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Home My WebLink About20203825.tiffRECEIVED COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 9, 2020 Dear Sir or Madam: DEC 18 2020 WELD COUNTY COMMISSIONERS On December 10, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Crestone Peak Resources Operating, LLC - Billings 34H -B268 Battery. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govicdphe Jared Polis, Governor ( Jill Hunsaker Ryan, MPH, Executive Director PubrC Rev►ew of/oy/21 Gc..pL(17)� kt_0 $/TRI PW6SM/ER/CHICK oG(m) 12/2 I/2O '.I 2020-3825 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating, LLC - Billings 34H -B268 Battery - Weld County Notice Period Begins: December 10, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Crestone Peak Resources Operating, LLC Facility: Billings 34H -B268 Battery Well production facility NWNE Section 34 T2N R68W Weld County The proposed project or activity is as follows: The permittee submitted an application to modify a well production facility located in the ozone non -attainment area. With this application, the operator is requesting to permit flaring of natural gas from the low pressure separators when the VRU is down. The application brings the facility to synthetic minor status for Title V for VOC (under 50 tpy). The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0591 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 fig COLORADO Department of Public Health b Environment x*.•x,Nto, COLORADO Air Pollution Control Division Department cf Public Health 6 £nwronment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0591 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: Billings 34H -B268 Battery Plant AIRS ID: 123/9CE0 Physical Location: NWNE Section 34 T2N R68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Buffer 004 Flaring of natural gas vented from the low pressure side of six (6) high/low pressure (HLP) separators and routed through the buffer house during vapor recovery unit (VRU) downtime. Enclosed Combustor(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4. ) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Buffer 004 --- --- 2.0 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and demonstrate compliance with the limits in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 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 Equipment ID AIRS Point Control Device Pollutants Controlled Buffer 004 Emissions from the low pressure side of six (6) high/low pressure (HLP) separators are routed through the buffer house to enclosed combustor(s) during vapor recovery unit (VRU) downtime. VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Buffer 004 Liquids throughput of condensate tanks during VRU downtime 32,850 bbl The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. 10. The owner or operator must use monthly VRU downtime records, monthly condensate oil throughput records, calculation methods described in the OEtM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 3 of 10 CP. N! 0 COLORADO Air Pollution Control Division Department of Public Wealth 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (0£tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or Page 4 of 10 COLORADO Air Pollution Control Division [Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the p.eople of Colorado For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirementsof Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit (permit - required points only) 001 Condensate storage tanks VOC NOx 50 50 13.9 0.4 003 Condensate loadout 004 Separator flaring Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Insignificant Sources -- (APEN- and/or permit -exempt) Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with, the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section IIIG. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation_ of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 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 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC. Permit for flaring of low pressure gas vented from the low pressure side of HLP separators at an existing well production facility. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Buffer 004 Benzene 71432 207.66 10.38 Toluene 108883 433.44 21.67 Ethylbenzene 100414 45.44 2.27 Xylenes 1330207 385.41 19.27 n -Hexane 110543 2069.57 103.48 2,2,4-Trimethylpentane 540841 1.87 0.09 Note: All non-criter'a reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab a and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health t; Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 2.4458 0.1223 Gas Analysis (4/22/2020) 71432 Benzene 0.0063 0.0003 108883 Toluene 0.0132 0.0007 100414 Ethylbenzene 0.0014 0.00007 1330207 Xylenes 0.0117 0.0006 110543 n -Hexane 0.0630 0.0032 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The VOC and HAP emission factors listed above are based on a site specific extended gas analysis obtained 4/22/20. The weight % values and molecular weight (33.6179 lb/lbmol) from the sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10) were used to determine the emission factors. NOx and CO emissions are based on a gas heat value of 1904.4 Btu/scf, and are below the APEN reporting threshold. Actual emissions are calculated by multiplying the emission factors in the table above by the total throughput of liquid from the condensate tanks while the VRU is down. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-315O. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Page 9 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 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 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Andy Gruel 431309 6/16/2020 11/16/2020 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 segmentiOil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Ozone (NOx& VOC) erestone Peak Resources Operating, LLC 123 9CE0 Billings 34H -B268 Battery Weld County Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) Emissions Source Type Equipment Name Emissions Control? Permit # (Leave blank unless APCD has already assigned) Issuance # Self Cert Required? Action Engineering Remarks 004 Separator Venting Buffer Yes 20WE0591 1 Yes Permit Initial Issuance Quadrant Section Township Range NVi/NE 2N Section 03 - Description of Project Crestone Peak Resources Operating, LLC (Crestone) submitted an application to modify a well production facility located in the ozone non -attainment area. With this application,. the operator is requesting to permit the flaring of natural gas from the low pressure separators. The operator also submitted an application to register 123/9CE0/001(condensate storage tanks) under GP01(package 432421). The application brings the facility to synthetic minor status for Title V for VOC (under 50 tpy). Public comment is required for this application because the permit establishes a new synthetic minor limit on VOC below 50 tpy and the NANSR threshold. Sections 04, 05 & 06 - For Division Use Only Section 04- Public Comment Requirements Is Public Comment Required? If yes, why? Requesting' Synthetic Minor Permit • Section 05 - Ambient Air Impact Analysis Requiremer Yes new syn or limit for VOC for NANSR Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: 502 Prevention of Significant Deterioration (PSD) ❑ Title V Operating Permits (OP) ❑ Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: 502 Prevention of Significant Deterioration (PSD) DODD Title V Operating Permits (OP) ❑ Non -Attainment New Source Review (NANSR) No Yes NOx CO VOC ❑ CIO DOD ❑ O No NOx CO VOC ❑ ❑ ❑ O ❑ PM2.5 PM10 TSP HAPs ❑ ❑ ❑ DOD PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ ❑ Section 1- Administrative Information aciliC/ AlRs ID: County 9c60 Plant 004 Point Section 07 - Equipment Dmcnptian Details Detailed Emissions UM Description: Flaring nMural gas vented nom the low pressure aide ofsix (6) high/low pressure separators and ranted through she bufferhaucp,. Emission Control Device Description. E I d..Combusk 44gveporrecavery uni}(Vitt')dowmime. Requested overall Voc & HAP control Efficiency °h: 95 Limited Process Parameter ,.F Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions- Separator Actual Throughput —asai84, r;"-(.. q:Barrels(bbt per year Requested Permit Limit Throughput= :arzs,;s; T rrels(bbl) per year Requested Monthly Throughput= _ Barrels OM) per month Potential to Emit (PTE) Throughput= .,.m_..+ Barrels(bbh peryear Secondary Emissions -Combustion Device(s) for Alt - Pollution Control Separator Gas Heating Value: - 1904.4 Btu/sof Volume of waste gas emitted per BBL of liquids throughput: , 4 scf/bbl -rcmmtaspecifle gas samplecollected 4/2/20 Control Device Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: 2S sett -.1000 Btu/scf MMscf/yr MMEtu/yr section 04- Emissions Factors 8 Methodologies Description SIN(6)weils: eithis 'minty produce co so, (6)high/low pressure (HLP) separatorsThe high pressure gas from the high pressure side.. the' IMP separators routed to the sales line via vapor recovemunits. The lowpressure gas .roMthe low :pressure sde of the HLP separators istye ally routed through a buffer house (liquids knockout) and then to the sales line via vapor recovery units Owing vapor recovery unit downtime,. the law pressure gas Yan.s1from the low pressure side of the HLP sessmatorss routed through a baffer tiome.(hqu ds knommt)andthento the enclosed combustor(. in order W develop We Slte We.frc era.,,, rate(se0.1)u.ng Gromax, tae operator used a. site pee is sales gas sample and a pressurized liquid sample collected on 4/22/2020. The operator then teedPomax to model the LP gas production rate(scf/bbl condensate). The operator collecteda MM. spmiRcsampie of the vented gas on, 4/22/20 to use the gas compositionf on factor d velopment. IPromax modeled gas flow rate r 0.00444187IMMSCFD lPromax model basis 50:001barrels per day of condensate production Modeled gas rate 1..4 s f/bbl Molecular weight 33.6179 weight h oxygen/Argon CO2. N2 methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n -Reza ne ryclohexane other hexanes heptanm methylcyclohmane 224-TMP Benzene Toluene Ethylbenzene Xylenes Cea Heavies 0:0131 0.I534 21.8715 770 49378 62274 1.4391 0:4178 22871 1.4326 0.7172 0.0013 0.1444 0.3014 0:0316 0.2680 Total VOC WI% miss ion Factors Senora[ rVent pollutant Benzene al ene thylberrzene glen n -Hexane - 124TMP (Uquid Throughput) (Liquid Throughput) Primary Control Device Uncontrolled Uncantrolled Emission Factor Source Pollutant (Ib/MMBtu) lb/bbl Emission Factor Source [Waste Heat ombustedf (Ga Throughput) PM10 -0.007 P _ 00075 0600 NOx '',0680 '000 Pilot ight Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMB[ s) Ib/MMsef Emission Factor Source PM10 (Waste Heat Combusted) 0 0680 (Pilot Gas Throughput) 2 of 5 K:\PA\2020\20WE0591.CP3 Separator Ventlrg Emissions Inventory Section OS Emissions Inventory Cdteda Pollutanss Potenllal to Emit Uncontrolled (tons/wari Actual Emissions Uncontrolled Controlled (tons/year) (tom/year) Requested Permit UmRs Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly limits Controlled fibs/month) _ __ P731O PM25 SOt NOS VOC CO 0012 0012 0012 0012 0012 0012 2 0001 0001 0001 0 0112 0112 0 112 19 10173 40 )73 2009 lit 0513 0511 0 Is 87 Hazardous Air Pollutants Potential to Eot Uncontrolled (lbs/year) Actual Emissions Uncontrolled Ilbghear) Controlled Ibshear) Requested Permit Limits Uncontrolled Controlled (lte/Wrt) Ibs/searl Benzene Toluene Etirylbenzene Xylene n Hexane 124 TMP 70106 207137 1013 413. 43344 2167 4514 n 44 217 38541 33541 1121 Zorn 7 2^099 10316 181 1.37 O. Section 06 Regulatory Summary Malys Regulation Parts B Regulation 7 Part 0 Section II B F Regulation 7 Part D Section II B 2 e (See regulatory aeon..y.7633e. for detailed analysis) Mono mums a permit Sou a s ett to ciliation (art S ct on iC2 r Il co tun deulc ter Ihh eoarimr s not si.bf < o Rol 2 Part D Suction II 0 2+ Section 07 Initial and Periodic Sampling and Testing Requirerrents Using Uquld Throughput to Monitor Compliance D0M the company use sne specdic emersion factors based on a pressurued liquid sample (Sampled upstream el the equipment covered under this AlRs ID) and prams simulation to estimate emnsens7 �a.—"* This sample should have been collected wrthln one year of the application received date However H the facility has not been modified (eg no new wells brought on line) then d maybe appropriate to use an older site -specific sample Il no the permit will contain an Initial Compliance testing requirement to collect a siteMspeclllc liquid sample and conduct an emission factor analysis to demonstrate that the emission factors aro less than or equal to the emissions factors established with this application _ Does the company request a control deuce efficiency greater than 9S% for a flare or combustion device? dyes the permit will contain initial and pored c compliance testing in accordance with PS Memo 2001 Section 03 Technical Analysis Notes l The weih were produung pnortb <Ngust 2014 and have of been refractured orreecl;n eted, andso the separatms o>vened byth6 point arenot sublectio Regulatnn T Part; Section llF w '1 w 4s r. r 2 The ertended gas alnlysA used to atablesh embslon factors In this application was obtalned from Me inlet of the hurter house (liquids knorkeut for tow pressure ga vented Irom the low pressure side of the HIP se{an{tors) rt this faaldy As` a result it h representative of only tow pressure gas that is vented to and contnalled by the enclosed combustors tai s , r r— — i t r 3 � ' 7f / ,r, , r _o t 1 /, r r 'r 1 `°rP w �,.. 3 NON and CO emissions from source are below ADEN reporting thresholds As a result limits and emission factors ore not lnckaded in the permh for NCiiimiCO,' a (4. During norm�pentlom tow pressure gas vented from the low pressure side of the HLP separaton b captured using Vapor recoVery'Inds (VRUs) and routed to the sales line During VBU downtime lie low pressure gas b routed through the buffer house (liquids knockoin) and Den to the enclosed combustors VRU downtime tracking is required m the permit to quantdythe volume of gas vented from the separators and routed to theendoied combustor(s) iy— ^ N S lndal and ire -iodic wale emeslurrs checks for the control den. are addressed by the 0&Mplan As a result, the penis¢ does nat contaln initial or perlode opacrlyNstinge ' Y F.t ' ' sz r 4 a` } t/ Section 09 SCC Cooling and Emissions Factors(For Inventory Use Only, AIRS PoIntN Process q SCC Code 004 01 310.01'9 GI go, di lion Goa lir,. ipl at on pollutant Uncontrolled Emissions Factor Control IC Units IC/1COCu rr Is PM25 0 ib/lf Ova cis 50x 005 0 Ihr 030 b rrels NOg 524 0 Y/10a15aneh VOC 1.,35 5 35 lb/ .V 0 rnr etc CO 3120 b/ rr'Ob n I Benzene o11 95 t2 cm berrcls Toluene 9 l L/tu'0S rr la Ethylbenzene 133 c000 rr Is Xylene Ill) nS b/109h m1 n Hexane 63. 75 b/10c0 ham Is 224 TMP OOis 15 1b/1000 tamuls P3110 l l5 \ � r_a �J 3 of 5 K \PA 2020\2OWE0591 CPI 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 Operatin 123 9EC0 Billings 34H Battery g, LLC History File Edit Date Ozone Status 11/17/2020 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 4.8 1,469.1 0.0 26.3 78.1 0.0 0.0 0.0 0.0 4.8 73.5 0.0 26.3 3.9 Previous taken from Nov 2014 tab Previous Permitted Facilit total 0.0 0.0 0.0 0.0 4.8 73.5 0.0 26.3 78.1 6.0 0.0 0.0 0.0 4.8 73.5 0.0 26.3 3.9 001 GP09 18-400 bbl condensate tanks 0.31 159.0 1.39 6.0 0.31 10.0 1.39 0.3 June 202a convert from 14VVE1077 to GP01 002 XA Produced water tanks 0.9 0.1 0.9 0.1 Cancelled 2017, below reporting threshold 003 14WE1079 truck loadout 37.3 2.1 1.9 0.1 No change 004 20WE0591 Separator venting "Buffer" 0.0 0.0 0.0 0.1 40.2 0.5 1.6 0.0 0.0 0.1 2.0 0.5 0.1 June 202O. new point APEN-Exempt / Insignificants Hi/Low Separators (6) 0.1 0.1 1.3 0.1 1.1 0.0 0.1 0.1 1.3 0.1 1.1 0.0 From June 2020 Form 102 Fugitive component leaks 0.4 0.0 0.4 0.0 From June 2020 Form 102 FACILITY TOTAL 0.1 0.1 0.0 0.0 1.7 237.5 0.4 3.0 9.9 0.1 0.1 0.0 0.0 1.7 14.9 0.4 3.0 0.6 VOC: Syn Minor (NANSR and OP) HAPS: Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0.4 236.5 0.0 1.9 9.7 0.0 0.0 0.0 0.0 0.4 13.9 0.0 1.9 0.5 Excludes units exempt from permits/APENs (O) Change in Permitted Emissions 0.0 0.0 0.0 0.0 -4.4 -59.6 0.0 -24.4 Pubcom & modeling not required Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 15.3 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy -59.6 Note 1 Note 2 Page 4 of 5 Printed 11/17/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY- HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Crestone Peak Resources Operating, LLC 123 9EC0 Billings 34H Battery Emissions - uncontrolled ( bs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 18-400 bbl condensate tanks 915 797 30 207 9254 797 6.0 002 XA Produced water tanks 49 153 0.1 003 14WE1079 truck loadout 701 1238 52 544 1738 2.1 004 20WE0591 Separator venting "Buffer" 208 433 45 385 2070 2 1.6 0.0 0.0 APEN-Exempt / Insignificants 0.0 Hi/Low Separators (6) 2 47 0.0 Fugitive component leaks 3 9 1 10 31 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.9 1.2 0.1 0.6 6.6 0.0 0.4 0.0 0.0 9.9 = au hNrs wnere uncontroiiea emissions > ae minimus values Red Text: uncontrolled emissions < de rninimus Emissions with controls (Ibs per vear POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 18-400 bbl condensate tanks 46 40 10 463 39.83 0.3 002 XA Produced water tanks 49 153 0.1 003 14WE1079 truck loadout 35 62 3 27 87 0.1 004 20WE0591 Separator venting"Buffer" 10 22 2 19 103 0 0.1 0.0 0.0 APEN-Exempt / Insignificants 0.0 Hi/Low Separators (6) 2 47 0.0 Fugitive component leaks 3 9 1 10 31 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.4 0.0 0.0 0.0 0.0 0.6 5 20WE0591.CP1 11/17/2020 Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or 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, welt 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-2(k) 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: 2{6W E pcj 1 AIRS ID Number: 123 / 9CE0 / D oLi- Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Billings 34H -B268 Battery Site Location: NWNE Section 34, T2N, R68W Mailing Address: 10188 East 1-25 Frontage Road (Include Zip Code) Firestone, CO 80504 Site Location Weld County: NAILS or SIC Code: 1311 Contact Person: Sabrina Pryor Phone Number: (303) 774-3923 E Mail Address2: sabrina.pryor@crestonepr.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that witl 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. APCD-21 i ,COLORADO ' I 'o.w*®nx at NJ,. !7®1M M Ln+fmnmeei Page 12 of 65 Permit Number: AIRS ID Number: 123 / 9CE0 / Section 2 - Requested Action 0 NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Buffer (separator) gas venting controlled by enclosed combustor. Company equipment Identification No. (optional): Buffer For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 07/01/2020 El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year 0 Yes ❑ Yes ❑ Yes ❑ No 0 No ❑✓ No LCD - Page 13 of 65 COLORADO Permit Number: AIRS ID Number: 123 / 9cEo / 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? Q Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: Q No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 32 850 bbl/year Actual: __ bbl/year Molecular Weight: 33.6179 VOC (weight %) 55.8663 Benzene (weight %) 0.1444 Toluene (weight %) 0,3014 Ethylbenzene (Weight %) 0.0316 Xylene (Weight %) 0.2680 n -Hexane (weight %) 1.4391 2,2,4-Trimethylpentane (weight %) 0.0013 Additional Required Documentation: Q Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. _. rnif.7 ielkigek-.COLORADO 3Nap 411410 �� Page 14 of 65 Permit Number: AIRS ID Number: 123 / 9cE0 / Section 5 - Geographical/Stack Information Geographical Coordinates (LatitudelLongitude or UTM) 40.101225/ -104.984766 ❑✓ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (•F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack depth (inches): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section . ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: NA Type: Enclosed Combustor MMBtu/hr Make/Model: NILA Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 % Minimum Temperature: NA Waste Gas Heat Content: Constant Pilot Light: El Yes ❑ No Pilot burner Rating: 1,904 0.025 Btu/scf MMBtu / hr Other: Pollutants Controlled: Description: Requested Control Efficiency: % Page 15 of 65 'COLORADO 4 F p«rtertn.wr.wa Permit Number: AIRS ID Number: 123 / 9cE0) Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) PM SO), NOx CO VOC Enclosed Combustor 100% 95% HAPs Enclosed Combustor 100% 95% Other: From what year is the following reported actual annual emissions data? NA Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissionsb {tons/year) Uncontrolled Emissions tons/ ear ( y ) Controlled Emissions tons/ ear / y ) PM SOx NO, CO VOC 0.068 0.31 2.45 Ib1MMBtu lbaMMBtu lb/bbl AP -42 AP -42 Site specific — — — — — — — — 40.17 0.11 0.51 2.01 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) Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., fg•r etc.) Uncontrolled Emissions (lbs/year) Controlled Emissionsb (lbs/year) Benzene 71432 6.3E-03 lb/bbl Sfte specific 208 10.38 Toluene 108883 1.3E-02 e,/bbl Site specific 433 21.67 Ethylbenzene 100414 1.4E-03 Ibibbl Site specific 45.48 2.27 Xylene 1330207 1.2E-02 Ib/bbl Site specific 385 19.27 n -Hexane 110543 6.3E-02 lb/bbl Site specific 2,069 103 2, 2,4-Trimethylpentane 540841 5.7E-05 PAN Site specific 1.88 0.09 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. -2 ©. COLORADO 5 Deparmer. at hahlr Rea. tarn Page 16 of 65 4 Permit Number: AIRS ID Number: 123 i 9cEo / Section 9 - Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 06/15/2020 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 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Small Business Assistance Program (303) 692-3175 OR (303)692-3148 APCD Main Phone Number Make check payable to: (303) 692-3150 Colorado Department of Public Health and Environment Farm Gas 'pit; i Page 17 of 65 coLoRADO 6 I bapottrirM mgr BWU It Cn.umn.n< Hello