The URL can be used to link to this page

Browse Search

Home My WebLink About20195170.tiffPLADGc Review O1/©6/2O COLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 17, 2019 Dear Sir or Madam: RECEIVED DEC 2 3 2019 COMMISSIONERS On December 18, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for HighPoint Operating Corporation - Critter Creek 16 SE Pad . 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 &t 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.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director cc : pL(r'P) N1 -(,x), Pw(smiettiCHR ) OG(514) 2019-5170 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: HighPoint Operating Corporation - Critter Creek 16 SE Pad - Weld County Notice Period Begins: December 18, 2019 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: HighPoint Operating Corporation Facility: Critter Creek 16 SE Pad Exploration Et Production Well Pad SESE Quadrant of Section 16, Township 11N, Range 63W Weld County The proposed project or activity is as follows: The Critter Creek 16 SE Pad is a new facility operated by HighPoint Operating Corporation (HighPoint). This facility processes the liquid from (17) wells onsite. After separation, crude and produced water is stored in tanks on location. In this application, HighPoint has requested to permit the emissions associated with storing crude and produced water. Any gas not used to fuel the onsite combustors and heaters is routed to a sales line. Crude is measured through a LACT and sold in a sales line. This facility also includes a compressor with its engine permitted under a GP02 (Point 001, Approval Letter Sent October 9, 2019, Package 400447). Fugitives and emissions from the 19 heaters onsite were reported as permit exempt. 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • 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 19WE0912 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: COLORADO Department at Public Health E* Environment James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLOR ADO Department of Public Health & EYWISCIitment 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: 19WE0912 Date issued: XX Issued to: HighPoint Operating Corporation Facility Name: Plant AIRS ID: Physical Location: County: General Description: Well Production Facility. Issuance: 1 Critter Creek 16 SE Pad 123/A05C SESE Quadrant of Section 16, Township 11N, Range 63W Weld County Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 002 Eight (8) 840 barrel fixed roof storage vessels used to store crude oil Enclosed Combustors 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section 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 www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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: AIRS Tons per Year Emission Point NO), VOC CO Type 002 2.1 52.4 9.5 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 & Environment 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.) AIRS Point Control Device Pollutants Controlled 002 Enclosed combustors with 98% Manufacturer Guaranteed Control Efficiency 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 AIRS Point Control Device Pollutants Controlled 002 Crude Oil Throughput 1,824,270 barrels "! Compliance with the annual throughput ''limits must be determined on a rolling twelve (12) month total. By the end of each month anew 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. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.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 XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; 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 Page 3 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 approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&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&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. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) 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. Page 4 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 ADDITIONAL REQUIREMENTS 18. 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 V0C or N0x per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five " percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation 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, VI.B.4). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit Number AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit GP02 001 RICE VOC 0 2(PSD)y 1.4 19WE0912.CP1 002 Crude Storage 52.4 19WE0913.CP1 003 Produced Water Storage 10.3 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- 1 t4.5(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 bee an 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 Permit History NI g COLORADO Air Pollution Control Division Department of PublicHealth & 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 James Ricci Permit Engineer Issuance Date Description Issuance 1 ! This Issuance Issued to HighPoint Operating Corporation for crude storage at a synthetic minor facility in the attainment area. Page 7 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 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 (Ib/yr) Controlled Emissions (lb/yr)' Benzene 71432 3570 178 002 Toluene' 108883 2682 134 Ethylbenzene 100414 320 16 Xylenes 1330207 779 39 n -Hexane 110543 29026 1451 2,2,4-Trimethylpentane 540841 233 12 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 �.I peet+a COLORADO Air Pollution Control Division Department of Public Health & 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/bbl Controlled Emission Factors lb/bbl Source -- NOx 1.98 x 10"3 1.98 x 10-3 AP -42 Chapter 13.5 Industrial Flares -- CO 9.02 x 10-3 9.02 x 10"3 -- VOC 1.15 x 10° 5.75 x 10-2 ProMax 5.0 and TANKS 4.0 71432 Benzene 1.96 x 10"3 9.78 x 10"5 108883 Toluene 1.47 x 10"3 7.35 x 10-5 100414 Ethylbenzene 1.76 x 10"4 8.78 x 10-6 1330207 Xylene 4.27 x 10-4 2.14 x 10-5 110543 n -Hexane 1.59 x 10-2 7.96 x 10-4 540841 2,2,4-Trimethylpentane 1.28 x 10-4 6.39 x 10-6 :. Note: The uncontrolled emissions factors for this point are based on a pressurized liquid sample taken at the Critter Creek 16SE facility (Well 5708B) on 7/9/2019 at 150.6 psig and 125 deg F. Flash emissions were estimated by modeling this site specific sample in ProMax 5.0 through a heater treater operating at 25 psig and 120 deg F and then to an atmospheric tank. Working and breathing losses were estimated by modeling a liquid with a RVP of 6.5 in TANKS 4.0. The controlled emissions factors are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN 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. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971 /oil - and -natural -gas -sector -emission -standards -for -new -reconstructed -and -modified -sources Page 9 of 10 COLORADO Air Pollution Control Division Department of Pubiic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD Synthetic Minor Source of: VOC 10) 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.g0V/ 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 MALT; 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: James Ricci Packaged: 415066 Received Date: 914/2019 Review Start Date: 10/25/2019 Section 01- Facility Information Company Name: HighPoint Operating Corporation! County AIRS ID: 123 Plant AIRS ID: AOSC Facility Name: Critter. Creek 16 SEP3`• Location: SESE Quadrant of Section 16, Township 11N, Range 63W County: Weld County Type of Facility: Exploration & Produc What industry segment? Cltl & Naturai Gas -Production Is this facility located in a NAAQS non -attainment area? - - No If yes, for what pollutant? O Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Quadrant Section Township Range SESE ❑ Ozone (NOx & VOC) 1 3` AIRs Point 9 Emissions Source Type Equipment Name Emissions Control? Permit M Issuance 9 Self Cert Required? Action Engineering Remarks 002 Crude ^Oil Tank Yes S 9WE0912 1 Yes! Permit Initial Issuance 003 Produced Water Tank Yes 19WE0913 1 Yes Permit Initial issuance Section 03 - Description of Project The Critter Creek 16 SE Pad is a new facility operated by HighPoint Operating Corporation (HighPoint). This facility processes the liquid from (17) wells onsite, After separation, crude and produced water is stored in. tanks on location. In this application, HighPoint has requested to permit the emissions associated with storing crude and produced water, Any gas not used to fuel the onsite combustors and heaters is routed to a sales line. Crude is measured through a tACT and sold in a sales line. This facility also includes a compressor with its engine permitted under a GP02 (Point 001, Approval Letter Sent October 9, 2019, Package 400447) Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Yes ousting Synthetic NJinorPermit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? N 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: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Yes 302 NOx CO VOC PM2.5 PM10 TSP HAPs O OOO ❑ ❑ ❑ ❑ ❑ D O DEL ❑ ❑ Is this stationary source a major source? tfo If yes, explain what programs and which pollutants here: SO2 NOx CO Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ OOO OOO ❑ ❑ Crude Oil Storage Tank(s) Emissions Inventory 002 Crude Oil Tank Facility AIRs ID: 123'' A05C Plant 002 Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: .barrel fixed root storage, vessels used to store crude nit Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = v Guaranteed Control efficie im rron Big Hurt Barrels (bbl) per year 1,824,270 - i Barrels (bbl) per year 124,270 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Btu/scf Waste gas/bbl of liquids produced = r ;I ti §4� c° scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = PTE heat content of waste gas routed to combustion device = VOC Mass 56 Flash Heating Value MW Pilot Gas Usage Fuel Heating Value Number of ECDs Actual pilot light emisisons = scf/hr BTU/scf Actual Crude Oil Throughput While Emissions Controls Operating = Requested Monthly Throughput = 1S4930 Barrels (bbl) per month 87ti m3/liter 44,212 MMBTU per year 53,055 MMBTU per year 53,055 MMBTU per year 6,377 MMBTU per year <— Flash Only (ProMax), see below for more conservative Method O— Flash Only (ProMax), see below for more conservative Method <-- Flash Only (ProMax), see below for more conservative Method <— Flash Only (ProMax), see below for more conservative Method <-- Flash Only (ProMax), see below for mare conservative Method MMBtu ton lb 1 1 Btu MMBtu Flash Gas � = Uncontrolled VOC — x 2000 tan x cosMw x 379.413'f:: X voc X Heat Content scF X 1 msetn yr yr Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? 52,131 MMBTU per year 61,282 MMBTU per year <— Includes Pilot <— Includes Pilot Pollutant Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bbl) (Crude Oil Throughput) 1.15E+00. 1.96E-03 1.47 E-03 4-27E-04 1.59E-02 1.28E-04 (Crude Oil Throughput) 9.78E-05 8.78E-06 7.96E-04 .6,39E-05 Control Device Uncontrolled (Ib/MMBtu) (waste heat combusted) Uncontrolled (Ib/bbl) .00751 ct,, X00079 iti320ti (Crude Oil Throughput) Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory API Gravity RVP ProMax Basis 36.9 6.5 365 bpy Engineer Applicant Flash (1b/hr) Flash (113/13131) Flash (Ib/bbl) Total (Ib/bbl) Total (1b/bbl) %Dill 0.046214 1.109132 0.039934 1.149066 1.1492800 0.0186% 0.000079 0.001889 0.000068 0.001957 0.001956901 0.0187% 0.000059 0.001419 0.000051 0.001470 0.001470328 0.0190% 0.000007 0.000169 0.000006 0.000175 0.000175527 0.0195% 0.000017 0.000412 0.000015 0.000427 0.000427253 0.0192% 0.000640 0.015355 0.000553 0.015908 0.015910757 0.0188% 0.000005 0.000123 0.000004 0.000128 0.000127744 0.0211% 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) Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 1048.3 873.6 43.7 1048.3 52.4 8903 0.2 0.2 0,2 0.2 0.2 34 . 0.2 0.2 0.2 0.2 • 0.2 34 1,8 1.8 1.8 2.1 2.1 354 0.2 8.1 8.1 9.5 9.5 1613 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) 2 of K:\PA\2019\19W E0912.CP1 Crude Oil Storage Tank(s) Emissions Inventory Benzene 3570 2975 149 3570 178 Toluene 2682 2235 112 2682 134 Ethylbenzene 320 267 13 320 16 Xylene 779 650 32 779 39 n -Hexane 29026 24188 1209 29026 1451 224 TMP 233 194 10 233 t2 Section 06 - Regulator1LSummary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7, Section XVII.B, 1.1, C.3 Storage tank is subject to Regulation 7, Section XVII, 5, C.1 & CO. Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVIl.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NIPS Subpart 0000 Storage Tank is not subject to NIPS 0000 Regulation S, Part E, MACE Subpart HH Not enough information (See regulatory applicability worksheet for detailed analysis) 3 of 5 K:\PA\2019\19 W E0912.CP1 Crude Oil Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? --a 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 of crude oil drawn at theis _s facility being permitted? 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 and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08- Technical Analysis Notes heated flesh'ga gas and working Asampieof pre un_edllm (operating at 25 ps g and, TANKS 4,0 was used to 03.A review of COGCC production d The applicant had a sltglrtlydffer nt o(17j threa phase inlet vepar tors eachwt1,a1.0:MMBm/ht BUrne. After the four stage of aeparat o ti,e. hydrocal bon liquid is sang oa{2)'. eachwihtL.0MMBtu/hr Surner. Afrertho seconasrage of separafion, any rernairbngliq u Hfis are 5en 00 storage. While stored, the crudeo erstorage ve Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point A 002 Process 01 SCC Code (WeIIs57055) on 7/5/20019 at 0c0 p g and 125 o e5R. The sample was :modeled m{Et-CT blh5o02hrough hro oil polo v Max was able to model the nasn gas off this atm tack sU..if 4l `l%hrs�4,as found to be a c rservairve estimation of R0,° ha-ed on the RVn con,ersr,.n eq ua, on found n PS Me Cd ae7rhl Ctiravtty of 400,% the flash portion of the secondary (flare) emissions co ante gas and can be seen above. This was':. wh chmakes thtstanksubject totN ors which resulted is emissions being —0 02% hghe Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.01 0.01 0.05 27.4 0.25 0.05 0.04 0.00 0.01 0.38 0.00 Control % 0 0 a 95 0 95 95 95 95 95 95 Units lb/1,000 gallons crude oil throughput lb/1,000 gallons crude oil throughput lb/1,000 gallons crude oil throughput Ib/1,000 gallons crude oil throughput. lb/1,000 gallons crude oil throughput lb/1,000 gallons crude oil throughput Ib/1,000 gallons crude oil throughput lb/1,000 gallons crude oil throughput lb/1,000 gallons crude oil throughput lb/1,000 gallons crude oil throughput lb/1,000 gallons crude oil throughput 4 of 5 K:\PA\2019\19 W E0912. CP1 Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements [ree is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2TPY (Regulation 3, Part A, Section ll.D.1.al7 2. Is the construction date pdorto 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to P2 is yes, la the crude oil storage tank opacity less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 1OTPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.0.3)? I5aerte requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2e. If answer to 02Is yes, is the crude oil storage tank capacity less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 1OTPY (Regulation 3, Part B, Section 11.0.2)? lyou have indicated that source Is In the Attainment Area Colorado Regulation 7, Section XVII 1. Is this tank located eta transmission/storage fa ditty? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor stations or natural gas processing plant? 3. Is this crude oil storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? (Storage tank )s subject to Repletion 7, Section XVII, 3, 1.1 D C.3 Section XVII.B—Genera l Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVIl.C.3 - Recordkeeping Requirements 5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. IStorxga such Is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60,Subpart Ito, Standards of Performance for Volatile Organic liquid Storage Vessels 1. la the individual storage vessel capacity greater than or equal to 75 cubic meters (ma) ['472 BBLsl? 2. Does the storage vessel meet the following exemption In 60.1116(dl(4P a. Does the vessel has a design capacity less than or equal to 1,589.874 m5 [-10,000 BBL[ used for petroleum' or ondensate stored,processed, or treated prior to custody transfer' as defined in 60.111h7 3. Was this condensate storage tank constructed, reconstructed,or.-..modified(see definitions 40 CFR, 60.2) afterJuly 23, 19847 4. Does the tank meet the definition of 'storage vessel. In 60.11167'- 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.1116? 6. Does the Garage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa [29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design apadty is greater than or equal to 151 m°["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.11ob(b))?; or c. The design capacity Is greater than or equal to 75 Mn ['472 BBL] but less than 151 m5 ['950 BBL] and shares a liquid with a maximum true vapor pressures less than 15.0 kPa(60.11ob(b))? lowtaq Yes - Wain Source Req Go to next , Source Req Continue-` Continue-` Go to the n Source is G. ,,,,?Edi'ii; I5ource is sc )['a%j Go to then Stooge Tar PAWN Storage Tank is not subject to VSP5 Xb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113k -Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements 460.1166 - Monitoring of Operations 40 CFR. Part 60. Subpart 0000. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this crude oil storage vessel located eta facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 2. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 113, 2015? 3. Are potential VOC emissions' front the Individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel_' per 60.54307 '.Storage Tank is net sule[sct to NPs 0000 Subpart A, General Provisions per §60,5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures 460.5395(g) - Notification, Reporting and Recordkeeping Requirements 460.5416(c)- Cover and Closed Vent System Monitoring Requirements §60.5417 -Control Device Monitoring Requirements [Note: Ka storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 2. Is the storage tank located at an oil and natural gas production facility that meats either of the following criteria: a. A fadlity that pro asses, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A fadlity that processes, upgrades or stores natural gas priorto the point et which natural gas enters the natural gas transmission and storage source category or is delivered toe final end user' (63.760(a)(3)17 1. Is the tank located at a facility that is major' for HAW 3. Does the tank meetthe definition of"storage vessel"' in 63.761? 4, Does the tank meet the definition of "storage vsel with the potential for flash emissionsne per 63.7617 5. Is thetank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? 'Not enough Inforn,atl Subpart A, General provisions per 063.764 (e) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACr review is required If Regulation 7 does not apply AND if the tank is in the non -attainment area. if the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis d 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 orregulabbn will control. The use of non -mandatory language such as -recommend,"'may,"should," and 'can,' is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must- and'required-are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. yes Yes weigg Continue-, Storage Tar — 6.55 tf o 0O0Oa, Continue-` COLORADO Air Pollution Control Division Department of Pubtto Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE09 1 3 Date issued: XX Issued to: HighPoint Operating Corporation Issuance: 1 Facility Name: Critter Creek 16 SE Pad Plant AIRS ID: 123/A05C Physical Location: SESE Quadrant of Section 16, Township 11N, Range 63W County: Weld County General Description: Well Production Facility Equipment or activity, subject to this permit: Emissions Control Description AIRS Point Equipment Description 003 Two (2) 840 barrel fixed roof storage vessels used to store produced water Enclosed Combustors This permitis 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section 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 www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 1 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) 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: AIRS Point Tons per Year NOX VOC 003 1.1 10.3 Emission Type 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 2 is4 COLORADO Air Pollution Control Division Department of Public Health & Environment 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.) AIRS Point Control Device Pollutants Controlled 003 Enclosed combustors with 98% Manufacturer Guaranteed Control Efficiency 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,rII.A.4,) Process Limits AIRS Point Pollutants Controlled Control Device 003 Produced Water Throughput 6,000,000 barrels 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. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.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 XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; 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 Page 3 of 3 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&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 OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) 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. Page 4 of 4 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 18. 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t 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-cntena reportable pollutant: If the emissions increase by 50% or five (5) tons per year, level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, processor activity; �rhichever is less,above the Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control, equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation 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, VI.B.4). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Page 5 of 5 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit Number AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit GP02 001 RICE VOC 0 2(PSDjy 1.4 19WE0912.CP1 002 Crude Storage 52.4 19WE0913.CP1 003 Produced Water Storage 10.3 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 6 aNt., COLORADO Air Pollution Control Division Department of Public Health 8 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 James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation for produced water storage at a synthetic minor • facility in the attainment area. Page 7 of 7 COLORADO Air Pollution Control Division Department of Public Health & 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 source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # ' Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 5710 285 Toluene 108883 4127 206 Ethylbenzene 100414 402 20 Xylenes 1330207 842 42 n -Hexane 110543 4046 202 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 8 COLORADO Air Pollution Control Division Department of Public Health & 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/bbl Controlled Emission Factors lb/bbl Source -- NOx 3.64 x 10"4 3.64 x 10"4 AP -42 Chapter 13.5 Industrial Flares -- CO 1.66 x 10-3 1.66 x 10-3 -- VOC 6.87 x 10-2 3.44 x 10-3 Flash Liberation Analysis 71432 Benzene 9.52 x 10-4 4.76 x 10-5 108883 Toluene 6.88 x 10-4 3.44 x 10-5 100414 Ethylbenzene 6.70 x 10"5 3.35 x 10"6 1330207 Xylene 1.40 x 104 7.01 x 10"6 110543 n -Hexane 6.74 x 10"4 3.37 x 10"5 Note: The uncontrolled emissions factors for this point are based on a pressurized water sample taken at the Critter Creek 16SE facility (Well 5708B) on 7/9/2019 at 152 psig and 131 deg F. Flash emissions were estimated by flashing the pressured water to 12.2 psia and 60 deg F. The controlled emissions factors are based on a control efficiency of 95% 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN 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. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD 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 Page 9 of 9 COLORADO Air Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: A0SC Facility Name: Critter'di 11Ppir>YOperating Corpora Location: SESE Quadrant of Section 16, Township 11N, Range 63W County: Weld County Type of Facility: Exploration & Prod What industry segment? iQil,$pNa40#Oas Pror! Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Section 02 - Emissions Units In Permit Application Carbon Monoxide (CO) Quadrant Section Township Range SESE 16 11N 3 Particulate Matter (PM) ❑ Ozone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit t Issuance # Self Cert Required? Action Engineering Remarks rl, eQilTbrsk ?9WE09!2 Y 1-��t 003 produced Water Tank I;, es 191VE09?0faalb iiiitilel Section 03 - Description of Project T'he Critter Creek 16 SE Pad is a new facility operated by HighPoint Operating Corporation (HighPoinr). This facility processes the liquid from (17) wells orsite. After Separation; crude and praducedd`''. = water is stored in tanks on location. In this application, Highfoint has' requested to permit the emissions associated with storing crude and produced wateriAny gas not used to rue! the onsite - combustors and heaters is routed to -a sates The. Crude is measured through a ' ACT and sold in a sales line. This facilityalse includes a cornpressor with its engine permitted under a6P0B(Poirnt 007., Approval Letter Sent October 9, 2.019; Package. 400447). Section 04.- Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? 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: 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, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) G SO2 NOx CO VOC PM2.5 PM10 TSP HAPs El SO2 NOx CO VOC PM2.5 PM10 TSP HAPs CI Produced Water Storage Tank(s) Emissions Inventory 003 Produced Water Tank 'Facility AIRS ID: County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potentidl to Emit (PTE) Throughput = Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= B6 Btu/scf Waste gas/bbl of liquids produced = 5 * scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = PTE heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Actual Produced Water Throughput While Emissions Controls Operating = Requested Monthly Throughput= 509509 Barrels (bbl) per month <-- From Flash Liberation Analysis <-- From Flash Liberation Analysis 26,753 MMBTU per year 32,104 MMBTU per year 32,104 MMBTU per year Emission Factors Produced Water Tank Pollutant VOC Benzene Toluene Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Produced (Produced Water Water Throughput) Throughput) 9.52E-04 4.76E- Ethylbenzene 6.10E -OS:. Xylene n -Hexane 224 TMP Pollutant Section 05 - Emissions Inventory 1406-04 7.8 0 O6'E+00:1: 0. Control Device Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) Emission Factor Source 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) VOC PM10 PM2.5 NOx CO 206.2 171.8 8.6 206.2 10.3 1751 0.1 0.1 0.1 0,1 0.1 20 0.1 0.1 0,1 0.1 0,1 20 1.1 0.0 0,9 1.1 1.1 185 5.0 4.1 4.1 5.0 5,0 845 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 5710 4758 238 5710 2&s. 4127 '3440 172 4127 206 402 335 17 402 20 842 701 35 842 42 4046 3372 169 4046 202 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is sub)ect to Regulation 7, Section KV31, B, C,i & C.3 Regulation 7, Section XVII.C.2 Storage took is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NIPS Subpart 0000 Storage Tank is not subject to tlOPS 0000 (See regulatory applicability worksheet for detailed analysis) ORM? 2 of 5 K:\PA\2019\19WE0913.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements 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 water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe 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. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08- Technical Analysis Notes Seventeen (17) onsite wells, send rquid o (17) nree phase inlet separators each with a 10 MM lituJhr Burner Any produced water that s removed atthis stage: is sent to storage. W{ i =' stored, producedwsb' Wi)r(.ehntflas1' 50)o•hit and breathing losses are assumed to he negligible. (0 yzo hW&B calculation resulted n — 20 lbsiof addition uncontrolled VOC/year) Asampfeotpressurized materwas taken azthe CntterCreok 165E facility (Well 55/08B) on 7/9/20019 at 152 psig and 131degF ihosam plei was flashed from 152Ppsig// Z31 deg F to the storageta conditions which -were anticipated to be 12r 2 psia acrd 60 deg F Sfandard conditions were assumed to be 14,65 psi and 60 deg I. The flash liberationdinsulted in 52 sef/bbl of flashed gas.eince ., WRwas reported maser, ti was assumed that a conversion alre dy ok peace _o standard conditions A Flashed as E .ended Analysis was providd i aQ c. •-• yttach was used to dereelop em s -ton factors isen nexttab) using the EPA Emission Inventory Improvement Program Publication: Volume It Chapter 1.0- Displacement Equation (15.4' 3'�, o,�„a. VOC emu s ions are. calculated to be 1,15 tpy per storage es0er. his tank not subject to the tank portion of 0OOOe Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point# 003 Process# SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.01. 1.0 0.04 0.02 0.02 0.00 0.00 0.02 0.00 Control % Units O lb/1,000 gallons liquid throughput O lb/1,000 gallons liquid throughput O lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 0 lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 95lb/1,000 gallons liquid throughput 95 lb/1,000 gallons liquid throughput 3 of 5 K:\PA\2019\19 W E0913.CP1 EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10- Displacement Equation (10.4-3) Ex= a*MW*Xx/C Ex = emissions of pollutant x 0.= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx= mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm IMW 26.8009 Ib/Ib-mol bbl/year scf/bbl Throughput '1 Gas -to -Oil Ratio (GOR) 5.16 mass fraction (/) Emission Factor (Ib/bbl) Emissions (lbs/year) Helium 0.00000 0.00000000 0.00 CO2 2;..70430 0.1082'1965 0.11 N2 527940 0.02287731 0.02 H25 0.00000 0.00000000 0.00 methane 33.24240 0.12111159 0.12 ethane 71:9084'0 0.04338506. 0.04 propane 10.65063 0.03890260 0.04 isobutane 0.84280 0.00307052 0.00 n -butane 362820 0.01321837 _ 0.01 isopentane - 0.60070 0.00219849 0.00 n -pentane 0:78230 0.00285010 0.00 cyclopentane 0.26440 0.00096327 0.00 n -Hexane 3 0.185]0 0.00067436 0.00 cyclohexane 0.16460 0.00059968 0.00 Other hexanes 0,51910 0.00189120 0.00 heptanes 0:18640 0.00067910 0.00 methylcyclohexane 012880 0.00046925 0.00 224-TMP 0.00000 0.00000000 0.00 Benzene 0.26120 0.00095161 0.00 Toluene 0.18880 0,00068784 0.00 Ethylbenzene 0:01840 0.00006704 0.00 Xylenes 0103850 0.00014026 0.00 C8 0.15230 0.€30055486 0.00 C9 ..x.0.04170 0.00015192 0.00 C10 ., :0 0.018076945 0 0.0 Total VOC Wt % 100.4tl014, �i '. ,..ai� r r� rA 18.8 0.0687:3 0.00003 n -Hexane 224-TMP Benzene Toluene Ethylbenzene Xylenes Total GOR Conversion Check Actual Pressure (Pi) -t. psia Actual Temperature (T5) ' / 11L Rankine Actual GOR (V5)z"yam. eYe1` cf/bbl Standard Pressure (P2) �1 psia Standard Temperature (1-2) y - Rankine Standard GOR (V7) 1 scf/bbl Pollutant lb/bbl VOC 0.0687299 Benzene 0.0009516 Toluene , 0.0006878 Ethylbenzene 0.0000670 Xylenes 0.0001403 n -Hexane 0.0006744 224-TMP 0.0000000 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be appl€cable far certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B -APEN and Permit Requirements 'Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from anycriteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.O.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation3, Part B, Section ll.D.1.M( 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, Nag greater than 10TPY or CO emissions greater than 10 TPY (Regulation 3, Part 0, Section ll.D.3)? 'Source requires a Permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section 11.0.1.')? 2. Is the operator claiming less than l% crude oil and is the tank located ate non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section 11.02)? 'You hake indicated that source is in she. Attainment Area Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production fedllty', natural gas compressor station' or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? 'Storage took is subject to Regulation i, Section 5531, 5, C.1 A C.3 Section XVII.B—General Provisions for Alr Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XV II.C.3 - Recordkeeping Requirements 5. Does the produied water storage tank contain only "stahillead" liquids? If no, the following additional provisions apply. 'Storage took is sukiect so .Regulation 7, Section Xtfl€.C.2 Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart 0000, standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located ate facility In the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60,2) between August 23, 2011 and September 1g, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? 'Storage Tank is not avblecc to NSPS OCIOO Subpart. A, General Provisions per §50.5425 Table 3 §50.5390- Emissions Control Standards for VOC §60.5413 -Testing and Procedures §60.5395(gl - Notification, Reporting and Recordkeeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 Control Device Monitoring Requirements [Note: If a storage vessel Is previously determined to he subject to N5P5 0000 due to emissions above 6 tans per year VOC on the applicability determination date, Is should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] RAC' Review .ACT review Is required If Regulation 7 does not apply AND d the tank b In the non -attainment area. If the tank meets bath criteria, then review .ACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Qualify Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as"recommend,"'may," "should," and "can," Is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes Yes Yes Continue-' Storage Tar Storage Tar WWI Source Req Go to next, Source Req Continue-' Continue-' Goto then Source is su — 5.15 tf subject to Crude Oil Storage Tank(s) APEN Form APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit RECEIVED SEPU47.9 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 APCD filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will requir�Ep payment for a new filing fee. This APEN is to be used for tanks that store crude oil 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. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. 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: Ic I1 Qq(2 AIRS ID Number: 123 / A05C / Dr0 2 — [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Critter Creek 16 SE Pad Site Location: Sec. 16, T11 N, R63W Mailing Address: (Include Zip Code) 555 17th Street, Ste. 3700 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 1 I 4150633 COLORADO Dew:memol Public Permit Number: AIRS ID Number: 123 / A05C / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under General Permit 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 name3 O Change permit limit O Transfer of ownership4 O 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 & Notes: Individual permit for (8) 840 bbl crude oil storage tanks. 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: Eight (8) 840 bbl crude oil storage tanks Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 6/4/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year ❑✓ Exploration Et Production (E&P) site ❑ Midstream or Downstream (non EftP) site Will this equipment be operated in any NAAQS nonattainment area? ■ Yes MI No Are Flash Emissions anticipated from these storage tanks? ig Yes ■ No 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 ■ Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 AVICOLORADO 2 I vveeneol is Permit Number: AIRS ID Number: 123 / AO5C / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) I Crude Oil Throughput: 1,520,225 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 36.9 degrees 0 Internal floating roof Tank design: ❑� Fixed roof 1,824,270 RVP of sales oil: 6.5 ❑ 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) Crude Tks 8 6,720 5/2019 6/2019 Wells Serviced by this Storage Tank or. Tank Battery6 (E&P Sites Only) API Number Name of Well Newly Reported Well - - See well list addendum ■ - ■ - ■ - - ■ _ ■ 5 Requested values will become permit limitations. Requested Limit(s) should consider future growth. 6 The EEP 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 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.91629/-104.4431988 Operator Stack ID No. > Discharge Height Above Ground Level (feet) ,Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD —20 N/A N/A N/A Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Downward 0 Horizontal 0 Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 48 and 84 ❑ Square/rectangle Interior stack width (inches): 0 Other (describe): Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 COLORADO 3 I AV ,:dam ISv?tU� 6 gnat enmttl Permit Number: AIRS ID Number: 123 / A05C / [Leave blank unless APCD has already assigned a permit # 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: VOC, HAPs Rating: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: N/A MMBtu/hr Make/Model: (1) 48" Leed, (5) 48" Cimarton & (4) 84" Cimarton Big Hurt 95 98 Waste Gas Heat Content: 2,482 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 0.73 MMBtu/hr O Closed Loop System Description of the closed loop system: 0 Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —25 psig Describe the separation process between the well and the storage tanks: The well fluids initially flow through the heated 3 -phase inlet separators, are then routed to the heated flash gas separators (oil polishers), and finally to the crude oil storage tanks. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 4 COLORADO et v-wnc H.Oh o-sn.tm, rn! Permit Number: AIRS ID Number: 123 I AO5C f [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor? Actual Annual Emissions Requested Annual Permit 5 Emission Limit(s) Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled : Emissions 8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 1.15 lb/bbl Eng. Est. 873.58 43.68 1,048.30 52A2 NOx 0.068 Ib/MMBtu AP -42 1.77 2.09 CO 0.31 Ib/MMBtu AP -42 8.09 9.51 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg.,etc.) Uncontrolled Emissions (pounds/year) Controlled 8 Emissions (pounds/year) Benzene 71432 1-'1%0E-01 lb/bbl Eng. Est. 2,975 149 Toluene 108883 1.47E-03 lb/bbl Eng. Est. 2,235 112 Ethylbenzene 100414 1.76E-04 lb/bbl Eng. Est. 267 13 Xylene 1330207 4.27E-04 lb/bbl Eng. Est. 650 32 n -Hexane 110543 1.59E-02 lb/bbl Eng. Est. 24,188 1,209 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach crude oil 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 emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 3/2019 COLORADO 5 I �- K: `.",Q,4U Permit Number: AIRS ID Number: 123 I A05C / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP08. J tiA 'ALA - Signature of Legally Authorized�l�erson (not a vendor or consultant) Date Marsha Sonderfan Senior EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: 11 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 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www.colorado. Roy /cdphe/apcd Form APCD-210 - Crude Oil Storage Tanks) APEN - Revision 3/2019 'COLORADO 6 I AV�°wa°E He?uh 6 _ nalronmem E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: HighPoint Operating Corporation Source Name: Critter Creek 16 SE Pad Emissions Source AIRS ID2: 123-A05C Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-47305 Critter Creek 16-5708B ■ 05-123-47306 Critter Creek 16-6005BE IN 05-123-47760 Critter Creek 17-5906B ■ 05-123-47308 Critter Creek 16-5807BW ■ 05-123-47310 Critter Creek 16-5906B ■ 05-123-47763 Critter Creek 17-5807B ■ 05-123-47759 Critter Creek 17-5807D ■ 05-123-47758 Critter Creek 17-5708B I 05-123-47312 Critter Creek 16-5708D ■ 05-123-47311 Critter Creek 16-5807BE IN 05-123-47298 Critter Creek 16-6104B ■ 05-123-47293 Critter Creek 16-6401B ■ 05-123-47296 Critter Creek 16-6401D ■ 05-123-47295 Critter Creek 16-6302BE ■ 05-123-47307 Critter Creek 16-5906D ■ 05-123-47762 Critter Creek 17-6005B ■ 05-123-47761 Critter Creek 17-6005D ■ O Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter NA Form APCD-212 \\\k\`°\ Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 12/2/2019 State.co.us Executive Branch Mail - APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C Peter Knell <pknell@spiritenv.com> To: "james.ricci@state.co.us" <james.ricci@state.co.us> Cc: Marsha Sonderfan <msonderfan@hpres.com> Hi James, Thu, Nov 7, 2019 at 9:55 AM Please find the attached Promax Report and updated well list addendum form. Don't hesitate to let me know if you have any questions or concerns. Thanks, Peter Knell Senior Project Manager pknell@spiritenv.com mobile: (303) 506-6417 SPIRIT ENV{RONMENtAI From: Marsha Sonderfan <msonderfan@hpres.com> Sent: Wednesday, November 06, 2019 12:38 PM To: Ricci - CDPHE, James <james.ricci@state.co.us>; CDPHE_Corr <CDPHE_Corr@hpres.com> Cc: Peter Knell <pknell@spiritenv.com> Subject: RE: APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C Hi James, I have reviewed your questions and have a few responses. I have cc'd Peter Knell with Sprit Environmental who will provide the updated data where necessary. I'm happy to answer any further questions you may have. Thanks, Marsha From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, October 31, 2019 8:07 AM https://mail.google.com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1649562870185807325&dsqt=1 &simpl=msg-f%3A1649... 1/2 12/2/2019 State.co.us Executive Branch Mail - APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C To: CDPHE_Corr <CDPHE_Corr@hpres.com> Subject: APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C Good Morning, I have a couple questions for the Critter Creek 16 SE Pad, AIRS ID 123-A05C. The application included permitting for produced water storage and crude storage. • There are some repeats on the Well List addendum (CC 16-5708 is listed twice). Also, well (API 123-47307) is showing up as a "D" well on the COGCC website but a "B" on the addendum (this may be an error on their part!). I didn't check them all but please send me a new addendum if any changes are needed. I apologize for these issues. Some well names got truncated when I sent them over to Spirit. We've chased down the correct list and Peter will send it. • For crude storage, I calculated the benzene emission factor to be 1.96 e-3. I think this may just be a typo, I can redline the APEN with your permission. Yes, this is a typo and you may redline the APEN. The calculation sheet is showing the correct factor. • Were any other wells sampled besides the one provided? o Have you seen a difference in samples from Codeil wells vs Niobrara wells in terms of emission estimations? o Does the sampling company choose a random well to sample or are they directed which to sample? We've sampled several wells in the area all with similar results. We do not see any difference between Niobrara and Codeil wells in terms of physical properties (e.g., API gravities, pour points) that may affect emission estimates. Further the wells are all commingled in a common oil polisher (heated separator) for the second stage of separation. In terms of which well is sampled, we generally try to sample the well that first cut oil out of the new producers, but it is really up to the lab to pick which separator (and therefore well) is sampled, so to that end it is perhaps somewhat random. • Do you have a sales oil analysis? Was RVP converted from API gray or was it measured? I've attached the full file of the oil pressurized liquid DHA analysis, which includes the results of a storage tank sales oil sample on page 5 of the pdf. • Can you please email me the full ProMax report with all inputs and all the streams? Peter will provide this. • 6,000,000 bbls of produced water is quite a bit. Does produced water loadout or W&B losses become significant at this volume? o The regulatory analysis noted that PW loadout was exempt but was curious if you had a copy of the calculations that you can share. We can run EPA Tanks for W&B best guess, but from several times doing this in the past, we expect potential emissions less than 250 lb/yr VOC, which is what we have been told by permit engineers to consider insignificant. Regarding truck loadout of the water, I quite frankly don't even know how to estimate those emissions. Any oil potentially remaining in emulsion when the produced water reaches the tanks would likely be gravimetrically separated in the tank, and the loadout process pulls the water from the bottom (i.e., water layer) of the tank. The water estimate was high to cover the initial peak water recovery from frac, but current actual water production rates are already below 1/3 of peak. Current water production rates is about 6,000 bbl/day for the entire battery (i.e., all 17 wells combined), which times 365 days is only 2,190,000 bbl potential in the next year, and will decline. Thanks, James Ricci Permit Engineer CDPHE COLORADO Department of Public Health & Environment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd 2 attachments Critter Creek 16 SE Pad_Promax Report_20191107.pdf 82K Aft. B - Critter Creek 16 SE - Well List Addendum 20191107.pdf 21K https://mail.google.com/mail/u/0?!k=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1649562870185807325&dsgt=l &simpl=msg-f%3A1649... 2/2 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.eov/pacific/cdphe/air-permits. 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. RECEIVED SEP 0 4 2019 Permit Number: /?WE R 13 APCD [EP AIRS ID Number: 123 / AO5C / O 63 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Critter Creek 16 SE Pad Site Location: Sec. 16, T11 N, R63W Mailing Address: (Include Zip Code) 555 17th Street, Ste. 3700 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.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-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 415064 1 I AY COLORADO Department d Pebflc Fig.% 5MlmnmeRl Permit Number: AIRS ID Number: 123 /A05C [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 O 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) O Change in equipment ❑ Change company name3 ❑ Change permit limit O Transfer of ownership' O 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 It 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: Two (2) 840 bbl produced water storage tanks Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 6/4/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑✓ Exploration Et Production (E&P) site O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? • Yes a No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes O No Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ✓ Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No ✓ ■ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 2 1 0v Dayucnient COLORADO o Pestic ,fua{Q,F'•EfyiRMnto Permit Number: AIRS ID Number: 123 / A05C / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 5,000,000 Requested Annual Permit Limits (bbl/year) 6,000,000 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof 2019 ❑ Internal floating roof O 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) PW TKs 2 1,680 5/2019 6/2019 Wells Serviced by this Storage Tank or Tank Battery6 (EftP Sites Only) API Number Name of Well Newly Reported Well See Well List Addendum O O O 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.91629/-104.4431988 Operator Stack ID No. Discharge Height Above Ground Level (feet) - Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) ECD -20 N/A N/A N/A Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ID Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 48 & 84 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 3 I Permit Number: AIRS ID Number: 123 / A05C / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O 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: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % 0 Combustion Device: Pollutants Controlled: VOC, HAPs Rating: TBD Type: ECD MMBtu/hr (1) 48" Leed, (5) 48" Cimarron and (4) 84" Cimarron Big Hurt Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A % Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 1,037 0.73 Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —152 psig psig Describe the separation process between the well and the storage tanks: The commingled liquids from the wells flow to the heated inlet separators and produced water then flows to the produced water storage tanks. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 4 I COLORADO DcpWnent ofPub. N. Ith 6Fintr4rksma! Permit Number: AIRS ID Number: 123 / A05C / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the ntrol efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control,, Efficiency (% reduction in emissions) VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit s Emission Limit(s) Uncontrolled Basis Units Source (AP -42, M fg•, etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.07 lb/bbl Eng. Est. 171.83 8.59 206.19 10.31 NOx 0.068 Ib/MMBtu AP -42 0.91 1.09 CO 0.31 Ib/MMBtu AP -42 4.14 4.97 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract. Servce (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP 42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 8 (pounds/year) Benzene 71432 9.52E-04 . lb/bbl Eng. Est. 4,758 . 238 Toluene 108883 6.88E-04 e lb/bbl Eng. Est. 3,440 ' 172 1 Ethylbenzene 100414 6.70E-05 ' lb/bbl Eng. Est. 335 f 17 ,/ Xylene 1330207 1.40E-04 -' lb/bbl Eng. Est. 701 / 35 n -Hexane 110543 6.74E-04 lb/bbl Eng. Est. 3,372 J 169 i 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLOP. ADO 5 I Permit Number: AIRS ID Number: 123 / A05C [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Moubk?uL467,,Juitkcit -A-1,4- 19 Signature of Legally Authorized Pidrson (not a vendor or consultant) Date Marsha Sonderfan Senior EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: ✓0 Draft permit prior to issuance 0 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 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www.colorado. gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 6I AVp COLORADO I m , E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: HighPoint Operating Corporation Source Name: Critter Creek 16 SE Pad Emissions Source AIRS ID2: 123-A05C Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-47305 Critter Creek 16-5708B ■ 05-123-47306 Critter Creek 16-6005BE ■ 05-123-47760 Critter Creek 17-5906B ■ 05-123-47308 Critter Creek 16-5807BW ■ 05-123-47310 Critter Creek 16-5906B ■ 05-123-47763 Critter Creek 17-5807B ■ 05-123-47759 Critter Creek 17-5807D ■ 05-123-47758 Critter Creek 17-5708B ■ 05-123-47312 Critter Creek 16-5708D ■ 05-123-47311 Critter Creek 16-5807BE ■ 05-123-47298 Critter Creek 16-6104B I 05-123-47293 Critter Creek 16-6401B ■ 05-123-47296 Critter Creek 16-6401D U 05-123-47295 Critter Creek 16-6302BE I 05-123-47307 Critter Creek 16-5906D ■ 05-123-47762 Critter Creek 17-6005B ■ 05-123-47761 Critter Creek 17-6005D ■ D D D Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter NA \\\-AV*\ J Q�Q‘ -` 4\4 - Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 12/2/2019 State.co.us Executive Branch Mail - APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C Peter Knell <pknell@spiritenv.com> To: "james.ricci@state.co.us" <james.ricci@state.co.us> Cc: Marsha Sonderfan <msonderfan@hpres.com> Hi James, Thu, Nov 7, 2019 at 9:55 AM Please find the attached Promax Report and updated well list addendum form. Don't hesitate to let me know if you have any questions or concerns. Thanks, Peter Knell Senior Project Manager pknell@spiritenv.com mobile: (303) 506-6417 SPIRIT ENVJRONM EN AL From: Marsha Sonderfan <msonderfan@hpres.com> Sent: Wednesday, November 06, 2019 12:38 PM To: Ricci - CDPHE, James <james.ricci@state.co.us>; CDPHE_Corr <CDPHE_Corr@hpres.com> Cc: Peter Knell <pknell@spiritenv.com> Subject: RE: APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C Hi James, I have reviewed your questions and have a few responses. I have cc'd Peter Knell with Sprit Environmental who will provide the updated data where necessary. I'm happy to answer any further questions you may have. Thanks, Marsha From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Thursday, October 31, 2019 8:07 AM https://mail.google.com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1649562870185807325&dsgt=1 &simpl=msg-f%3A1649... 1/2 12/2/2019 State.co.us Executive Branch Mail - APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C To: CDPHE_Corr <CDPHE_Corr@hpres.com> Subject: APEN Review: Critter Creek 16 SE Pad, AIRS ID 123-A05C Good Morning, I have a couple questions for the Critter Creek 16 SE Pad, AIRS ID 123-A05C. The application included permitting for produced water storage and crude storage. There are some repeats on the Well List addendum (CC 16-5708 is listed twice). Also, well (API 123-47307) is showing up as a "D" well on the COGCC website but a "B" on the addendum (this may be an error on their part!). I didn't check them all but please send me a new addendum if any changes are needed. I apologize for these issues. Some well names got truncated when I sent them over to Spirit. We've chased down the correct list and Peter will send it. For crude storage, I calculated the benzene emission factor to be 1.96 e-3. I think this may just be a typo, I can redline the APEN with your permission. Yes, this is a typo and you may redline the APEN. The calculation sheet is showing the correct factor. Were any other wells sampled besides the one provided? o Have you seen a difference in samples from Codell wells vs Niobrara wells in terms of emission estimations? o Does the sampling company choose a random well to sample or are they directed which to sample? We've sampled several wells in the area all with similar results. We do not see any difference between Niobrara and Codell wells in terms of physical properties (e.g., API gravities, pour points) that may affect emission estimates. Further the wells are all commingled in a common oil polisher (heated separator) for the second stage of separation. In terms of which well is sampled, we generally try to sample the well that first cut oil out of the new producers, but it is really up to the lab to pick which separator (and therefore well) is sampled, so to that end it is perhaps somewhat random. • Do you have a sales oil analysis? Was RVP converted from API gray or was it measured? I've attached the full file of the oil pressurized liquid DHA analysis, which includes the results of a storage tank sales oil sample on page 5 of the pdf. • Can you please email me the full ProMax report with all inputs and all the streams? Peter will provide this. • 6,000,000 bbls of produced water is quite a bit. Does produced water loadout or W&B losses become significant at this volume? o The regulatory analysis noted that PW loadout was exempt but was curious if you had a copy of the calculations that you can share. We can run EPA Tanks for W&B best guess, but from several times doing this in the past, we expect potential emissions less than 250 lb/yr VOC, which is what we have been told by permit engineers to consider insignificant. Regarding truck loadout of the water, I quite frankly don't even know how to estimate those emissions. Any oil potentially remaining in emulsion when the produced water reaches the tanks would likely be gravimetrically separated in the tank, and the loadout process pulls the water from the bottom (i.e., water layer) of the tank. The water estimate was high to cover the initial peak water recovery from frac, but current actual water production rates are already below 1/3 of peak. Current water production rates is about 6,000 bbl/day for the entire battery (i.e., all 17 wells combined), which times 365 days is only 2,190,000 bbl potential in the next year, and will decline. Thanks, James Ricci Permit Engineer COPHE COLORADO Department of Public Health Et Environment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd 2 attachments Critter Creek 16 SE Pad_Promax Report_20191107.pdf 82K .n Aft. B - Critter Creek 16 SE -Well List Addendum 20191107.pdf 21K https://mail.google.com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1649562870185807325&dsgt=1 &simpl=msg-f%3A1649... 2/2 Hello