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Home My WebLink About20201725.tiff --:. COLORADO 1 Department of Public aC PH E Health b Environment RECEIVED MAY 0 5 2020 Weld County - Clerk to the Board 1150 O St WELD COUNTY PO Box 758 COMMISSIONERS Greeley, CO 80632 April 22, 2020 Dear Sir or Madam: On April 23, 2020, the Air Pollution Control Division will begin a 30-day public notice period for HighPoint Operating Corporation - Park 4-63-4 NE 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 Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator cap c°1a 14300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe I - ,th lt4i_ "-7:7,-,:?, tot Jared Polis,Governor I Jilt Hunsaker Ryan,MPH, Executive Director Pub'',c Rev'erui cc:P�(i�),H�( ),pi„&14/6R/cH/cW), 2020-1725 t/i5/20 G0O14) 6/oct/2O M. Air Pollution Control Divisio n nNotice of a Proposed Project or Activity Warranting Public 0 CDPHE Comment Website Title: HighPoint Operating Corporation - Park 4-63-4 NE Pad - Weld County Notice Period Begins: April 23, 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: HighPoint Operating Corporation Facility: Park 4-63-4 NE Pad EE LP Well Pad SENE SEC 4, T4N, R63W Weld County The proposed project or activity is as follows: Applicant is requesting individual permit coverage for the condensate tank battery and liquid loading sources at this facility, in addition to GP08 coverage for a produced water tank battery. 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 19WE0959 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 (COLORADO 1 � Department of Public Health Et Environment i CDPHE Condensate Storage Tai. ( APEN Form APCD-205 COAir 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 wilt be rejected and will require re-submittal. Your APEN will be rejected If it Is filled out incorrectly,is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks, produced water storage tanks,hydrocarbon liquid loading,etc.).In addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Mr Pollution Control Division(APCD) website at:www.colorado.stoviDacificicdphe/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, 1 t ' J q AIRS ID Number: 12-3 /A ' / I (Leave blank unless APCO has already assigned a permit#and AIRS ID) Section 1 -Administrative Information Company Name: HighPoint Operating Corporation Site Name: Park 4-63-4 NE Pad Site Location Site Location: SENE Sec.4,T4N, R63W County: Weld NAICS or SIC Code: 1311 Mailing Address: (include Zip Code) 555 17th Streets Suite 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E-Mail Address2: CDPHE_Correhpres.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. 4.^0198 amp CotogAC0 Form APCD-2O5 Condensate Storage Tanks)APEN Revision 3/2019 1 i Aitiff ≥r,-.1 , Permit Number: AIRS iD Number: (Leave blank unless APC()has already assigned a permit#and AIRS ID) Section 2- Requested Action O NEW permit OR newly-reported emission source {['J Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GP08 If General Permit coverage is requested,the General Permit registration fee of 5312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O 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) -Aoorrwtut.Paw Acrops- • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Register condensate storage tanks under an individual permit. 3 For company name change,a completed Company Name Change Certification Form(Form AP:D-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: Six (6) 400 bbl condensate storage tanks. Company equipment Identification No. (optional): For existing sources,operation began on: For new or reconstructed sources,the projected start-up date is: 07/08/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration&Production(E&P)site O Midstream or Downstream(non E&P)site Witt this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Are Flash Emissions anticipated from these storage tanks? 0 Yes ❑ No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? 0 Yes O No if"yes",identify the stock tank gas-to-oil ratio: 0.00297 m3/titer Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes 0 No 805 series rules?if so,submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual 0 Yes O No emissions a 6 ton/yr(per storage tank)? COLORAco Form APCD-205 Condensate Storage Tanks)APEN-Revision 3/2019 2 I at' :" "> Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 4- Storage Tank(s)information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (Uhl/year) I Condensate Throughput: 305.000 366.000 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 42.8 degrees RVP of sales oil: 8.2 Tank design: 0 Fixed roof O Internal floating roof O External floating roof Storage /I of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) Cond.TICS 6 2400 01/2019 07/2019 Wells Serviced by this Storage Tank or Tank Battery'(EBP Sites only) API Number Name of Well Newly Reported Well 05 -123 •49070 Park 4-63-4-0108B 0 05 -123 -49074 Park 4 63 4 16090 0 05 -123 -49075 Park 463 4 16098 0 05 123 -49079 Park 4-63-4-1724C 0 O S 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) 40.343323, -104.434189 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (It/sec) ECD —20 TBD TBD TBD Indicate the direction of the stack outlet:(check one) 0 Upward O Downward O Upward with obstructing raincap O Horizontal O Other(describe): indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 84 O Square/rectangle Interior stack width(inches): Interior stack depth(inches): O Other(describe): Amy COLORADO Form APCD-2O5 Condensate Storage Tank(s)APEN •Revision 3/2019 3 ! v no,-1 Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit and AIRS ID) Section 6-Control Device information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: V4c&HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model:(2)84 '!Cimarron Big Hurts ' Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: NJA Waste Gas Heat Content: 2,448 Btu/scf Constant Pilot Light: Q Yes ❑ No Pilot Burner Rating: 0.14 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: 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)? —11.1 psig Describe the separation process between the well and the storage tanks: Hydrocarbon liquids flow from the four(4)inlet separators to one(1)heated flash gas separator(heater treater),then to one(1)VRT,and then to the six(6)condensate storage tanks. COLORADO Form APCD-205 Condensate Storage fiank(s)APE1i Revision 3/2019 4 I AV' t ..' . Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 8- Emissions Inventory Information Attach alt 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 overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) VOC EGO 9s% NOx CO HAPs EGO 95% Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory l Emission Factor7 Actual Annual Emissions Request A Emissionu `(Permit Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions° Emissions Emissions Bash MJg.,etc.) (tons/year) (tons/year) (tons/year) (ton+shear) VOC 1.762 lb/bbl Eng.Est. 268.64 13.43 322.36 16.12 NOx 0.068 Ib/MMBtu AP-42 0.50 0.59 CO 0.31 Ib/MMBtu AP-42 2.28 2.70 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor7 Actual Annual Emissions Absct Chemical Name Seca aCAS) Source Uncontrolled Controlled Uncontrolled Units 60.42,2, Emissions Emissions` Number Basis Mfg.,etc.) (Pounds/yam) (pounds/year) Benzene 71432 0.004 lb/bbl Eng.Est 1127 56 Toluene 108883 0.003 lb/bbl Eng.Est 802 40 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.033 lb/bbl Eng.Est 10197 510 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations.Requested limits)should consider future growth. x Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14.03. s Annual emissions fees will be based on actual controlled emissions reported.if source has not yet started operating,leave blank. COLORADO Form APCD-2O5 Condensate Storage Tank(s)APEN-Revision 3/2019 5 I ®Y :m.R Permit Number: AIRS ID Number: / (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 GP01 or GPo8,I further certify that this source is and will be operated In full compliance with each condition of the applicable General Permit. tel Signature of Legally Authorized rson 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 requiretts. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment httos://www.cotorado.ttovicdphe/apcd Aw COLORADO Form APCD-205 Condensate Storage Tank's}APEN-Revision 3/2019 6 Ie=" o P H E Hydrocarbon Liquid Loading APEN * LI Form APCD-208 CO 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 hydrocarbon liquid loading only. 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,glycol dehydration unit, 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.aov/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: /60/609Z-(1) AIRS ID Number: /z?), /,yy/ 6 OZ, [leave blank unless APCD has already assigned a permit✓:and AIRS ID) Section 1 Administrative Information Company Hame': HighPoint Operating Corporation Site Name: Park 4-63-4 NE Pad Site Location Site Location: SENE Sec. 4, T4N, R63W County: Weld NAICS or SIC Code: 1311 ,tailing address: ,include Zip Code, 555 17th Street, Ste. 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E-Mail Address2: CDPHE,Corr@hpres.com use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 1 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 41'J193 QQ COLORADO Form,APCD-208 Hydrocarbon Liquid Loading APEN • Revision 3/2019 1 I S�® '" Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit»and AIRS ID) Section 2-Requested Action 0 NEW permit OR newly-reported emission source 0 Request coverage under construction permit O Request coverage under General Permit GP07 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 earn box below that applies) • Change fuel or equipment O Change company name3 ❑ 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 PluuIT AcnoKs- • Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info ft Notes: Register condensate loadout emissions under an individual permit. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-1O4)must be submitted. Section 3-General Information General description of equipment and purpose: Condensate Loading. iI{ Company equipment Identification No. (optional): For existing sources,operation began on: For new or reconstructed sources, the projected start-up date is: 07/08/2019 Wilt this equipment be operated in any NAAQS nonattainment area? ❑ Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes Q No emissions? Does this source load gasoline into transport vehicles? O Yes ❑ No Is this source located at an oil and gas exploration and production site? Q Yes O No if yes: Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes Q No average? Does this source splash fill less than 6750 bbl of condensate per year? O Yes 0 No Does this source submerge fill less than 16308 bbl of condensate per year? O Yes El No COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 2 1 Permit Number: AIRS ID Number: / / (Lea.-a blank unless APCD has already assigned a permit and AIRS ID) Section 4-Process Equipment Information Product Loaded: ❑ Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded§: 366,000 bbl/year Actual Volume Loaded: 305,000 bbt/year This product is loaded from tanks at this facility into: Tank trucks (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions,complete the following: Average temperature of 52.45 °F Saturation Factor: 0.6 bulk liquid loading: True Vapor Pressure: 4.06 Psia a 60°F displaced vapors:Motecutar weight of � lbrlb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: bbl/year Actual Volume Loaded: bbt/year Product Density: tb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: fti/truckload S Requested values wilt become permit limitations.Requested limit(s)should consider future process growth. COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 3 1 'G Permit Number: AIRS ID Number: [Lease Wahl,unless APCD has already assigned a per ait rr and AIRS ID] Section 5 -Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.343323/-104.434189 l schargeight Above Operator !Level Terip. Plow Rate Velocity Stack ID No - f»D IA C411 (t/sec) (feet) ECD -20 TBD TBD TBD Indicate the direction of the stack outlet: (check one) Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter(inches): 84 ❑Other(describe): 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. • 0 Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: VOC, I-IAPs Rating: TBD M Btu/hr Combustion 84"Cimarron Big Hurts Type: EGO Make/Model:(2) Q Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: >98 Minimum Temperature: NA 'F Waste Gas Heat Content: 2448 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.34 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: ANtrCCLoRAao Form APCD-208 Hydrocarbon Liquid Loading APEI4 Revision 3/2019 4 i ..:r,M Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit#and MRS ID] 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 overall(or combined)control efficiency(x reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (X reduction In emissions) PM SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: [] Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ID Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/661. ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Lfnndt(s) Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Bask Units ( 2. Emissions Emissions6 Emissions Emissions MJs.,etc) (gyro►) (taniWa) (tans/year) (tans/year) PM SOx NO. 0.068 b/MAAL3tu AP-42 0.04 0.05 CO 0.31 Ib/MMBtu AP-42 0.20 0.24 VOC 0.169 lb/bbl Eng.Est. 25.80 1.29 30.96 1.55 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Servke(CAS) Uncontrolled units fAp„42. Emissions Emissions6 Number Basis Alb,etc.) (pou,dslyeor) (pounds/y ) Benzene 71432 Toluene 108883 Ethytbenzene 100414 Xylene 1330207 n-Hexane 110543 0.003 b/bbi Eng.Est. 979 49 2,2,4- 540841 Trimethylpentane Other: 3 Requested values will become permit limitations.Requested llmit(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. CO4O ilADO Form APCO.2©8 Hydrocarbon Liquid Loading APEN Revision 3/2019 5 � .:.. . Permit Number: AIRS ID Number: / / (Leave blank unless APCD has already assigned a permit 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. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. tAAVAAAAL IA) *11 Signature of Legally Authorized 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: Q Draft permit prior to issuance E Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, Ii.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of 5312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692.3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Maln Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment httos://www.colorado.eov/cdoheiaocd coLoP•Do Form APC0-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 COLORADO I�I � Air Pollution Control Division CDAHE Department o₹Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0959 Issuance: 1 Date issued: Issued to: HighPoint Operating Corporation Facility Name: Park 4-63-4 NE Pad Plant AIRS ID: 123/A094 Physical Location: SENE SEC 4 T4N R63W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS`; Emissions Control Equipment Equipment Description ID Point Description Cond.'TKs 001 Six (6) 400 barrel fixed roof storage vessels Enclosed Combustion used to store condensate Device(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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.co.lorado.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 Page 1 of 9 .. , COLORADO Air Pollution Control Division COPHE Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.Rov/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 II.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 I I I.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 nn permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year ' Emission Equipment ID Point PM2.5 NO), VOC CO Type Cond. TKs 001 --- --- 16.1 2.7 Paint Note:See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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 9 ≤ «. COLORADO YJ! Air Pollution Control Division CQPHE 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.) Facility AIRS Pollutants Equipment Control Device ID Point Controlled Cond. TKs 001 Two (2) Enclosed Combustion Devices VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Process Parameter Annual Limit ID Point Cond. TKs , 001 Condensate throughput 366,000 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) Page 3 of 9 . y.'". COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 13. 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 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. 14. 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. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING &t MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. 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 XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page4of9 .w.�s COLORADO4.O Air Pollution Control Division t DPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level'reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • .Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- Page 5 of 9 COLORADO 1 Air Pollution Control Division CDPH Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 operators 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. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation Page 6 of 9 a COLORADO Air Pollution Control Division DP Department Department of Pulac 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 E.1 of the Common Provisions Regulation. See: ihttps://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 Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,352 68 Toluene 108883 963 48 Ethylbenzene 100414 74 4 001 Xylenes 1330207 255 13 n-Hexane 110543 12,236 612 2,2,4- 540841 7 0 Trimethylpentane 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 7 of 9 a ,....,,- COLORADO 4444 Air Pollution Control Division W" Department of Public Health ft 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: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 3.233 * 10-3 3.233 * 10-3 AP-42 Chapter CO 1.474 * 10-2 1.474 * 10-2 13.5 VOC 1.762 0.0881 71432 Benzene 3.694 * 10"3 1.847 * 10-4 108883 Toluene 2.630 * 10-3 1.315 * 10-4 100414 Ethylbenzene 2.025 * 10-4 1.013 * 10-5 Flash Liberation 1330207 Xylene 6.980 * 10-4 3.490 * 10-5 Analysis + Tanks 4.0.9d 110543 n-Hexane 3.343 * 10-2 1.672 * 10"3 540841 2,2,4- 1.830 * 10-5 9.150 * 10-' Trimethylpentane 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 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT HH Not Applicable Page 8 of 9 �r�~,x/ COLORADO a �3i►�,.. Air Pollution Control Division Department of Public Health b Ertvtronrnent Dedicated to protecting and improving the health and environment of the people of Colorado 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A- Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ-Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN Subpart XXXXXX Page9of9 4r.~<-. COLORADO 4.0_40 Air Pollution Control Division CQPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0960 Issuance: 1 Date issued: Issued to: HighPoint Operating Corporation Facility Name: Park 4-63-4 NE Pad Plant AIRS ID: 123/A094 Physical Location: SENE SEC 4 T4N R63W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID' Point Equipment Description Description Liquid 002 Truck loadout of condensate by Enclosed Flare Loading submerged fill 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 Page 1 of 10 Cashr,�.� COLORADO .{1 Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION.LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: AIRS Tons Per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type Liquid Loading 002 --- --- 1.6 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission 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. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants Controlled ID Point Liquid 002 Enclosed Flare VOC and HAP Loading Page 2 of 10 a • .. COLORADO Air Pollution Control Division CDP Department of Pubttc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit ID Point Liquid 002 Condensate Loaded 366,000 barrels Loading The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined,on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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.) 10. This source is subject to the odor requirements of Regulation Number 2. j(State only enforceable) 11. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 12. All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 13. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a tog available to the Division on request. Page 3 of 10 VI COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 14. For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 10 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 Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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. 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 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 5 of 10 COLORADO a .„4,w,,„ Air Pollution Control Division CDAH€ Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab Initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT Ben Fischbach Permit Engineer Page 6 of 10 • '"' - COLORADO Air Pollution Control Division Department of Public Wealth 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation. Page 7 of 10 .,.w<� COLORADO �„4 Air Pollution Control Division `� Department of Pubhhc 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 Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 130 6 Toluene 108883 92 5 Ethylbenzene 100414 7 0 002 Xylenes 1330207 25 1 n-Hexane 110543 1,174 59 2,2,4- 540841 1 0 Trimethylpentane 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. 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl NOx 2.86 * 10' 2.86 * 10-4 AP-42 Chapter CO 1.31 * 10"3 1.31 * 10-3 13.5 VOC 1.692 * 10-1 8.458 * 10-3 Benzene 71432 3.547 * 10-4 1.774 * 10-5 Eng. Est. Page 8 of 10 COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl Toluene 108883 2.527 * 10"4 1.263 * 10-5 Ethylbenzene 100414 1.953 * 10-5 9.767 * 10-' Xylene 1330207 6.700 * 10-5 3.350 * 10-6 Eng. Est. n-Hexane 110543 3.209 * 10-3 1.604 * 10.4 224 TMP 540841 1.680 * 10-6 8.401 * 10-8 The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 4.06 psia M (vapor molecular weight) = 68 lb/lb-mot T (temperature of liquid loaded) = 512.45 °R The uncontrolled non-criteria reportable air pollutang (NCRP) emission factors were calculated by multiplying the VOC emission factor by the ratio of the mass fraction of each NCRP in the vapors to the mass fraction of VOC in the vapors. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Page 9 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) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ben Fischbach Package #: 420201 Received Date: 10/2/2019 Review Start Date: 12/11/2019 Section 01 - Facility Information Company Name: HighPoint Operating Corporation Quadrant Section Township Range County AIRS ID: 123 Plant AIRS ID: A094 Facility Name: Park 4-63-4 NE Pad Physical Address/Location: SENE quadrant of Section 4, Township 4N. Range 63W County: Weld County Type of Facility: Exploration & Pi ad What industry segment? Oil & Natural Gas Production & Processislg Is this facility located in a NAAQS non-attainment area? Yes If yes, for what pollutant? Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only Permit # AIRs Point # Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Eqi ipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) PA Tabs Hidden in this File - See PA for Permit Initial 19WE0959.CP1 Condensate Tar ,- Cond. TKs 19WE0959 Yes issuance for this PA Permit Initial Liquid Loading Yes Issuance Section 03 - Description of Project Applicant is requesting individual permits for the condensate tank battery and liquid loading sources at this facility, in addition to GP08 coverage for the produced water tank battery. Applicant based all emissions calculations on site-specific emission factors which were developed for each point. Facility is classified as synthetic minor for VOC (TV and NANSR), and true minor for all other pollutants. Facility is requesting a Synthetic Minor permit, and will requ re Public Comment. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement 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? No Is this stationary source a synthetic minor? Yes 9 If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) . Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Q Non-Attainment New Source Review (NANSR) Hydrocarbon Loadout Emissions Inventory Section 01 - Administrative Information 123 :':.;:,. 002 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Condensate loadout from storage tanks to tan < trucks. Description: Emission Control Device Enclosed Combustion Devices Description: Is this loadout controlled? ' . ,4 .. , , egt • Sr Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 305,000 Barrels (bbl) per year Requested Permit Limit Throughput = 366,000 Barrels (bbl) per year Requested Monthly Throughput = t :::: Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 366,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2448 Btu/scf Actual Volume of waste gas emitted per year = 524577 scf/year Changed Waste Gas emission equations to reflect operator Requested Volume of waste gas emitted per year = 629493 scf/year calculations which use the actual gas MW (instead of assumed Actual heat content of waste gas routed to combustion device = 1,284 MMBTU per year value of 68 lb/lbmol from Gasoline RVP 8.3 properties) and also to Requested heat content of waste gas routed to combustion device = 1,541 MMBTU per year reflect VOC% of gas. Both of these alterations to equation result in slightly more conservative results, so will accept and use in Potential to Emit (PTE) heat content of waste gas routed to combustion device = 1,541 MMBTU per year permit. Control Device Pilot Fuel Use Rate: 0 scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: 0 Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Loading Loss Equation L = 12.46*S*P*M/T Factor Meaning Value Units Source S Saturation Factor 0.b ; !,, � P True Vapor Pressure 4.06 psia AP-42 Table 7.1-2: Gasoline RVP 8.3 Properties Assumed M Molecular Weight of Vapors 68 lb/lb-mol AP-42 Table 7.1-2: Gasoline RVP 8.3 Properties Assumed *** RVP 8.3 Properties assumed based on Results of Flash T Liquid Temperature 512.45 Rankine AP-42 Table 7.1-2: Gasoline RVP 8.3 Properties Assumed Liberation Analysis, which shows an RVP equivalent L Loading Losses 4.02765944 lb/1000 gallons (@100F, by ASTM D6377) of 8.2 psi. Assumed RVP of 8.3 is 0.169161696 lb/bbl more conservative, so will accept and base emission factors off of properties in table 7.1-2. *** Component Mass Fraction Emission Factor Units Source Benzene 0.00210 0.00035475 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Toluene 0.00149 0.000252673 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Ethylbenzene 0.00012 1.95333E-05 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Xylene _ 0.00040 6.70013_-05 lb/bbl Ratio of Benzene:VOC in condensate flash gas. n-Hexane _ 0.01897 0.003208997 lb/bbl Ratio of Benzene:VOC in condensate flash gas. 224 TMP 9.93E-06 1.68028E-06 lb/bbl Ratio of Benzene:VOC in condensate flash gas. Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Volume (Volume Loaded) Loaded) VOC 1.692E-01 8.458E-03 Site Specific -AP-42. Chapter 5.2, Equat,:r: I Benzene 3.547E-04 1.774E-05 Site Specific- AP-42: Chapter 5.2, Equ ;ate, Toluene 2.527E-04 1.263E-05 Site Sp-til"k • APM42 Chapter SI, Lid.:: Ethylbenzene 2.953E-05 9.767E-07 Site Specific -SAP-42:Chapter .52 Equation a Xylene 6.700E-05 3.350E-05 Site Specific - AP-42: Chapter w_2, £quatii n-Hexane 3.209E-03 1.604E-04 Site Specific - AP42° Chapter S.2 Ecp ab on 224 TMP 1.680E-06 8.401E-03 r ° - S ,£quatiion ?. Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.00E+00 PM2.5 0.00E+00 SOx 0.00E+00 NOx 0.0680 2.86E-04 x CO 0.3100 1.31E-0= Pilot Light Emissions Uncontrolled Uncontrolled Pilot light emissions are accounted Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source for/apportioned to on point 001 at this facility. (Pilot Gas (Waste Heat Combusted) Throughput) PM10 0.0000 PM2.5 0.0000 SOx 0.0000 NOx 0.0000 CO 0.000£3 2 of 6 K:\PA\2019\19WE0960.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrol ed Controlled Uncontrolled Controlled Controlled (tons/year) (tons/yea-) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.00 0.00 0.00 0.00 0.00 0 PM2.S 0.00 0.00 0.00 0.00 0.00 0 S0x 0.00 0.00 0.00 0.00 0.00 0 NOx 0.05 0.04 0.04 0.05 0.05 9 V0C 30.96 25.80 1.29 30.96 1.55 263 CO 0.24 0.20 0.20 0.24 0.24 41 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 130 108 5 130 6 Toluene 92 77 4 92 5 Ethylbenzene 7 6 0 7 _ 0 Xylene 25 20 1 25 - 1 n-Hexane 1174 979 49 1175 59 224 TMP 1 1 0 1 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? RC s a*i. ,. r . 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 *** RVP 8.3 Properties assumed based on Results of Flash Liberation Analysis, which shows an RVP equivalent (@100F, by ASTM D6377) of 8.2 psi. Assumed RVP of 8.3 is more conservative, so will accept and base emission factors off of properties in table 7.1-2. *** Altered Waste Gas emission equations to reflect actual gas MW (instead of assumed value of 68 Ib/Ibmol from Gasoline RVP 8.3 properties) and also to reflect V0C% of gas. Both of these changes to equation result in slightly more conservative results, so will accept and use in permit. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process #t SCC Code Pollutant Factor Control % Units 002 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 , lb/1,000 gallons transferred PM2.5 0.00 L.. lb/1,000 gallons transferred S0x 0.00 c lb/1,000 gallons transferred N0x 0.01 0 lb/1,000 gallons transferred V0C 4.0 _ lb/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.01 9' Ib/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n-Hexane 0.08 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 3 of 6 K:\PA\2019\19WE0960.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? 3. Is the loadout operation loading less than 10,000 galons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non-Attainment Area 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)? Yes Go to next 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? Yes Go to the n 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No Go to next 4. Is the loadout operation loading less than 6,750 bbis per year of condensate via splash fill? Na Go to next 5. Is the loadout operation loading less than 16,308 bbis per year of condensate via submerged fill procedure? No Go to next 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes The Ioadou Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? Yes ; The Ioadou The loadout must operate with submerged fill and 'oadout emissions must be routed to flare to satisfy RACT. 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 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. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name HighPoint Operating Corporation County AIRS ID 123 History File Edit Date 4/1512020 Plant AIRS ID A094 Ozone Status Non-Attainment Facility Name Park 4-63-4 NE Pad 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 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total r Previous Permitted Facility total 0.0 (1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0959 Six (6) 400 bbl Condensate Tanks 0.6 322.4 2.7 7.4 0.6 16.1 2.7 0.4 New 002 19WE0960 Condensate Loadout 0.1 31 .0 0.2 0.7 0.1 1 .6 0.2 0.0 New 003 GP08 Two (2) 400 bbl Produced Water Tanks 0.0 2.6 0.1 0.2 0.0 5.9 0.1 0.0 New 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 0.7 355.9 0.0 3.0 8.3 0.0 0.0 0.0 0.0 0.7 23.6 0.0 3.0 0.4 VOC: Syn Minor (NANSR and OP) NOx: True Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: True Minor B, T, X, HCHO & Total HH: True Minor + affected Area 7777: True Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0.7 355.9 0.0 3.0 8.3 0.0 0.0 0.0 0.0 0.7 23.6 0.0 3.0 0.4 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.7 23.6 0.0 3.0 Pubcom required based on requesting Syn Minor Permit Limit. Modeling Not required. Total VOC Facility Emissions (point and fugitive) 23.6 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 23.6 Project emissions less than 25 tpy Note 1 Note 2 Page 5 of 6 Printed 4/15/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name High Point Operating Corporation County AIRS ID 123 Plant AIRS ID A094 Facility Name Park 4-63-4 NE Pad Emissions - uncontrolled (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 19WE0959 Six (6) 400 bbl Condensate Tanks 1352 963 74 256 12236 7.4 002 19WE0960 Condensate Loadout 130 92 7 ._ 1175 0.7 003 GP08 Two ;2; 400 bbl Produced Water Talks 143 96 6 - 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.8 0.6 0.0 0.1 6.7 0.0 0.0 0.0 0.0 8.3 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McCH 224 TMP H2S TOTAL (tpy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0959 Six :6' 400 bbl Condensate Tanks 68 48 4 13 612 0 0.4 002 19WE0960 Condensate Loadout 0 59 0 0.0 003 GP08 Two (2) 400 bbl Produced Water Tanks _ 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 0.0 0.0 0.0 0.0 0.4 6 19WE0960.CP1 4/15/2020 Hello