. The design capacity is greater than or equal to 151 ms (-950 BBL) and stores a liquid with a maximum true vapor pressure' lessthan 3.5 kPa (60.1106(b))?; or c. The design capacity is greater than or equal to 75 Ms (-472 BBL) but lessthan 151 m' ('950 BBL] and stores a liquid with a maximum true vapor pressure' lessthan 15.0 kPa160.110b1b))? Does the storage tank meet either one of the following exemptions from control requirements: a. The design capacity is greater than or equal to 151 m' ("950 BBL] and stares a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. The design capacity is greater than or emelt° 75 M' (-472 BBL] but less than 151 m' ('950 BBL) and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but lus than 27.6 kPa? 40 CFR, Part 60, Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment natural gas transmission and storage segment of the industry? 2. Was this storagevessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2)between August 23, 2013 and September 18, 2015? 3. Wasthis storagevessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015' 4. Are potential vac em s'from the individual storage vessel greater than or equal to 6 tons per year? 5. Does this storage vessel meet the definition of "storage vessel"' per 60.5430/60.5430a? 6 Is the storage vessel subject to and controlled in accordance with re ulrements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HH7 e.orage anii is „o, sublert to ldSpS ocoo [Note: If a storage vessel is previously determined to be subject te NSPS 0000/0000a due to emissions above 6 ton=- per year VOC on the applicability determination date, it should remain subject to NSPS 0000/O0OOa per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year] Yef:::rf00, f(gWA'y.... Continue -You have Indicated th Go tothe question 4. Storage Tank is not subject NSPS Storage Tank is not subject NSPS '6,4•18WARM 40 CFR, Part 63, Subpart MALT MOP and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or Is delivered to a flnal end user' (63.760(a)(3))7 2. Isthe tank located at a facility that Is major'for HAes? 3. Does the tank meet the definition of"storage vessel' in 63.%617' 4. Doesthetank meet the definition. of"storage vessel wrth the potential for flash emissions"' per 63.7617 5. Isthetanksubiect to control re ueeme. under 40CFR Part 60, Subpart Kb or Subpart 00007 IYs ICoMinue- You have indicated th Subpart A, General provisions per 463.764 (a) Table 2 463.766- Emissions Control Standards 463.773 -Monitoring 463.774- Recordkeeping 463.775 - Reporting RACT Review RACT review Is required If Regulation 7 does not apply AND If the tank 'sin the non -attainment area. If the tank meets both criteria, then review PACT requirements: Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations, end Air Qualify Control Comntission regulations. This document is not ale 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 orsubstifute for any law regulation, r any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations. and Air Quality Conbal Commission regulations, the language of the statute or regulation will control. The use of non-mendefory language such as "recommend,""may,"`should," and 'can,'is intended to describe APCD interpretations and recommendations. Mandatory fennlnology such as "must" and `required" are intended le 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. MM. Storage Tank Is not subject MAC COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Crestone Peak Resources Operating. LLC 123 9D9B Vogl Geist McCoy 5H -F267 Battery History File Edit Date Ozone Status 11/25/2020 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 7.8 219.4 0.0 11.1 12.6 0.0 0.0 0.0 1.4 53.1 0.0 4.6 0.7 Previous Permitted Facilit total 0.0 0.0 0.0 0.0 0.5 219.0 0.0 2.8 12.6 0.0 0.0 0.0 0.0 0.5 52.7 0.0 2.8 0.6 001 GP01 Condensate Tanks (24) 0.5 246.3 2.2 7.1 0,5 12.3 2.2 0.4 Conversion from GP to individual permit 002 GP05 Produced Water Tank 1.9 0.2 10.0 0.0 APEN Update 003 15WE0343 Condensate Loadout 74.8 4.2 3.7 0.2 No Change 004 GP02.CN GM 5.7L 92HP VRU engine 0.0 - 0.0 Cancellation received 8/10/2015. Source no - longer exists. 005 GP02.CN GM 5.7L 92HP VRU engine 0.0 0.0 Cancellation received 12/24/2015. Source no longer exists. 006 GP02.CN GM 5.7L 92HP VRU engine 0.0 0.0 Cancellation received 12/24/2015. Source no longer exists. 007 GP02.CN GM 5.71. 92HP VRU engine 0.0 "r 0,0 Cancellation received 7/24/2017. Source no longer exists. 008 GP02.CN GM 5.7L 92HP. VRU engine 0.0 0.0 Cancellation received 8/10/2015. Source no longer exists. 009 GP02.CN GM 5.7L 92HP VRU engine " 0.0 0.0 Cancellation received 8/10/2015. Source no longer exists. 010 17WE0785.CN Compressco GJ230, sn: FP -62213 0.0 0.0 Cancellation received 6/12/2019. Source no longer exists. 011 1.7WE1107.CN ZPP 428 VRU. Engine, SN: 414041 0.0 0.0 Cancellation received 2/12/2019. Source no longer exists. 012 19WE0701.XP Compressco GJ230, 46hp 4SRB, sn: TBD 7.3 0.40 8.3 0.1 0.9 0.4 1.8 0.1 XP Pilot Program - Emissions based on APEN in RMB. 013 20WE0485 Buffer (Separator Venting) 0.3 143.7 1.4 8.8 0.3 7.2 1.4 0.4 Newly permitted emissions source FACILITY TOTAL " 0.0 0.0 0.0 0.0 8.1 467.1 0.0 11.9 20.4 . 0.0 0.0 0.0 1.7 33.6 0.0 5.4 1.1 VOC: Syn Minor (PSD, NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -Hexane HH: Syn Minor, no Dehys ZZZZ: Syn Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0.8 466.7 0.0 3.6 20.4 0.0 0.0 0.0 0.0 0.8 33.2 0.0 3.6 1.0 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions _ 0.0 0.0 0.0 0.0 0.3 -19.5 0.0 0.8 Pubcom & modeting (not) required based on (A change in emissions) Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fug tive) 33.6 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy -19.5 Note 2 Page,7 of 8 Printed 12/15/2020 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 9D9B Facility Name Vogl Geist McCoy 5H -F267 Battery Emissions - uncontrolled (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224TMP H2S TOTAL(tpy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate Tanks (24) 1423 1169 52 375 11198 28 7.1 002 GP05 Produced Water Tank 84 266 0.2 003 15WE0343 Condensate Loadout 1407 2484 1092 3486 4.2 004 GP02,CN GM 5.7L 92HP VRU engine 0.0 005 GP02.CN GM 5.7L 92HP VRU engine 0.0 006 GP02.CN GM 5.7L 92HP VRU engine 0.0 007 GP02.CN GM 5.7L 92HP VRU engine 0.0 008 GP02.CN GM 5.7L 92HP VRU engine 0.0 009 GP02.CN GM 5.7L 92HP VRU engine 0.0 010 17WE0785.CN Compressco GJ230, sn: FP -62213 0.0 011 17WE1107.CN ZPP 428 VRU Engine, SN: 414041 0.0 012 19WE0701.XP Compressco GJ230, 46hp 4SRB, sn: TBD 89 12 i e 1 t; 0.1 013 20WE0485 Buffer (Separator Venting) 1708 1453 45 146 14204 8.8 TOTAL (tpy) 0.0 0.0 0.0 2.3 2.6 0.0 0.9 14.6 0.0 0.0 0.0 0.0 20.4 `Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde ACr01Bln Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate Tanks (24) 71 58 19 560 1 0.4 002 GP05 Produced Water Tank 4 13 0.0 003 15WE0343 Condensate Loadout 70 124 55 174 0.2 004 GP02.CN GM 5.7L 92HP VRU engine 0.0 005 GP02.CN GM 5.7L 92HP VRU engine 0.0 006 GP02.CN GM 5.7L 92HP VRU engine 0.0 007 GP02.CN GM 5.7L 92HP VRU engine 0.0 008 GP02.CN GM 5.7L 92HP VRU engine 0.0 009 GP02.CN GM 5.7L 92HP VRU engine 0.0 010 17WE0785.CN Compressco GJ230, sn: FP -62213 0.0 011 17WE1107.CN ZPP 428 VRU Engine, SNr 414041 0.0 012 19WE0701.XP Compressco GJ230, 46hp 4SRB, sn: TBD 89 12 1'I i 13 0.1 013 20WE0485 Buffer (Separator Venting) 85 73 i2 710 0 0.4 TOTAL (toy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.7 0.0 0.0 0.0 0.0 1.1 8 20WE0485.CP1 12/15/2020 Colorado Air Permitting Pro ec PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Ben Fischbach 429472 4/24/2020 19/16/2020 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 segment2'f2U & Natural Gas Production & Processing - Is this facility located in a NAAQS non -attainment area? Ye: If yes, for what pollutant? Ozone (NOx Crestone Peak Resources Operating, LLC 123 9D98 Vogl Geist McCoy SH F267 (East) Weld County Section 02 - Emissions Units In Permit Application Emissions Control? Quadrant Section Township Range AIRS Point # (Leave blank unless APCD has already assigned) 0 013 Emissions Source Type SeparatorVenting Equipment Name TANKS Buffer Yes Ye Permit # (Leave blank unless APCD has already assigned) 20 W E0485 20 W E0486 SENW I' 2N° 67 Leave Blank- For Division Use Only Issuance # Self Cert Required? Action Engineering Remarks 1 Yes Permit Initial - Issuance ReplacesGP01'. 1 - Yes .. Permit Initial _Issuance New '. Section 03 - Description of Project Applicant proposes the permitting of condensate tanks under an individual co permitting of a new point (013) under an individual construction perm replacing the existing GP01 coverage for hat point (001), and the Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes. If yes, why? Requesting Synthetic : Minor Penmrt? Section 05 -Ambient Air Impact Analysis Requirement Buffer has uncontrolled. emissions of 143-.5 tpy and is therefore requesting a synthetic minor permit. 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 sourcea synthetic minor? If yes, indicate programs and which pollutants: SO2 NOx Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source amajor source? If yes, indicate programs and which pollutants: SO2 NOx Prevention of Significant Deterioration (PSD). Title V Operating Permits (OP) J Non -Attainment New Source Review (NANSR) No Yes CO _ — — No"t _ CO r=te VOC J '? _ VOC PM2.5 PM2.5 PM10 TSP HAPs _ PM10 TSP HAPs Separator Venting Emissi.ons invento-y Section 01- Administrative Information 'Facility AIRS ID: County 9D9B Plant 013 Point Section 02 - Equipment Description Details the emissions from the low pressure side of seven (7) Nigh -low pressure (HLP) separators are routed to ECD during VRU downtime, Detailed Emissions Unit Description: ,ECD clueing VRU downtime Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput= 0,0 MMscf per year 95 Requested Permit Limit Throughput= ✓. 4.07 MMscf per year Requested Monthly Throughput = MMscf per month Potential to Emit (PTE) Throughput = MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control 21.89,7 Btu/scf Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: scfh Btu/scf MMscf/yr Section 04 - Emissions Factors & Methodologies Facility uses common bank of ECDs - pilot fuel accounted for on Point 001. Description EmiSStOLT factors are cgfcufated using the Displacement Equation below, and are based on a Sfte-specific gas sample collected from the Buffer house at the Vogl -Geist McCoy 5H -F267 Easf facility on 1/28/2020 and analyzed on - 1/29/2020. Sample was, collected at a pressure of 21-2 psig and a temperature of 76F. - MW 38.5 Weight Oxygen/Argon CO2 N2 methane ethane 14.6 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 5.2 14.9 7.4 0.5 3.4 0.9 2.3 0.9 0.0 0.4 0.4 0.0 0,1 1.3 Total VOC Wt b/Ib-mol Displacement Equation Ex=Q'MW'Xx/C 2 of 7 K:\PA\2020\20WE0486.CP1 g Emissions inventory Section 05 - Emissions Inventory Primary Control Device Factors Pollutant Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant Pilot Light Emissions PM10 CO Pollutant PM10 PM2.5 CO Separator Ven ing Uncontrolled Controlled (Ib/MMscf) (Gas Throughput) (Ib/MMscf) (Gas Throughput) Uncontrolled Uncontrolled ( (Waste Heat Combusted) b/MMBtu) Emission Factor Source Ib/MMscf Emission Factor Source (Gas Throughput) Uncontrolled Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) 0`:3Y0) Ib/MMscf Emission Factor Source (Pilot Gas Throughput) Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx VOC CO 0.0 _... „.0 0,0 ., 0 j _ 0,0 0.0 _.c. G.0 .,._ 0.0 _ 0,3 0.0 0.30 „3 _ 143.7 0.0 0,0 1=3.65 7.18 1220 1.4 0.0 0.0 _._., 1.23 205 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM 1708 ., 0 1708 85 -1453 0 y _453 73 45 0 r 45 2=5 0 r. 245 _< 14204 _ ;, 14204 Section 06 - Regulatory Summon/ Analysis Regulation 3, Parts A, B Regulation 7, Part D, Section ILB, F Regulation 7, Part D, Section II.B.2.e (See regulatory applicability worksheet for detailed analysis) s'ou=`se requires A' -.P,,, is permit Source subiect-.vReguiatIon7, Parr 3.c,::a._._ 148:8996 Ib/MMscf 678.807 Ib/MMscf 3 of 7 KAPA\2020\20WE0486.CP1 Separator Venting Emissions inventory SeMion 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Arefacility-wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment area OR are emissions greaterthan or equal to 90 tons per year in the ozone attainment area? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed -and operational upon startup of this point? If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point # 013 Process # SCC Code O1 3.10 0"t •s0 P:aren Pollutant Uncontrolled Emissions Factor Control % PM10 0 PM2.5 SOx NOx LIB ,9 V0C CO 679 3 Benzene ._,.. Toluene Ethylbenzene Xylene 605 n -Hexane 34S0.> 224 TMP 0 S 35 Units '.b./ v:M0..7r lOOMNISCO .ry • ,.CaiS�� .mrosCr. 4 of 7 K:\PA\2020\20WE0486.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 Reauireme�ts e is in tea ,..,, ettemrrer-t Area. ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.S.a)? 2. Are total facility uncontrolled VOC emissions greater than.S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.3)? I;ot,. i'mp he -Cover, that source_ ih the ttontittipp,,pert,_4. a NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than (TPY(Regulation 3, Part A, Section ll.D.l.a)? 2. Are total faciltyuncontrolled 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 11.0.2)? 'Soma, ',tetras APPIP, is petra,t Colorado Regulation 7, Part O, Section II 1 Was the well newly constructed, hydraulically ft d pleted on or after August 1, 2014? lee .. lati_e 7. - , c S. . Section 11.6.2. —General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Enninsions Control (Optional Section) a. 'stills separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? IT1pontp.1 davitePP, „tpprwt ula.-un? P _tlon Y.3.2._ Section 11.8.2.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 orregetlation, 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 orregulation will control. The use of non -mandatory language such as "recommend,"may,""should,`and tan," is intended to describe APCD interpretations and recommendations. Mandatory, terminology such as "must" and "required"are intended to describe controlling requirements unckr the terms of the Clean Air Aetend Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Re Source is I source Is. The mntn COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Crestone Peak Resources Operating, LLC 123 9D9B Vogl Geist McCoy 5H -F267 Battery History File Edit Date 11/25/2020 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (ton 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 7.8 219.4 0.0 11.1 12.6 0.0 0.0 0.0 1.4 53.1 0.0 4.6 0.7 Previous Permitted Facili total 0.0 0.0 0.0 0.0 0.5 219.0 0.0 _ 2.8 12.6 0.0 0.0 0.0 0.0 0.5 52.7 0.0 2.8 0.6 001 GP01 Condensate Tanks (24) 0.5 . 246.3 2.2 7.1 0.5 12.3 2.2 0.4 OonversPon from GF to individual permit 002 GPO5 Produced Water Tank 1.9 0.2 10.0 0.0 APEN Update 003 15WE0343 Condensate Loadout 74.8 4.2 3.7 0.2 No Change 004 GP02.CN GM 5.7L 92HP VRU engine 0.0 , _ - - 0.0 Cancellation received 8/10/2015,.. Souree,nO longer exists. 005 GP02.CN GM,5. VRU engine 0 0 - 0.0 Cancellation received 12/24/2015. Source no . longer exists '' '" 006 GP02,CN GM 5 7L'92HP VRU engine _ �. 0.0 0.0 Cancellation received 12/24/2015. Source no longer exists , 007 GP02,CN GM 5.7L 92HP VRU engine 0.0 ' 0.0 Cancellation received 7/24/2017, Source no longer exists, 008 GP02.CN GM 5.71. 2HP VRU engine 0.0 0 Cancellation ancellatian received 8/10/2095 Source no, longer exists. i 009 GP02,CN GM 5.7L 92HP VRU engine 0.0 0.0 Cancellation received 8/10/2015. Source no longer exists. 010 17WE0785.CN Compressco GJ230;isn: PP -62213 - 0.0 0.0 Cancellation received 6/12/2019 Source no longer exists. ' ' 011 17WE1107 CN ZPP 428 VRU Engine, SN. 414041 0.0 - 0.0 Cancellation received 2/12/2019 Source no longer exists. ' ;" .. 012 19WE0701-XP Compressco GJ230, 46hp 4SRB, sn: TBD 7 3 0.40 8.3 0.1 0 9 0.4 1.8 0.1 XP Pilot Program - Emissions based on APEN in RMB. 013 20WE0485 Buffer (Separator Venting) 0.3 143.7 1.4 8.8 0.3 7.2 1.4 0.4 Newly permittecl entiss-ions source FACILITY TOTAL 0.0 0.0 0.0 0.0 8.1 467.1 0.0 11.9 20.4 0.0 0.0 0.0 1.7 33.6 0.0 5.4 1.1 VOC: Syn Minor (PSD, NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -Hexane HH: Syn Minor, no Dehys 7777: Syn Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0.8 466.7 0.0 3.6 20.4 0.0 0.0 0.0 0.0 0.8 33.2 0.0 3.6 1.0 Excludes units exempt from permits/AIPENs (A) Change in Permitted Emissions 0.0 0.0 0.0 - 0.0 0.3 -19.5 0.0 0.8 Pubcom & modeling (not) required based on (A change in emissions) Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Pe miffed VOC emissions (point and fug five) 33.6 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy -19.5 Note 2 Page 6 of 7 Printed 12/15/2020 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 9D9B Facility Name Vogl Geist McCoy 5H -F267 Battery Emissions - un POINT PERMIT Description Formaldehyde Acetaldehyde Acroleln Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate Tanks (24) 1423 1169 52 375 11198 28 7.1 002 GP05 Produced Water Tank 84 266 0.2 003 15WE0343 Condensate Loadout 1407 2484 1092 3486 4.2 004 GP02.CN GM 5.7L 92HP VRU engine 0.0 005 GP02.CN GM 5.7L 92HP VRU engine 0.0 006 GP02.CN GM 5,7L 92HP VRU engine 0.0 007 GP02.CN GM 5.7L 92HP VRU engine 0.0 008 GP02.CN GM 5.7L 92HP VRU engine 0.0 009 GP02.CN GM 5.7L 92HP VRU engine 0.0 010 17WE0785.CN Compressco GJ230, sn: FP -62213 0.0 011 17WE1107.CN ZPP 428 VRU Engine, SN: 414041 0.0 012 19WE0701.XP Compressco GJ230, 46hp 4SRB, sn: TBD 89 12 11 7 2 1 13 0.1 013 20WE0485 Buffer (Separator Venting) 1708 1453 45 246 14204 8 8.8 TOTAL (tpy) 0.0 0.0 0.0 2.3 2.6 0.0 0.9 14.6 0.0 0.0 0.0 0.0 20.4 = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with control POINT PERMIT Description Formaldehyde Acetaldehyde Acroleln 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 Tanks (24) 71 58 3 19 560 1 0.4 002 GP05 Produced Water Tank 4 13 0.0 003 15WE0343 Condensate Loadout 70 124 55 174 0.2 004 GP02.CN GM 5.7L 92HP VRU engine 0.0 005 GP02.CN GM 5.7L 92HP VRU engine 0.0' 006 GP02,CN GM 5.7L 92HP VRU engine 0.0 007 GP02.CN GM 5.7L 92HP VRU engine 0.0 008 GP02.CN GM 5:7L 92HP VRU engine 0.0 009 GP02.CN GM 5.7L 92HP VRU engine 0.0 010 17WE0785.CN Compressco GJ230, sn: FP -62213 0.0 011 17WE1107.CN ZPP 428 VRU Engine, SN: 414041 0.0 012 19WE0701.XP Compressco GJ230, 46hp 4SRB, sn: TBD 89 12 11 7 2 1 13 0.1 013 20WE0485 Buffer (Separator Venting) 85 73 2 12 710 0 0.4 TOTAL (tpy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.7 0.0 0.0 0.0 0.0 1.1 7 20WE0486.CP1 12/15/2020 Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. ,4 ;,r,_= . crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) APR x k website. 20 2.0 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: ZO w PO416 AIRS ID Number: 123 / 9D9B /001 [Leave blank unless APCD has already assigned a hermit and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Crestone Peak Resources Operating, LLC Vogl Geist McCoy 5H -F267 (East) Site Location SENW Sec. 5, T2N, R67W County: Weld Mailing Address: (include Zip Lode) 10188 East I-25 Frontage Road Firestone, CO 80504 NAICS or SIC Code: 1311 Contact Person: Sabrina Pryor Phone Number: (303) 774-3923 E -Mail Address2: sabrina.pryor@crestonepr.com 1 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. Form APCD-2O5 - Condensate Storage Tanklsl APEN Revision 12!2019 1 Page 5 of 73 429469 lee•COLORADO fmw� u x.afti Permit Number: AIRS ID Number: 123 / 9D9B / 001 [Leave blank unless APCD has already assigned a hermit and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name; ❑ Change permit limit ❑ Transfer of ownership" ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Request conversion from GP01 to an individual permit. 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-1O4) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate storage tanks TANKS 10/29/2014 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 0 Exploration Ft Production (EEtP) site weeks/year Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? IS Yes ■ No Are Flash Emissions anticipated from these storage tanks? p Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No ■ a If "yes", identify the stock tank gas -to -oil ratio: m'/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No D Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual• emissions ≥ 6 ton/yr (per storage tank)? Yes No p COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 12/2019 Page 6 of 73 ❑ Upward ❑ Horizontal Permit Number: AIRS ID Number: 123 / 9D9B / 001 ve bank i ntess APCC has atready assigned a permit n and AIRS ID] Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbUyear) 39,386 Requested Annual Permit Limits (bbUyear) 47,450 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 56.5 degrees ❑ Internal floating roof Tank design: Ei Fixed roof RVP of sales oil: 11.4 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TANKS 24 12,000 11/2014 11/2014 Wells Serviced by this Storage Tank or Tank Batteryb (EftP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37783 Vogl Geist 2D -5H -F267 ■ 05 - 123 • 37778 Vogl Geist 2E -5H -F267 ■ 05 - 123 - 37777 Vogl Geist 2F -5H -F267 ❑ 05 - 123 - 37780 Vogl McCoy 2E -5H -F267 ■ 05 - 123 • 37779 Vogl McCoy 2F -5H -F267 ■ s Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.167829 / -104.914945 r❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. en Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCC-205 Condensate Storage Tankis) APED! - Revision 1212019 Page 7 of 73 11ICOIOIIADO 3 I Vlr' ." d � a Permit Number: AIRS ID Number: 123 / 9D9B / 001 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: Make/Model: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: NA MMBtu/hr Type: Enclosed Combustor Make/Model: NA Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes ❑ No Pilot. Burner Rating: 2,737.5 2,800 0.025 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (Ear> Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 25 psig Describe the separation process between the well and the storage tanks: Wellhead production t0 high -low pressure three-phase separators, high-pressure gas to sales, low-pressure gas to enclosed combustor. Condensate and produced water to storage tank battery. -BF 12/15/20 Per attached email Form APCD-2O` Condensate Storage Tank(s) APEN - Revision 12/2019 Page 8 of 73 'COLORADO 'l I g • lbWo�w Permit Number: AIRS ID Number: 123 / 9D9B / 001 ark unless APCD has already assigned a permit -/ and AIRS IDI Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. 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) VOC Enclosed Combustor (ECD) 100% 95% NOx CO HAPs Enclosed Combustor (ECD) 100% 95% Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP -42, Mfg., etc.) Emissions (tons/year) Emissions$ (tons/year) Emissions (tons/year) Emissions (tons/year) VOC 1-4.020. 10.38 lb/bbl Site Specific 106.54 5.32 282,80 245.27 44-14 12.31 NOx 0.068 Ib/MMBtu AP -02 -- 0.17 -- 0:34 0.48 CO 0.310 Ib/MMBtu AP -42 -- 0.78 -- 1,40 2-19 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. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? 0 Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (lbsfyear) Controlled Emissions$ (lbsfyear) Benzene 71432 4:06E-02 3 00E-02 lb/bbl Site Specific 689 34 Toluene 108883 2 80E -022.46E -C2 lb/bbl Site Specific 655 43 Ethylbenzene 100414 1.02€ -O3 -1.10E -C 3 lb/bbl Site Specific 91 5 Xylene 1330207 677E -03790E-0 lb/bbl Site Specific 768 38 n -Hexane 110543 367E -01236E -C1 lb/bbl Site Specific 9,559 478 2,2,4-Trimethylpentane 540841 4.12E-o45.86E-c4 1b/bbl Site Specific 358 16 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. -BF 12/15/20 Per attached email Form APCU-2O5 Condensate Storage Tank(s) APEN - Revision 12/2019 Page 9 of 73 COLORADO 5 , arntallaga ewme se.nem ent Permit Number: AIRS ID Number: 123 / 9D9B i 001 [Leave blank unless APCD has a!reach/ assigned a permit ;: and AIRS ID[ Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, 1 further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 4/22/2020 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: El Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303)692-3175 OR (303) 692-3148 APCD Main Phone Number (303)692-3150 Form APCD-2O5 Condensate Storage Tanks) APEN - Revision 12/2019 6 ( > lit Page 10 of 73 COLORADO E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: Crestone Peak Resources Operating, LLC Source Name: Vogl Geist McCoy 5H -F267 (TANKS) Emissions Source AIRS ID2: 123 / 9D9B / 001 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37782 Vogl McCoy 2G -5H -F267 ❑ 0.5 - 123 - 37781 Vogl McCoy 2H -5H -F267 ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - • - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A • Form APCD-212 Blb-APEN FORM 212 - Wellsite Addendum-VGM 5H -F267 TANKS Page 11 of 73 Gas Venting APEN - Form APCD-2114,, Air Pollutant Emission Notice (APEN) and ,f 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 locks 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: *Lt AIRS ID Number: 123 / 9D9B / 013 (Leave Flank unless APCD has at; a salned a pernmi . and AIRS ID] Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Vogl Geist McCoy 5H -F267 (East) Site Location: SENW Sec. 5, T2N, R67W Mailing Address: (Include Zip Code) 10188 East I-25 Frontage Road Firestone, CO 80504 a Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Sabrina Pryor (303) 774-3923 sabrinapryor@crestonepr.com 1 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. Form APCD-211 Gas Venting APEN - Revision 12.2019 Page 19 of 73 429470 COLORADO 1 I «a.°""°="4 Permit Number: AIRS ID Number: 123 / 9D9B / e blank unless APCD has already asstened a permit = and AIRS I0) Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that apphes) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership" ❑ Other (describe below) - OR APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTION; - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info ii 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: Huffer (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: 6/1/2020 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? Form APCD-211 - Gas Venting APEN - Revision 12/2019 Page 20 of 73 days/week weeks/year Yes ❑ Yes Yes ❑ No Q No ❑ No iteicotonAoo Permit Number: AIRS ID Number: 123 / 9D9B / {Leave blank unless APCD has already assigned a permit and A1R5 ID} Section 4 - Process Equipment Information • Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameterss: Liquid Throughput Process Parameterss: Vented Gas Properties: Ej Yes ❑ No Vent Gas Heating Value: 2,190 BTU/SCF Requested: ,4 07 MMSCF/year Actual: __ MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 3$.5320 VOC (Weight %) 69.4516% Benzene (Weight %) 0.,4127% Toluene (weight %) 0.3512% Ethylbenzene (weight %) 0.0109% Xylene (Weight %) 0.0595% n -Hexane (Weight %) 3.4327% 2,2,4-Trimethylpentane (Weight %) 0.0019% Additional Required Documentation: a ❑ pressure) Attach a representative gas analysis (including BTEX £t n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and s 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 APCD-211 Gas Venting APEN - Revision 12/2019 Page 21 of 73 Permit Number. AIRS ID Number: 123 / 9D9B / ;Leave blank unless ARCD has already assigned a permit " and AIRS ID} Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.167829 /-104.914945 ® 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. £3peralor i i(101. 17i�rge i�iit Above royr d F -v. Temp t X ie Fiats �4. Y 1ty ': {≥ 1 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Section b - 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 MMBtu/hr Type: Enclosed Combustor Make/Model: N/A Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: NA 95 95 Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 2,190 0.025 Btu / scf MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Farm APCD-211 Gas Venting APEN - Revision 12/2019 Page 22 of 73 4I COLORADO DeedPutti Health 5Honn:mm 1 Permit Number: AIRS ID Number: 123 / 9D9B / [Leave blank unless APCD has already assigned a permit and AIRS ID) 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? Q 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 (x of total emissions captured by control equipment) Control Efficiency (x reduction of captured emissions) PM SO. NO. CO VOC Endosed Combustor (ECD) 100% 95% HAPs Endosed Combustor (ECD) 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: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb (tons/year) Uncontrolled Emissions (tans/year) Controlled Emissions (tons/year) PM SO. NO. 0.068 tb/MMBtu AP -42 0,31- 0-30 CO 0.31 tb/MMBtu • AP -42 -- -- — 1.41 1.38 VOC 70,610 Ib/MMscf Site specific -- -- 144 7.18 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled ' Emissions (lbs/year) Controlled Emissions6 (lbs/year) Benzene 71432 420 lb/MMscf Site specific 1,706 1.708 85,28 85 Toluene 108883 357 Ib/MMsd Site specific 4;451 1.453 72.57 73 Ethylbenzene 100414 11.08 lb/MMscf Site specific 45.05 45 2,-25 2 Xylene 1330207 60_49 lb/MMscf Site specific 246 4230- 12 n -Hexane 110543 3,490 Ib/MMsd Site specific 44,4&714,204 708 710 2, 2,4-Trimethylpentane 540841 1.93 lb/MMscf Site specific 7 85 0.39 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. Form APCD-211 - Gas Venting APEN - Revision 12/2019 Page 23 of 73 asCOLORADO 5 »"ate -BF 12/15/2020 P4r attached email Permit Number: AIRS ID Number: 123 / 9D9B / [Leave blank unless APCD has already assigned a permit and AIRS !Dl Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. C ; ; ,�.. : , `� 4/22/2020 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 $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 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 Form APCD-211 - Gas Venting APEN - Revision 12/2019 Page 24 of 73 ICOLORADO Hello