HomeMy WebLinkAbout20201148.tiffCOLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
March 12, 2020
Dear Sir or Madam:
RECEIVED
MAR 18 2020
WELD COUNTY
COMMISSIONERS
On March 13, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Crestone Peak Resources Operating, LLC - Rodman Bruntz 26H. 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 8 Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor Jill Hunsaker Ryan, MPH, Executive Director
Pvbl : C Rev:ec.J cc: PLCrP), (-II..(1-K),RATIA! R/GN/ciC),
000Jn)
4/aol2a
4/2.7/10
2020-1148
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Crestone Peak Resources Operating, LLC - Rodman Bruntz 26H - Weld County
Notice Period Begins: March 13, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Crestone Peak Resources Operating, LLC
Facility: Rodman Bruntz 26H
Exploration it Production Well Pad
SWNW S26 T2N R66W
Weld County
The proposed project or activity is as follows: This facility is requesting a new emission point to vent buffer
(separator) gas to an enclosed combustion device. In addition to this permit, the source has updated site
specific emission factors for their condensate tanks permitted under the GP01 and has removed the control
device from the produced water tanks permitted under the GP05. This facility is synthetic minor for VOC
and n -hexane in the nonattainment area.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE1030 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:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
(COLORADO
Department of Public
Health 6 Environment
COLORADO
Air Pollution Control Division
Department of Public Health E, Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE1030 Issuance: 1
Date issued:
Issued to:
Crestone Peak Resources Operating, LLC
Facility Name: Rodman Bruntz 26H
Plant AIRS ID: 123/9D3B
Physical Location: SWNW Section 26 T2N R66W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point '
Equipment Description '
Emissions Control
Description
Buffer
06
Low Pressure Buffer Separator
Enclosed Combustion
Device
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act'(C.R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (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 containedin this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation', of this source.
EMISSION LIMITATIONS, AND RECORDS
6. Emissions of air pollutants must not exceed the fol
Part B, Section II.A.4.)
Annual Limi
owing limitations. (Regulation Number 3,
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
Buffer
006
---
---
15.8
2.9
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Buffer
006
Emissions from the low pressure buffer
separator are routed to an enclosed
combustion device during Vapor Recovery
Unit (VRU) downtime
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request.' (Regulation Number 3, Part B,
11.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Buffer
006
Natural Gas Venting
7.82 MMSCF
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the separator(s) using the flow meter. The flow meter must be
calibrated and maintained per the manufacturer's specifications and schedule. The owner or
operator must use monthly throughput records to demonstrate compliance with the process
limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases
must allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
OPERATING £t MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the 0£tM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing'Requirements
15. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 9, 40 C; F. R. Part 60, Appendix A, to measure opacity from the, flare for one
'continuous hour. (Regulation. Number 1, Section II.A.5)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. 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
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
18. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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.
21. 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,
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
22. 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.
23. 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.
24. 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.
25. 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:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Crestone Peak Resources Operating, LLC.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II. E.1 of the
Common Provisions Regulation. See:'https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)''
Buffer
006
Benzene
71432
2,554
128
Toluene
108883
2,339
117
Ethylbenzene
100414
123
6
Xylenes
1330207
757
38
n -Hexane
110543
20,510
1,025
2,2,4-
Trimethylpentane
540841
10
1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMscf)
Controlled
Emission
Factors
(lb/MMscf)
Source
NOx
162.2
162.2
AP -42,
Chapter 13.5
CO
739.6
739.6
VOC
80,535
4,026.75
Site -Specific
Extended Gas
Analysis Sample
Taken 5/15/2018
71432
Benzene
326
16.3
108883
Toluene
299
14.95
100414
Ethylbenzene
15.74
0.787
1330207
Xylene '
96.76
4.838
110543
; n -Hexane
2,621
131.1
Note: The controlled emissions factors for this point 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 facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC and n -hexane
PSD
True Minor Source of: CO
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
Page 8 of 9
4t4
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Lauraieigh Lekocy
Package#: -+21630
Received Date: 11/112019
Review Start Date: 12/12✓2'29
Section 01-Facility Information
Company Name: Creston Peak Resources Operating,LLC. Quadrant Section Township Range
County AIRS ID: 123.- 5WNW 26 2N 66
Plant AIRS ID: 9.0038-.,.
Facility Name: Rodman'Bruntz'.26H
Physical
Address/Location: :2°,99n9 essedsses
County: Weld County
Type of Facility: £xetdson&Production Well Pad
What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOzk.VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRs Point# Permit#
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit initial
006 Separator Venting Buffer Yes 191991030 1 Yes Issuance
A
Section 03-Description of Project
This source is requesting a new emission point,to vent natural gas,from a separator controlled by an enclosed combustor.Additionally,the source requested
updated site-specific emission;actors for their GP01 and the removal of the control device controlling their produced water tanks(GP05).This source has not yet
been started up.
This source is a synthetic minor source for VOC and n-hexane
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? ?'es
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? .Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) —
Title V Operating Permits(OP) _ d ❑ ❑✓
Non-Attainment New Source Review(NANSR)
Is this stationary source a major source?
If yes,indicate programs and which pollutants: 502 NOx v CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(P5D)
Title V Operating Permits(OP)
Non-Attainment New Source Review(NANSR)
Section 01-Administrative Information
Facility AlRs ID:
County Plant Point
Section 02-Equipment Description Details
lc,Separator Gas Venting&trios Vail downtime
Detailed Emissions Unit Description: @ ,
61FC)esed tnyit'bti₹atips4 E8nnku
Emission Control Device Description:
Requested Overall VOC&HAP Control Efficiency% 0$
Limited Process Parameter i :itria
Gas meter ` ";,'' .
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput=• - 11.11 MMscf per year
IRequested Permit Limit Throughput= MMscf per year Requested MonthlyThroughput= MMscf per month
Potential to Emit(PTE)Throughput= b MMscf per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: 235$_P Btu/scf
Volume of waste gas emitted per BBL of.. e" i
liquids throughput: iii,PFRPREsd/bbl
Control Device
Pilot Fuel Use Rate: 2S scfh d.%MMscf/yr
Pilot Fuel Gas Heating Value: 18611 Btu/scf
Section 04-Emissions Factors&Methodologies
Description
Site speceflct.#Sufferfaas sample taken&/1S/2614 Igo wells et the foci&iiphave been added Wssrs41 luhstethatdatepyrMGM tlaM ..
MW t 42.4 Ib/Ib-mol Displacement Equation
Ex=Q*MW a Xx/C
Wei ht%
Oxygen/Argon
CO2 ",.,,7
N2 G.?
methane
ethane 15.0.
.ropane - 24,7
isobutane 4.S
n-butane 17.5
iso.entane
n-pentane 7,3
cyclopentane 03..
n-Hexane - 2,4
cyclohexane 0.6'
Other hexanes
he.tanes 1,7
methylcyclohexane ,5
224-TMP
Benzene
Toluene
Ethylbenzene n
X lenes 0,3
C8+Heavies
Total
VOC Wt
2 of 7 K:\PA\2019\19W E1030.CP1
Separator Verting Em ss(ons Inventory
Emission Factors Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (lb/MMscf) (lb/MMscf)
(Gas Throughput) (Gas Throughput)
VOC R bf s-ohofyss'''
Benzene - .Ex€ende§_gagafaVyks `
Toluene , xtE€de?" tpyYy s3
Ethylbenzene ;'t§te— sanafyr ts
Xylene _ t ..!r4s3 0oo)'uis, ,
n-Hexane . ___ -.. 7fxta d gaA'Ana#ystx'_
224 TMP
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.0075 AP-42'Toht , .i fa11UfPNj-2.6(
PM2.5 0.0070 Ar-42 Taste 1..47a't+PGz510/W4.rsj
SOx 0.0000. `Alf 42�142Otax)
NOx 0.0680 AP-��t€,r4-$ lSootr545Hares(Noxl
Co 0.3100 ,,BP-14 Chaptec.41s*1fradt:sfylatfidres;(CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10 0.0075 ' AP•42Tdh(s`-14 5M1t1/PM.2..5)
PM2.5 0.0075 A554lt'ab(4 t ( .t0JPlULLS)
Sox 0.0000- AP-4.y€o'ldn 0.75)SOX)
NOx 0.0680 OP-42 Cs yter110 Md*UUodak Flares(Nox)
CO 0.3100 - AP-42tapter 1151titatbtares:(CO)
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 ._
PM2.5 _ .. . . , ..
SOx ....
NOx . ,. ...
VOC _,__ .- _ _
CO ._ ...
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) )Ihs/year) (lbs/year) (lbs/year)
Benzene __ ;___
Toluene .. ..
Ethylbenzene .-. _
Xylene -- ..
n-Hexane . . ..
224 IMP
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B
Regulation 7,Section XVII.B,G
Regulation 7,Section XVII.8.2.e
(See regulatory applicability worksheet for detailed analysis)
3 of 7 K:\PA\2019\19W E1030.CP1
Separator Vent)fig E a a ,_, y
Section 07-Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Doesthe company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID,and should have been collected within one year of the application received date.However,if the facility has
not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample.
If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate
that the emission factors are less than or equal to the emissions factors established with this application.
Are facility-wide permitted emissions of V0C greater than or equal to 45 tons per year? :.-;riatitWegV
If yes,the permit will contain:
-An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application.
-A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Yes
If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180
days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03.
Doesthe company request a control device efficiency greater than 95%for a flare or combustion device? -#
If yes,the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
f Y ( � l
. � � alt ti j
a #ri�a�^r''�� -.✓,;SE�, �✓�,avA 6.���2:�m_n _.. ..,o.� ..,,:.. .. .;i".:x .. .. a` � „ - r, i�ir� ..,�3_., �.. ... "/
5ection 08-Technical Analysis Notes
Per C0GCC,none of the wells at tnis,nci-;y rum.been re,fractured or completed since before.2014;upon discussion with the source,it was determiced that they were oat subject to Regulation 7,aectron 0,:F"-t II.,orotfier Partt 2
requcements,so this source will have the opacity rc uu_me0ts from regulation 1 anti an initial resting condition tha'is ainethud 9,This control device Is bang used to control the condensate tanks,s,,is regorerl to meet the requirements of
XVII 8.2(now owl D,Section!LB 2),bat nr.,t based to this point,so the permit will reflect applicaarhty based on the separator venting.
Section 09-Inventory SCC Coding and Emissions Factors
AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units
006 01 _ -69 t:r",s PM10 17.6
PM2.S -7 5 _ E'ojt=t7 s`t=CF
50x 1. j. 111/MNISCF
N0x -6.0.3 0 €.,•.t>1;iv.Ce
V0C i;}S3c.1 95 AaMSCF
CO 73s..O ' 4-4`,:=ap5€:".
Benzene 341.4 �:-I C,•3"i5v-
Toluene 228.9 95 ib/Pnt SCF
Ethylbenzene .Iau.7 91 ,a o..'aft_-
Xylene 95.8
n-Hexane 2.52.1-2
224 TMP
4 of 7 Ki\PA\2019\19WE1030.CP1
•
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re viaticum 3 Parts A and B APEN and Permit Requirements
5aurse Is is the Nan-A'ra,nmcnt:Area
•
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section tI.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)?
IY uhave.ndiso!ndthats the an-1n,rn,crnGnu
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY(Regulation 3,Part A,Section 11.1.1.a1? Key Source Re
2. Are total fecilityuncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part R,Section 11.1.2)? pas Source Re
Is requires a permit
Colorado Regulatom 7,Section eVII
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? 1I ''Source Is
ISm r i;_ is , .. gnlolhan 7,Setmr. IN,"
Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section RVII.G-Emissions Control
Alternative Emissions Control Optional Section'
a. Is thb separator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? ' The contra
IT laparator is notu,bl-ct:uY Cuio-
. r:m nn]Snn YVII.B,2e
Section XVII.B.2.e-Alternative emissions control equipment
Disclaimer
This document assists operators vnth determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is
not a rule or regulation,and the analysis it contains may not apply to particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,
regulation,or any ofherlegally 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 Qualify 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
Weeded to describe APCD Interpretations and recommendations.Mandatory terminology such as'must"and'required"are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself
•
•
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Crestone Peak Resources Operating,LLC
County AIRS ID 123 History File Edit Date 2/13/2020
Plant AIRS ID 9D3B Ozone Status Non-Attainment
Facility Name Rodman Bruntz C266 and D266 Last Modified By: Lauraleigh Lakocy
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 0.0 0.0 0.0 _ 0.0 8.4 238.1 0.0 13.3 11.3 0,0 0.0 0.0 2.0 50.9 0.0 6.8 0.6 From April 2019
Previous Permitted Facilit total 0.0 0.0 0.0 0.0 1.1 237.9 0.0 5.0 11.3 0.0 0.0 0.0 0.0 1.1 50.5 0.0 5.0 0.6
001 14WE1608 Hydrocarbon loadout to trucks 29.2 1.7 1.5 0.1 No Change
002 GP01 Condensate Tanks(14;12-750 bbl, 0.4 190.1 1.9 3.9 0.4 10.0 1.9 0.2 Updating throughput&SSEF
2-300 bbl)
003 GP05 Produced Water Tanks(4) 1.1 0.1 10.0 0.0 AP EN Update
004 17WE0781.XP RICE(COMPRESSCO,GJ230,<50 7,3 0.2 8.3 0.1 0.9 0.4 1.8 0.1 XP Pilot Program
HP)
005 r° 17W50762,CN RICE,(COMPRESSCO e)230<50 0:0 00 Canoeltatio(rreceived7/25/2019 Source=7o
�,• ,'t,r HP) "F, „>. .1 longerextets
008 19WE1030 Separator Gas Venting(Buffer) 0.1 0.1 0,6 314.9 2.9 13.1 0.1 0.1 0.6 15.8 2.9 0.7 New Emission Point
0.0 0.0
0.0 0.0
APEN Exempt/Insignificant Sources 0.0 0.0
HI/Low Separators(13) 0.2 0.2 2.8 0.2 2.4 0.1 0.2 0.2 2.8 0.2 2.4 0.1 Per Form APCD-102
Hulk Heater Treater 0.1 0.1 0.8 0.6 0.0 0.1 0.1 0.8 0.6 0.0 Per Form AFCD-'102
Fugitives 0.9 0.0 0.9. 0.0 Per P"onn APCD-102
FACILITY TOTAL 0.4 0.4 0.0 0.0 11.9 535.7 0.9 16.1 19.0 0.4 0.4 0.0 5.5 37.9 0.9 9.6 1.1 VOC: Syn Minor(NANSR and OP)
NOx:True Minor(NANSR and OP)
CO: True Minor(PSD and OP)
HAPS: Syn Minor(n-hexane)
Permitted Facility Total 0.1 0.1 0.0 0.0 1.0 535.3 0,0 4.8 18.9 0.1 0.1 0.0 0.0 1.0 37.3 0.0 4.8 0.9 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions 0.1 0.1 0.0 0.0 -0.1 -13.2 0.0 -0.2 Pubcom required as this request is for a new
synthetic minor limit.Modeling not required based
on division guidance.
Total VOC Facility Emissions(point and fugitive) 38.8 Facility is eligible for GP02 because<45 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -13.2 Project emissions less than 25 tpy
Note 1
Note 2
Page 6 of 7 Printed 2/27/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,LLC
County AIRS ID 123
Plant AIRS ID 9D3B
Facility Name Rodman Bruntz C266 and D266
Emissions-uncontrolled(lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane Me0H 224 TMP H2S TOTAL(tpy)
rPrevious FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 14WE1608 Hydrocarbon loadout to trucks 550 980 428 1362 1.7
002 GP01 Condensate Tanks(14;12-750 bbl,2-300 bbl) 788 683 22 156 6210 31 3.9
003 GP05 Produced Water Tanks(4) 57 179 0.1
004 17WE0781.XP RICE(COMPRESSCO,GJ230,<50 HP) 89 12 11 7 2 1 13 0.1
005 17WE0782,CN RICE.(COMPRESSCO,:GJ230,<50 HP) 0.0
006 19WE1030 Separator Gas Venting(Buffer) 2554 2339 123 757 20510 10 13.1
0.0
0.0
APEN Exempt/Insignificant Sources 0.0
Hi/Low Separators(13) 4 102 0.1
Bulk Heater Treater 1 28 0.0
Fugitives 8 61 0.0
TOTAL(tpv) 0.0 0.0 0.0 2.0 2.0 0.1 0.7 14.2 0.0 0.0 0.0 0.0 19.0
"Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de minirnus
Emissions with controls(lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 14WE1608 Hydrocarbon loadout to trucks 27 49 21 68 0.1
002 GP01 Condensate Tanks(14;12-750 bbl,2-300 bbl) 39 34 1 8 310 2 0.2
003 GP05 Produced Water Tanks(4) 3 9 0.0
004 17WE0781.XP RICE(COMPRESSCO,GJ230,<50 HP) 89 12 11 7 2 1 13 0.1
005 17WE0782.CN RICE(COMPRESSCO,GJ230,<50 HP) 0.0
006 19WE1030 Separator Gas Venting(Buffer) 128 117 6 38 1025 1 0.7
0.0
0.0
APEN Exempt/Insignificant Sources 0.0
Hi/Low Separators 03) 4 102 0.1
Bulk Heater Treater 1 28 0.0
_Fugitives 8 61 0.0
TOTAL(tpy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.8 0.0 0.0 0.0 0.0 1.1
7 19WE1030.CP1 2/27/2020
vvt�
1 I r
Gas Venting APEN Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
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:
/9We/0.393
AIRS ID Number: 123 / 9D3B / D D'
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name:
Site Location:
Mailing Address:
(Include Zip Code)
Rodman Bruntz 26H
Site
SWNW Section 26, T2N, R66W Location County: Weld
10188 East 1-25 Frontage Road
Firestone, CO 80504
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
Sabrina Pryor
(303) 774-3923
E -Mail Address2: sabrina.pryor@crestonepr.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
421629
Av COLORADO
1 i
Permit Number: AIRS ID Number:
123 / 9D3B /
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name3 O Add point to existing permit
❑ 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 -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
enclosed combustor.
Buffer (separator) gas venting controlled by
Company equipment Identification No. (optional): Buffer
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is: 1/1/2020
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
El Yes
O Yes
❑✓ Yes
No
No
No
cOLORAoo
2I
Permit Number:
AIRS ID Number: 123 / 9O3B /
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
VentValue:
Heating Valuue::
2 358
,
BTU/SCF
Requested:
11.18
MMSCF/year
Actual:
__
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
41.44
VOC (Weight %)
73.66
Benzene (Weight %)
0.30
Toluene (Weight %)
0.27
Ethylbenzene (Weight %)
0.014
Xytene (Weight %)
0.089
n -Hexane (Weight %)
2.40
2,2,4-Trimethylpentane (Weight %)
0.0012
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
31
AV
COLORADO
Lr csl Vut�<
Permit Number:
AIRS ID Number:
123/903B/
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.11138 / -104.74962
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
(7)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Sep Vent
Indicate the direction of the stack outlet: (check one)
0 Upward
O Horizontal
Ei
O Downward
Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
O Other (describe):
Interior stack diameter (inches):
O Upward with obstructing raincap
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.
O VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed:
0 Combustion
Device:
Pollutants Controlled:
VOCs, HAPs
Rating: NA MMBtu/hr
Type: Enclosed Combustor Make/Model:
NA
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: NA Waste Gas Heat Content: 2,358 Btu/scf
Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: 0.025 MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
COLORADO
AV 4
Permit Number:
AIRS ID Number:
123 / 9D3B I
Section 7 - 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
rail (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SOX
NO.
CO
VOC
Enclosed Combustor
95%
HAPs
Enclosed Combustor
95%
Other:
From what year is the following reported actual annual emissions data?
NA
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions°
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOx
NO.
0.068
Ib/MMBtu
AP -42
--
--
--
0.90
CO
0.31
lb/MMBtu
AP -42
--
--
--
4.12
VOC
80.54
lb/Mscf
Eng calc
--
--
450.12
22.51
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
Emissions°
(pounds/year)
Benzene
71432
0.33
lb/Mscf
Eng calc
Toluene
108883
0.30
lb/Mscf
Eng calc
Ethylbenzene
100414
0.016
lb/Mscf
Eng calc
Xylene
1330207
0.097
lb/Mscf
Eng calc
n -Hexane
110543
2.62
lb/Mscf
Eng calc
2'2'4
Trimethylpentane
540841
0.0013
lb/Mscf
Eng calc
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
5�
AVCOLoenoo
Permit Number:
AIRS ID Number: 1 23 / 9D3B /
[Lease blank unless APCD has already assigned a permit r; and AIRS ID?
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
10/31/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Sabrina M. Pryor Air Quality Engineer
Name (please print) Title
Check the appropriate box to request a copy of the:
✓❑ Draft permit prior to issuance
✓❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
430O Cherry Creek Drive South
Denver, CO 8O246 -153O
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/cdphelapcd
Form APCD-211 Gas Venting APEN - Revision 3/2O19
7ua7 COLORADO
6 I ,\/
!WED
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
�t l tt','tt.'
AIRS ID Number: 123 / 9D3B /
[Leave blank unless APCD has already assigned a permit 11 and AIRS ID]
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Rodman Bruntz 26H
Site Location: SWNW Section 26, T2N, R66W
Mailing Address:
(Include zrp Code) 10188 East 1-25 Frontage Road
Site Location
County: Weld
NAICS or SIC Code: 1311
Firestone, CO 80504 Contact Person: Sabrina Pryor
Phone Number: (303) 774-3923
E -Mail Address2: sabrina.pryor@crestonepr.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 1212019
,,t,..;.
Permit Number:
AIRS ID Number: 123 / 9D3B /
[Leave blank unless APCD has already assigned a permit b: and AIRS ID]
Section 2 - Requested Action
NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that opplies)
❑ Change fuel or equipment ❑ Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
1:1 Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Buffer (separator) gas venting controlled by enclosed combustor
Company equipment Identification No. (optional): Buffer
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
3/1/2020
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
Form APCD-211 - Gas Venting APEN - Revision 12/2019
days/week weeks/year
❑✓ Yes
❑ Yes
qi Yes
❑ No
❑✓ No
❑ No
COLORADO
2 t WONT ..tot: .1
IiNalNbZn ironmrnt
Permit Number:
AIRS ID Number: 123 / 9D3B /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
O Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Btowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy?
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ Yes O No
Vent Gas
Heating Value:
2,358
BTU/SCF
Requested:
7.82
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
41.44
VOC (Weight %)
73.66
Benzene (Weight %)
0.30
Toluene (Weight %)
0.27
Ethytbenzene (Weight %)
0.014
Xylene (Weight %)
0.089
n -Hexane (Weight %)
2.40
2,2,4-Trimethylpentane (Weight %)
0.0012
Additional Required Documentation:
0 Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
............... .
Form APCD-211 - Gas Venting APEN - Revision 12/2019
�i,� iCOLORADO
3 j E ,s.
Permit Number:
AIRS ID Number: 1 23 / 9D3B /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.11138 / -104.74962
r❑ Check box if the following information is not applicable to the source because emissions wilt not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
°„
Operator
,Sxack ID�No
Discharge Height
Above Ground Level
(Feet)
Temp
('F)
Flovr Rate
.� ., (ACF�4t)
Yeloctty
fftLee
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward
❑ Horizontal O Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
O Upward with obstructing raincap
Interior stack depth (inches):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
O VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed:
❑ Combustion
Device:
Pollutants Controlled: VOCs, HAPs
Rating: NA
Type: Enclosed Combustor Make/Model: NA
MMBtu/hr
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: NA Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating:
2,358
0.025
Btu/scf
MMBtu/hr
O
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 12/2019
COLD R ADD
r w"'m" ft'h'
4 fl eilh bCnbenmou
Permit Number:
AIRS ID Number: 1 23 / 9D3B /
[Leave blank unless APCD has already assigned a permit ii and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes 0 No
If yes, describe the control equipment AND state the collection and control efficiencies report the overall, or
iole emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
PM
SOX
NOX
CO
VOC
Enclosed Combustor
100%
95%
HAPs
Enclosed Combustor
100%
95%
Other:
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Basis
0.068
0.31
80.54
lb/MMBtu
lb/MMBtu
lb/Mscf
AP -42
AP -42
Site Specific
Units
Source
(AP -42,
Mfg., etc.)
Actual Annual Emissions!
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
S0x
NO.
CO
VOC
315.08
0.63
2.89
15.75
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑✓ Yes ❑ No
e to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42, .
Mfg,, etc.)
Uncontrolled
Emissions
Ibs/ e
ar ( Y _.,.J
Controlled
Emissions
(lbs/year)
Benzene
71432
0.33
lb/Mscf
Site Speck
Toluene
108883
0.30
lb/Mscf
Site Specific
Ethylbenzene
100414
0.016
lb/Mscf
Site Specific
Xylene
1330207
0.097
lb/Mscf
Site Specific
n -Hexane
110543
2.62
lb/Mscf
Site Specific
2,2,4-Trimethylpentane
540841
0.0013
lb/Mscf
Site Specific
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-211 - Gas Venting APEN - Revision 12/2019
b COLORADO
5 I Apt
IlIapartm.eiPuttle
NMM6 Yn-bonnte.t
Permit Number:
AIRS ID Number: 123 / 9D3B /
[Leave blank unless APCD has already assigned a permit ,Y and AIRS ID]
Section 9 - Applicant Certification
hereby certify that all information contained herein and information submitted with this application is complete,
true, andyc lrr yt.
f
Y'et ;.1///f/ 2/13/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Sabrina M. Pryor Air Quality Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
ID 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 to: For more information or assistance call:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
Make check payable to: (303) 692-3150
Colorado Department of Public Health and Environment
Form APCD-211 - Gas Venting APEN - Revision 1212019 6
'COLORADO
DaParienent at Public
M.tfth i Health 6Ernenment
3/12/2020 State.co.us Executive Branch Mail - Crestone Peak Resources Operating, LLC - Rodman Bruntz 26H Permit Modification Updates
STATE OF
COLORADO
Lakocy - CDPHE, Lauraleigh <lauraleigh.lakocy@state.co.us>
Crestone Peak Resources Operating, LLC - Rodman Bruntz 26H Permit Modification
Updates
Sabrina Pryor <Sabrina.Pryor@crestonepr.com> Thu, Feb 27, 2020 at 1:28 PM
To: "Lakocy - CDPHE, Lauraleigh" <lauraleigh.lakocy@state.co.us>
Lauraleigh,
The proposed control is an enclosed flare, therefore can you revert back to the combustion device used with no visible emissions
during normal operations (was permit condition 13 in first draft) and revert condition 15 back to Method 22 initial testing?
You may redline the APEN on page 2 as described below.
Can you tell me what the criteria is causing this permit to go to public comment?
Thanks so much,
Sabrina M. Pryor
Air Quality Engineer
Crestone Peak Resources
A CRESTONE PEAK
F;;Sauc►5
From: Lakocy - CDPHE, Lauraleigh <lauraleigh.lakocy@state.co.us>
Sent: Thursday, February 27, 2020 8:18 AM
To: Sabrina Pryor <Sabrina.Pryor@crestonepr.com>
Subject: [EXTERNAL MAIL] Re: [EXTERNAL MAIL]Re: [EXT]Crestone Peak Resources Operating, LLC - Rodman Bruntz 26H
Permit Modification Updates
Dear Sabrina,
Thank you for this feedback! May I redline the APEN on page 2 to select the option "No" to the question, "Is this equipment subject to
Colorado Regulation No. 7 Section XVII.G?"?
With that being established, I removed conditions 13 and 14 and added condition 12. While this flare is subject to Section II
requirements because it is controlling the condensate tanks (GP01), but that applicability does not apply for its control of the
separator venting. Additionally, the initial compliance demonstration has been changed to a method 9 test (permit condition 15). Let
me know if you have any questions. And thank you for that note on the former condition 13! I had missed that reference.
I have updated the emission factors in the notes to permit holder and attached an updated permit draft. Can you let me know if this is
acceptable to go to public comment?
httpsa/mail.google.com/mail/u/0?ik=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1659723139784056637&dsgt=l &simpl=msg-f%3A16597... 1/7
Hello