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Home My WebLink About20202688.tiff C X,- COLORADO 4:44114 'P liteDepartment of Public Health b Environment RECEIVED AUG 1 3 2020 WELD COUNTY Weld County - Clerk to the Board COMMISSIONERS 1150 O St PO Box 758 Greeley, CO 80632 August 10, 2020 Dear Sir or Madam: On August 11, 2020, the Air Pollution Control Division will begin a 30-day public notice period for CCRP Operating Inc. - Cox 22-B. 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 Ft 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 I '',:,,,/ *fin' Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director ,. ,, PL/b 1:c Rev ; eGJ cc.pLcrp), m..(Ds),P0(3K/Ek/cw/cg) 2020-2688 o' /O9/2O 06(3,4) O Y/31 /2-O 44‘46.< :3M> Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public ccPHe CM Comment Website Title: CCRP Operating Inc. - Cox 22-B- Weld County Notice Period Begins: August 11, 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: CCRP Operating Inc. Facility: Cox 22-B Well Production Facility NENW of Section 22, Township 12N, Range 64W Weld County The proposed project or activity is as follows: CCRP Operating Inc. (CCRP) submitted an application requesting to modify an existing synthetic minor oil and gas well production facility located in the ozone attainment area. The operator is requesting to modify the existing crude oil storage vessels, produced water storage vessels, hydrocarbon liquid loadout and separator venting source. The operator is also requesting to add a new separator venting source due to the addition of a new well to the facility. 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 16WE0646, 19WE0076, 19WE0077, 20WE0634 Et 20WE0635 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: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 COLORADO -�.- Depaxttnent of Public 1 I SDH9E Health 0 Environment Denver, Colorado 80246-1530 �_,awy'� COLORADO Department of Public L " Health&Environment COLORADO #40 fi Air Pollution Control Division _. " DeoarOnerel of Puftie Health B Envtronri i M Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 16WE0646 Issuance: 2 Date issued: Issued to: CCRP Operating Inc. Facility Name: Cox 22-B Plant AIRS ID: 123/9E51 Physical Location: NENW SEC 22 T12N R64W County: Weld County Description:, Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID. Cox#1 Natural gas venting from one (1) two-phase Enclosed Enclosed 003 separator and one (1) three-phase heater Combustor(s) Flare treater. 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. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. 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 Page 1 of 10 COLORADO ti4 Air Pollution Control Division CDPt Dtg.,aritrivql. eub .Health Er art irri m Dedicated to protecting and improving the health and environment of the people of Colorado 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.) 3. 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.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part,B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type Cox#1 003 --- --- 9.2 2.8 Point Enclosed Flare 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. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit- prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 , COLORADOPollution Control • biviaian CDPHE [tvar.. ent o PUNY_Ht7frti(T n,rvirrt - Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Pollutants Equipment Point Control Device Controlled ID Cox #1 Enclosed 003 Enclosed Combustor(s) VOC and HAP Flare PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Process Parameter Annual Limit ID Cox #1 Natural gas vented from the two-phase Enclosed 003 01 separator and three-phase heater treater 11.4 MMSCF and routed to the enclosed combustor(s) Flare 02 Combustion of pilot light gas 0.5 MMSCF The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must continuously (i.e. at least once every 15 minutes) monitor and record the volumetric flow rate of natural gas vented from the two-phase separator and three- phase heater treater and routed to the enclosed combustor using an operational continuous flow meter(s). The flow meter(s) must be installed, calibrated and maintained according to the manufacturer's specifications. The flow meter(s) must accurately measure and record the maximum and minimum potential rates of natural gas vented from the two-phase separator and three-phase heater treater. 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 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) Page 3 of 10 40'71CCLORADO ' ( Air Pollution Control Division C6PHd Lrs:5torrte+"it cae PutO ttealtti&rrtrnrr-wrre-a Dedicated to protecting and improving the health and environment of the people of Colorado 12. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by 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. 14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (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&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the commingled natural gas vented from the two-phase separator and three-phase heater treater in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, hydrogen sulfide and 2,2,4-trimethylpentane content(weight fraction)of this emission stream. The sample shall be collected prior to the inlet of the enclosed combustor and prior to being combined with any other stream. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must Page 4 of 10 COLORADO Mr Pollution Control Division COPH D arvne+}1 o4 Pubic Health b tr r*rutte^A Dedicated to protecting and improving the health and environment of the people of Colorado be submitted- to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 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. All previous versions of this permit are cancelled upon issuance of this permit. 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,r per year,a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. Page 5 of 10 -�»�-�c ' C O L O R A D O COiH€ I Air Pollution Control Division ( C tuntnt o+Pubis:Ffeairf C Ftivircnrrie`i; Dedicated to protecting and improving the health and environment of the people of Colorado 20. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 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. Page 6 of 10 _, »•- . COLORADO Air Pollution Control Division CDPH D qr{7er11 ex'Ruble f fealrh f7 EtIv r 0rvrte*n Dedicated to protecting and improving the health and environment of the people of Colorado 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 May 22, 2018 Issued to Extraction Oil Et Gas, Inc. Issuance 2 This Issuance Issued to CCRP Operating Inc. Decrease process limit from 68 MMscf/year to 11.4 MMscf/year. Update emission limits. Correct emission factors. Include initial testing. Page 7 of 10 COLORADO Air Pollution Control Division CDFHE D%aarithetll Publ:Health b tapir,_nrrie-:: 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) (ib/yr) Benzene 71432 295 15 Toluene 108883 369 19 Ethylbenzene 100414 90 5 003 Xylenes 1330207 205 11 n-Hexane 110543 4,003 201 2,2,4- 540841 4 1 Trimethylpentane Hydrogen Sulfide 7783064 17 1 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO 44400 �. Air Pouttution Control Division COP 0. .ofirrteni of Pubic.Neallit Er thvvs art Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point OO3: Process 01: Natural gas vented from the two-phase separator and three-phase heater treater and routed to the enclosed combustor(s) Uncontrolled Controlled CAS # Pollutant Weight Emission Emission Source Fraction of Factors Factors Gas (%) lb/MMSCF lb/MMSCF CO --- 468.17 468.17 AP-42 Chapter 13.5 VOC 44.67 32,076.66 1,603.83 71432 Benzene 0.036 25.85 1.29 Gas Analysis 108883 Toluene 0.045 32.31 1.62 110543 n-Hexane 0.489 351.14 17.56 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%: The VOC and HAP emission factors listed above are based on a commingled site specific two-phase; separator and three-phase heater treater extended gas analysis obtained on 12/20/2016. The weight % values and molecular weight (27.215 lb/lbmol) from the sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10)were used to determine the emission factors. The CO emission factor listed in the table above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor (0.31 lb/MMBtu) by a higher heating value of 1,510.237 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total metered two-phase separator and three-phase heater treater gas vented to and combusted by the enclosed combustor. Process O2: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) CO 468.17 468.17 AP-42 Chapter 13.5 Note: The CO emission factor above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor(0.31 lb/MMBtu) by a higher heating value of 1510.237 Btu/scf.Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 50 scf/hr. There is one enclosed combustor equipped with a single pilot light that controls emissions from this source. The total volume of pilot gas flow is determined by monitoring the hours the enclosed combustor operates with an operational pilot light. Total actual emissions are obtained from the sum of emissions resulting from the natural gas vented from the two-phase separator and three-phase heater treater and routed to the enclosed combustor(s) (process 01) and the combustion of pilot light gas (process 02). Page 9 of 10 ( COLORADO Mr Pollution Control Division CDPHE Dtt Pubs_N atiti 6 .rv?r=^Y€trit- : Dedicated to protecting and improving the health and environment of the people of Colorado 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, n-Hexane it Total HAP PSD 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 website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A- Subpart KKKK 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 ffi COLORADO Air Pollution Control fivision PD HE me:�i C PvC3e Meakh 6 tneroxuYan Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 9WE0076 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: Cox 22-B Plant AIRS ID: 123/9E51 Physical Location: NENW SEC 22 T12N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description One (1) Enclosed Cox#5 Natural gas venting from one (1) two-phase Combustor (Make Enclosed 007 separator and one (1) three phase heater Crimson Energy, LLC, Flare treater. Model: CE-1000, SN: CE1000-CCRP-0118) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify Page 1 of 15 ICOLORADO Air Pollution Control Division ("14_.. .... rrt '3 Rubs Heflin 'flarXFrrte.': Dedicated to protecting and improving the health and environment of the people of Colorado compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section ll.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type Cox #5 007 9.2 57.3 41.9 Point Enclosed Flare Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice Page 2 of 15 COLORADO Air Pollution Control Division GDPH[ Dedicated to protecting and improving the health and environment of the people of Colorado (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.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Emissions from the two-phase separator and Cox#5 three-phase heater treater are routed to Enclosed 007 one (1) enclosed combustor (Make: Crimson VOC and HAP Flare Energy, LLC, Model: CE-1000, SN: CE1000- CCRP-0118) 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, Section II.A.4.) Process Limits Facility AIRS Process Equipment Point Process Parameter Annual Limit ID Cox#5 01 Natural gas vented from the two-phase Enclosed 007 separator and three-phase heater treater 178.5 MMSCF Flare and routed to the enclosed combustor 02 Combustion of pilot light gas 0.2 MMSCF The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator must continuously (i.e. at least once every 15 minutes) monitor and record the volumetric flow rate of natural gas vented from the two-phase separator and three- phase heater treater and routed to the enclosed combustor using an operational continuous flow meter(s). The flow meter(s) must be installed, calibrated and maintained according to the manufacturer's specifications. The flow meter(s) must accurately measure and record the maximum and minimum potential rates of natural gas vented from the two-phase separator and three-phase heater treater. 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. Page 3 of 15 �,,rt ! COLORADO '" I Air Pollution Control Division CDPH DeDaHirm,It C.:0 Pubie tf lth 5 utwtrt,^ovne^a Dedicated to protecting and improving the health and environment of the people of Colorado 11. On a minimum of an hourly basis, the owner or operator shall monitor the control device for the presence of a pilot light and an operational auto-igniter. These monitoring records shall be used to calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto-igniter, the flow volume from the two-phase separator and three-phase heater treater shall be assigned a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years, and a summary of monthly pilot light downtime and vapor flow during pilot light downtime shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. 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) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 15. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by 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. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 17. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (0&M) plan and record keeping format approved by the Division, in order to Page 4 of 15 COLORADO 140 Air Pollution Control Division cop . rw_:51. Pubtx:Health E,:rivirmliirttr,a Dedicated to protecting and improving the health and environment of the people of Colorado 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 18. The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the commingled natural gas vented from the two-phase separator and three-phase heater treater. The sample shall be analyzed for gross (higher) heat content and total VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, hydrogen sulfide, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. The sample shall be collected prior to the inlet of the enclosed combustor and prior to being combined with any other stream. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies, 19. Within one hundred and eighty days (180) of the issuance of this permit, the owner or operator shall conduct an initial source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98%for VOC for each operating scenario. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • flow rate of natural gas vented from the two-phase separator and three-phase heater treater and routed to the enclosed combustor; • combustion chamber temperature; • pilot gas flow rate; • Gas heat content at the inlet of the control device; Page 5 of 15 COLORADO Mr Pollution Control Division CDP wi L tune F00 Pubes Ftes1ih Er ErwuritYte,A Dedicated to protecting and improving the health and environment of the people of Colorado • Gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-M0)/M; The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. Results of the initial compliance test must be submitted to the Division as part of the self-certification process. If the results of the initial compliance test do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. (Regulation Number 3, Part B., Section III.G.3.) Periodic Testing Requirements 20. On an annual basis, the owner or operator must complete a site specific extended gas analysis ("Analysis") of the commingled natural gas vented from the two-phase separator and three- phase heater treater. The sample shall be analyzed for gross (higher) heat content and total VOC content (weight fraction) of this emission stream. The sample shall be collected prior to the inlet of the enclosed combustor and prior to being combined with any other stream. Periodic sampling shall be conducted at a minimum of at least one hundred and eighty (180)days apart. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 21. At least once every 12 months, the owner or operator shall conduct a source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario. Periodic testing shall be conducted at a minimum of at least one hundred and eighty (180) days apart. During the test, the owner or operator must measure: Page 6 of 15 a - r. ' COLORADO Air Pollution Control Division CDPHH D >a tt*Ie'W C Pub1Y.Health$tnor,..rtrie^1 Dedicated to protecting and improving the health and environment of the people of Colorado • mass emission rates of VOC at the inlet of the control device (M1) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • flow rate of natural gas vented from the two-phase separator and three-phase heater treater and routed to the enclosed combustor; • combustion chamber temperature; • pilot gas flow rate; • Gas heat content at the inlet of the control device; • Gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M1-Mo)/M1 The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. If the results of the periodic compliance tests do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Records of annual compliance tests must be maintained by the owner or operator for a minimum of five (5) years and made available to the Division for inspection upon request. (Regulation Number 3, Part B., Section III.G.3) ALTERNATE OPERATING SCENARIOS 22. The control device may be replaced with a like-kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like-kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this construction permit. The owner or operator shall maintain a log on-site or at a local field office Page 7 of 15 _ COLORADO *PP Air Pollution Control Division GDPHE 3 reer.aitirne,a c.1 Pubk Health it t, 'r.,rrrierfl Dedicated to protecting and improving the health and environment of the people of Colorado to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 23. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternative Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternative Operating Scenario and has replaced the control device. 24. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternative Operating Scenario provision, the owner or operator shall conduct a source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • flow rate of natural gas vented from the two-phase separator and three-phase heater treater and routed to the enclosed combustor; • combustion chamber temperature; • pilot gas flow rate; • Gas heat content at the inlet of the control device; • Gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-M0)/M; The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations Page 8 of 15 ' COLORADO 40 ewe Air Pollution Control Division ia . € Detvrtt,lent Putte Hearts b teentht Dedicated to protecting and improving the health and environment of the people of Colorado and Records section of this permit. If the results of the periodic compliance tests do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Records of compliance tests must be maintained by the owner or operator for a minimum of five (5) years and made available to the Division for inspection upon request. (Regulation Number 3, Part B., Section III.G.3) ADDITIONAL REQUIREMENTS 25. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 26. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS Page 9 of 15 ' COLORADO Air Pollution Control Division crW€ "... -` 1 ritr1.1 P'ub3K.Hoolth7 Ea EnterCWien: Dedicated to protecting and improving the health and environment of the people of Colorado 27. 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. 28. 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. 29. 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. 30. 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. 31. 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. 32. 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. 33. 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. Page 10 of 15 ' COLORADO *40 Air Pollution Control Division GDPHE Di4k?rar"i Cy'Pubbc Health Er.r_rYuircigtriee,1 Dedicated to protecting and improving the health and environment of the people of Colorado By: Harrison Slaughter, P.E. • Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to CCRP Operating Inc. Permit for one (1) two-phase separator and one (1) three-phase heater treater at an existing synthetic minor oil and gas well production facility. Page 11 of 15 *- ! COLORADO ' ! Aar Pollution Control Division CDFHff E E erne,a o'Pubix.hiealfft b Er v,rervrreo 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) (Ib/yr) Benzene 71432 4,615 93 Toluene 108883 5,768 116 Ethylbenzene 100414 1,410 29 007 Xylenes 1330207 3,205 64 n-Hexane 110543 62,679 1,254 2,2,4- 540841 54 1 Trimethylpentane Hydrogen Sulfide 7783064 257 6 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 12 of 15 ' COLORADO Air Pollution Control Division CDPHE Dearahrhent o'PubIK Health t,cnyIrcrrrIe-a Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 007: Process 01: Natural gas vented from the two-phase separator and three-phase heater treater and routed to the enclosed combustor. Uncontrolled Controlled CAS # Pollutant Weight Emission Emission Source Fraction of Factors Factors Gas (%) lb/MMSCF lb/MMSCF CO --- 468.17 468.17 AP-42 Chapter N0x --- 102.7 102.7 13.5 V0C 44.67 32,076.66 641.53 71432 Benzene 0.036 25.85 5.17x10-1 108883 Toluene 0.045 32.31 6.46x10-1 100414 Ethylbenzene 0.011 7.9 1.58x10-1 Gas Analysis 1330207 Xylene 0.025 17.95 3.59x101 110543 n-Hexane 0.489 351.14 7.02 7783064 Hydrogen Sulfide 0.002 1.44 2.87x10-2 Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 98%. The V0C and HAP emission factors listed above are based on a commingled site specific two-phase separator and three-phase heater treater extended gas analysis obtained from the Cox 1 well on 12/20/2016.The weight%values and molecular weight(27.215 lb/lbmol)from the sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10) were used to determine the emission factors. The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors(0.068 lb/MMBtu and 0.31 lb/MMBtu) by a higher heating value of 1,510.237 Btu/scf. Actual N0x and CO emissions are calculated by multiplying the emission factor in the table above by the total metered two-phase separator and three-phase heater treater gas vented to and combusted by the enclosed combustor. Actual VOC and HAP emissions must be calculated using the following equation: 1 VOC&HAP Actual Emissions = [(Vtotal —VPLx) X (EFcontrolled)] "�' [(VPLx) X (EFuncontrolled)] Where: • VOC Et HAP Actual Emissions in the equation above have units of lbs/month • Vtotal =Total metered monthly volume of gas vented from the two-phase separator and three- phase heater treater and sent to the control device during the month (MMscf/month) • VPLx= Total metered volume of gas vented from the two-phase separator and three-phase heater treater and sent to the control device while the pilot light is not lit/operational (MMscf/month) • EFcontrolled = Controlled emission factor listed in the table above for Process 01 (lb/MMscf) • EFuncontrolled = Uncontrolled emission factor listed in the table above for Process 01 (lb/MMscf) Page 13 of 15 -��- COLORADO Air Pollution Control Division CDPHE I Dmt ntrieeI f?°Pubix:Health h b rwrr- rimed Dedicated to protecting and improving the health and environment of the people of Colorado Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) CO 468.17 468.17 AP-42 Chapter 13.5 NOx 102.7 102.7 AP-42 Chapter 13.5 Note: The NOx and CO emission factors above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a higher heating value of 1510.237 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 22 scf/hr. There is one enclosed combustor equipped with a single pilot light that controls emissions from this source. The total volume of pilot gas flow is determined by monitoring the hours the enclosed combustor operates with an operational pilot light. Total actual emissions are obtained from the sum of emissions resulting from the natural gas vented from the two-phase separator and three-phase heater treater and routed to the enclosed combustor (process 01) and the combustion of pilot light gas (process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane Et Total HAP PSD 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 website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK Page 14 of 15 ( COLORADO Air Pollution Control biviaion iDPN Dedicated to protecting and improving the health and environment of the people of Colorado NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 15 of 15 .•4, COLORADO Air Pollution Control Division Del ?trtiefli S?Put'3k tie 'B critiinxrrtlr+r, Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0077 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: Cox 22-B Plant AIRS ID: 123/9E51 Physical Location: NENW SEC 22 T12N R64W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Equipment Description Emissions Control ID Point Description Hydrocarbon liquid loadout from Loadout 002 storage vessels to tank trucks using None 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 (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 10 , COLORADOu o Air Division CDPHE C irnenl co Fulda_Healtl i b InvIrkxrne a 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.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Tons per Year Emission Point PM2.5 NO, VOC CO Type Loadout 002 --- --- 13.8 --- 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. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 10 ",-ts. COLORADO 40""' Air Pollution Control Division CDPHE DeortrneII(Y'Puti/'NeaRti E_rivirC41stle'7i Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 7. 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. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit ID Point Loadout 002 Hydrocarbon liquid 265,472 barrels loaded 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 8. 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) 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. Page 3 of 10 ICOLORADO AuPollution Comrot Division OP IF Oec a Ceu Puttr Heel'6'crl4"JrOtirtle T. Dedicated to protecting and improving the health and environment of the people of Colorado • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 12. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 13. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • 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 toss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 14. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 15. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. Page 4 of 10 ! COLORADO AF Pollution Control Division t1"146 ritvatIrrivellC PI.blO F'iC i}t&:S7V'reerr'1u:"a'. Dedicated to protecting and improving the health and environment of the people of Colorado • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 16. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 17. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 18. This source is not required to follow a Division-approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Existing Number Emission Point New Emission Point Page 5 of 10 O is , Air Pollution Division ©PHE - x Dee 3ttrnen o Put O FteatUi 6 Iariitia-Jrtex'd Dedicated to protecting and improving the health and environment of the people of Colorado GP07 123/9E51/002 123/9E51/002 22. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) 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. 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. 23. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 24. 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 6 of 10 k� COLORADO ( Air Pollution Control Division CDPH I Elesxrattie•a d PuLfr He&Erii$ ri:ry Ie'1 Dedicated to protecting and improving the health and environment of the people of Colorado 25. 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. 26. 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. 27. 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. 28. 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. 29. 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. 30. 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: Harrison Slaughter, P.E. Permit Engineer Page 7 of 10 aw COLORADO Mr Pollution Control Division CDPHE De6.1Tirnell 6 Pubic HeaAt1 l_rlv reftrnk'"71 Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issued to CCRP Operating Inc. Issuance 1 This Issuance Permit for hydrocarbon liquid loadout at an existing synthetic minor well production facility. / Page 8 of 10 ICOLORADO I Air Pollution Control Division • CDPHE a € Det.rltrle,i1 o Pubic'Health b Eriy'ro rnt-1 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 48 48 002 n-Hexane 110543 425 425 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: Point 002: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl VOC 1.04x10-1 1.04x1O1 CDPHE PS Memo 14-02 n-Hexane 110543 1.60x10-3 1.60x10-3 CDPHE PS Memo 14-02 Note: The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14- 02 for crude oil loadout. Actual emissions must be calculated by multiplying the emission factors in the table above by the hydrocarbon liquid loadout throughput. Page 9 of 10 COLORADO Air Pollution Control Division MPH I Ellant Path::t reaun&alvtrcTimea Dedicated to protecting and improving the health and environment of the people of Colorado 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, n-Hexane Et Total HAP PSD 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 website listed below: http://www.ecfr.Q0v/ 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 • ICOLORADO Air Pollution Control Division E Decenmerd a%%Ur_Health B rrtviro me, Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0634 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: Cox 22-B Plant AIRS ID: 123/9E51 Physical Location: NENW SEC 22 T12N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description TNK 1-5 001 Five (5) 500 barrel fixed roof crude,oil Enclosed storage vessels. Combustor(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 a- , , -*".1. ICOLORADO DPHE Air Pollution Control Division i C ..Naq felt 0,?utd�_I-feelI6Envtru rle-a Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type TNK 1-5 001 --- --- 5.2 3.6 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 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.) Page 2 of 10 .r COLORADO I Mr Pollution Control Division ©PHE I i D t,DHHIe,1t o Pubbr i fealni&trlviret,irle*"1 Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Pollutants Equipment Point Control Device Controlled ID TNK 1-5 001 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Process Parameter Annual Limit ID 01 Crude Oil 275,283 barrels TNK 1-5 001 Throughput 02 Combustion of pilot 0.3 MMSCF light gas 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. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. Page 3 of 10 •, ( � Lu tRAQtion oOl ivision CDPHE - D car-1rrw,it a'?ubi_Healdl&Irv{ra4,ot'-",t Dedicated to protecting and improving the health and environment of the people of Colorado 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 16. Upon startup of this point, 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 OftM 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. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator must complete site specific sampling including a compositional analysis of the pre-flash pressurized crude oil routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. The pre-flash pressurized crude oil sample must be obtained from the outlet of the heater treaters. Testing must be in accordance with the guidance contained in PS Memo 14-03. Results of the analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/bbl crude oil throughput) using Division approved methods. Results of the analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Page 4 of 10 - COLORADO Mr Pollution Control Division DPHE [ DeDWIttlwltd Pubic We91tli& ri rccin -t? Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Existing Number Emission Point New Emission Point GP08 123/9E51/001 123/9E51/001 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) 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. 21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). Page 5 of 10 COLORADO M Pollution ol ivision GDPH D r rne•tt c7"PuGly_Ffe3frfr&ErPortxrrleoll Dedicated to protecting and improving the health and environment of the people of Colorado GENERAL TERMS AND CONDITIONS 22. 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. 23. 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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. Page 6 of 10 le , COLORADO Air Pollution Control Division CDPHE Dete,ltrient "PuGig_HeaaSh b crivt�ivtl�7 Dedicated to protecting and improving the health and environment of the people of Colorado By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to CCRP Operating Inc. Permit for crude oil storage vessels at an existing synthetic minor oil and gas well production facility. Page 7 of 10 _, ...„,,,.. Air, COtion LORADO R A D Control Division CDPHE Dts.NaRrtle•:1&PuLlO He'.tllh b Lr 'rcrr ns 11 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 642 32 Toluene 108883 470 . 24 Ethylbenzene 100414 17 1 001 Xylenes 1330207 221 11 n-Hexane 110543 5,522 276 2,2,4- • 540841 539 27 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: Point 001: Process 01: Crude oil throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 2.52x10-2 2.52x10-2 AP 42 Chapter 13.5 Page 8 of 10 v. # COLORAt O I Mr Pollution Control Division CDPHE C *;tTie+11 u"PutIa_tin b uiv�nxvntr 1 Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 7.521x10-1 3.76x10-2 71432 Benzene 2.33x10-3 1.16x10-4 108883 Toluene 1.70x10-3 8.52x10-5 ProMax Et EPA 110543 n-Hexane 2.006x10-2 1.0x10-3 Tanks 4.09D 540841 2, 1.96x10-3 1.96x10-3 9.78x10-5 Trimethylpentane Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%.The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with ProMax and EPA Tanks 4.09d. The pressurized liquid sample was obtained from the outlet of the heater treater for the Cox 1 well on 02/13/2017 and used as an input for the ProMax simulation to estimate flash emissions.The sample temperature and pressure are 52°F and 24 psig respectively. Working and breathing emissions were estimated using EPA Tanks 4.09d. This simulation uses Denver, CO for the location basis and crude oil (RVP 5) for the liquid basis.The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using a GOR of 23 scf/bbl and heat content of 3535 Btu/scf. Actual emissions must be calculated by multiplying the emission factors in the table above by the total crude oil throughput. Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) CO 468.17 468.17 AP-42 Chapter 13.5 Note: The CO emission factor above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor(0.31 lb/MMBtu) by a higher heating value of 1510.237 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 17 scf/hr.There are two enclosed combustors each equipped with a single pilot light that control emissions from this source. As a result, the total pilot light gas fuel flow is 34 scf/hr.The total volume of pilot gas flow is determined by monitoring the hours the enclosed combustors operate with operational pilot lights. Total actual emissions are obtained from the sum of emissions resulting from the crude oil throughput (process 01) and the combustion of pilot light gas (process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each Page 9 of 10 aCiDPNE .. ...„„...:,. COLORADO OL C R A Dol Division [3eAiPTr5er,t 0 Pub hfeelttt 6€rhricrsrte-d Dedicated to protecting and improving the health and environment of the people of Colorado 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, n-Hexane 8 Total HAP PSD Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A- Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 ‘„., , ' COLORADO ( Air Pollution Control Division GDPH6 I D irrtere 0"PutbI tfeaMI b Irmn_rf'fl c1 Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0635 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: Cox 22-B Plant AIRS ID: 123/9E51 Physical Location: NENW SEC 22 T12N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID PW 1-3 004 Two (2) 500 barrel and one (1) 100 barrel Enclosed fixed roof produced water storage vessels. Combustor(s) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 4, : COLORADO Air Pollution Control Division COPNC. _• Deoa,ittieni o%UIr Flea Rh b Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type PW 1-3 ` 004 --- --- 1.8 2.3 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 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.) Page 2 of 10 ".� Air Pollution control Division tvf C ctrttett Putar Health L Ittarrurrrrre-a Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Pollutants Equipment Point Control Device Controlled ID PW 1-3 004 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Process Process Parameter Annual Limit ID Point Produced Water 01 265,472 barrels PW 1-3 004 - Throughput 02 Combustion of pilot 0.2 MMSCF light gas 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. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. Page 3 of 10 COLORADO 440 Air Pollution Control Division CDPHe ,• *ae71-11 o Pubir.-Elul[}1 Er CClvirvc'm Dedicated to protecting and improving the health and environment of the people of Colorado 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Existing New Emission Point Number Emission Point GP08 123/9E51/004 123/9E51/004 Page 4 of 10 COLORADO Air Padlution Control Division DeovIrriell it Lla Health E alr tufrne Dedicated to protecting and improving the health and environment of the people of Colorado 20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 22. 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. 23. 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 Page 5 of 10 0 ( COLORADO Mr Pollution Control Division C©PHE Deceor tent 0'Pubic_FICLI!Ii 6 Et7htK.unt-i Dedicated to protecting and improving the health and environment of the people of Colorado 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. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to CCRP Operating Inc. Permit for produced water storage vessels at an Page 6 of 10 je ...844_ 1.~ ti PL r Pol. u ti R tion /�►Controf Division MPHF CatOme�3S GY'FuGfse Health Er Lf+virCtiYrle'11 Dedicated to protecting and improving the health and environment of the people of Colorado existing synthetic minor well production facility. Page 7 of 10 , COLORADO Air Pollution Control Division CDPHE Dee rirrient a`PubIx:tfealrti 6_pArt+vnent 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 alt 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 - (Ib/yr) (lb/yr) Benzene 71432 1,859 93 004 n-Hexane 110543 5,841 292 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: Point 004: Process 01: Produced Water Throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 1.67x10-2 1.67x10-2 AP-42 Chapter 13.5 VOC 2.62x10 ' 1.31x10 2 CDPHE PS Memo 14-03 71432 Benzene 7.0x10-3 3.5x10-' CDPHE PS Memo 14-03 110543 n-Hexane 2.2x10-2 1.1x10-3 CDPHE PS Memo 14-03 Page 8 of 10 -""Abp"' 1' COLORADO Air u tion toDivision Detxiarr tent 0'Pubic-Health C trpert_ ine,a Dedicated to protecting and improving the health and environment of the people of Colorado Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-03 for produced water storage vessels in Weld County. The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) were converted to units of lb/bbl using a heat content of 1,496 Btu/scf and gas-to-water ratio (GWR) of 36 scf/bbl. Actual emissions must be calculated by multiplying the emission factors in the table above by the produced water throughput. Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) CO 468.17 468.17 AP-42 Chapter 13.5 Note: The CO emission factor above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor(0.31 lb/MMBtu) by a higher heating value of 1510.237 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 17 scf/hr. There is one enclosed combustor equipped with a single pilot light that controls emissions from this source.The total volume of pilot gas flow is determined by monitoring the hours the enclosed combustors operate with operational pilot lights. Total actual emissions are obtained from the sum of emissions resulting from the produced water throughput (process 01) and the combustion of pilot light gas (process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane a Total HAP PSD Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: Page 9 of 10 COLORADO qpAir Pollution Control Division oi%),agrne-it Puitr_HeaRti$-rIvIrivlrien1 Dedicated to protecting and improving the health and environment of the people of Colorado httg://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 u For Division Use Only I_ Review Engineer: Harrison Slaughter Package#: 386248 Received Date: 11/9/2018 Updated APEN received on 01/28/19&updated calculations received 06/21/19 Review Start Date 4/11/2019 Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township Range County AIRS ID: 123 NENW 22 1214 64 Plant AIRS ID: 9E51 Facility Name: Cox 22-B au xr ryF '� Physical Address/Location: County: Weld County Type of Facility: Exploration&Production Well Pad What industry segmentiOil'&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? No If yes,for what pollutant? Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point k Permit (Leave blank unless Emissions (Leave blank unless Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already Issuance# Required? Action Remarks assigned) assigned) Permit 003 Separator Venting Cox#1 Enclosed Flare Yes 16WE0646 2 Yes Modification Section 03-Description of Project CCRP Operating Inc.(CCRP)submitted an application requesting to modify an existing synthetic minor oil and gas well production facility located in the ozone attainment area.The following items are being updated with this application: 1.Transfer ownership of the facility from Extraction Oil&Gas Inc.to CCRP. 2.Decrease the requested process limit from 68 MMscf/year to 11.4 MMscf/year. 3.Correct the emission factors in the notes to permit holder section. 4.Include initial testing. New synthetic minor limits are being established at this facility.As a result,all the sources covered by individual permits will be sent through the public comment process. Additionally,the self-certification was submitted for this source on 11/09/18 and was approved by the self-certification coordinator on 12/05/18.However,this permit will require the operator to obtain an initial sample and submit it as part of the self-certification process.As a result,the permit will be re-issued as initial approval. 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 OS-Ambient Air Impact Analysis Requiremer 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(P5D) ❑ ❑ ❑ 0 ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ (] ❑ DOB Non-Attainment New Source Review(NANSR) ❑ ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review(NANSR) ❑ ❑ Secar/cil Veruticcg Emissions/rive_-ocp Section 01-Administrative Information 3E51 003 Facility AIRS ID: County3 pant Point Section 02-Equipment Description(Mugs Detailed Em sslotu De N taro-phase from one(1)taroh separator and one(l)Mreephaue heater treater. Unite non. Enclosed Combusfor(z) Emission Control Device Description' Requested Overall VOC&HAP Control Efficiency°a: 45 United Process Parameter Natural Ga8Ventrs{,y` -. p' Gas meter Wes,meterts careptl T Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput 9.5 MMscf per year Requested Permit Imuffihrouffipute 11.4 MMscf per year Requested MonthlyThroughput= -.. MMscf per month Potential to Emit(PTE)Tluoughput A t.•:MMscf per year Secondary Emissions-Combustion Devicels)for Air Pollution Control Separator Gas Heating Value: 1510.2 BILdscf Volume of waste gas emitted per 661, liquidsthroughput y v scf/bbl Control Device Pilot Fuel Use Rate: - '50'scfh -- MMscf/yr Mot Fuel Gas Heating Value: 1510.2 Btu/scf :MMBtU/yr O Section 04-Emissions Factors 8 Methodoloelez Description TheCox)well(4114 05-123-41963)produces to one Miele two.phase separator.Mixed liquid from the two-phase separator U[hen routed to one(1)heater treater farthree-phase separNon.lhe gas resulting from the two-phase separator and Mree. phase heater treater is routedMend controlled by an enclosed combustor.Asite specific commingled...phase separator and three-phase heatertreater sample was obd1ed from the faculty on 12/20/2016.The sample temperature and pressure were not provided.The weight%velum and molecular weight from the sample along with Me displacement equation(sfwvm helms)were used to estimate emissions from MB source. (MW I 27.215llb/Ib-mot Displacement Equation Ex=ec PAW•Xx/C .rl Weight _ 0 Hydrogen Sulfide 0.00 X2:9562 CO2 4.78 04091 N2 1.46 59.4411 methane 35.04 - - 12.7129 ethane 14.05 14931fi propane 2322 ..._ - .1..79 IsOhutane 336 .00010e 10.60 0.8989 isopentane 238 _ 0.9425 e 2:50 _... .0.0505 ryc�pentane 0.13 0.49 cyclohexane 0.06 -- Other hexanes 0.70 -,.i. .0.0241 , heptanes 0.01 0.016 methNcyclohexane 0.09 224-TMP 0.(10 Benzene 0.04 Toluene 0.05 - 0.0134 Ethylbeitzene 0.01 0.0028 Xylenes 0.03 - - 0.0064 CM Heavies 0.13 Total 0.0001 VOCWI% Emissmn Factors for Venting Uncontrolled Controlled Con rolled Pollutant (Ib/MMsc0 Ilh/MMscf) Emission Factor source (Gas Throughput) (Gas Thrmughp4tl VOL Extended gas analysis Benzene [treaded gas analysis Toluene Extended gas analysis EMylbenzene Extended,analysis Xylene - Extended gas analysis Extentr,essanalysis 224 TINP Extruded gas analysis Hydrogen Sulfide :272ndedgas analysis Primary Control Owl, Uncontrolled Uncontrolled - Pnllutant (Ib/MM9tu) 15/MMscf [mission Ezctmr source (Waite Heat Combusted) (Gas Throughput) MOO 0.0075 . - - 4,42,6(01.4.(PM10/pM.2.5) PM25 0.0071 HP421 6.1.4-2 ffilV110/PM.2.5) 503 0.0010 Dater Txphin 503 0.0100 AP-42 Chapteri3.5 Industrial.,fl re CMOs)(C0( CO 0.3300 --,- AP�tlsa�1351odusvlal Flares(CO) Pilot tight Emisai0ns Uncontrolled Uncontrolled Pollutant (Ib/MMBt0l Ib/MMscf Emission Factor source (Waste Heat Combusted) (Pilot Gas Th r0ughput) PMIO 0,0075 - BM20/PM.2.5) ,42.5 0.0075 - 30/PM:2.5) SOx 0.0006 2(50x) NOx 0.0680 al Hares(Nix) VOC 00054 4-2ND[) CO 03100 'ustrial Places(CO) Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly limits Criter2 Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/Marl (00rrs/year) (tors/year) (tons/year) (tons/year) (Ibs/month( FM10 . .,. PM2.5 (I.1G' ..r 50x J.015 , NOx 0.18 _" VOC 1.1121 CO P400,014100 Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (155/year) (lbztyaarl Ills/vearl 1150/,ear) Ills/year) Benzene TolueneEthylbenzene XYlene ) .. - '-Hexane 401.47 2241M1 .. .. 0-i1 Hydrogen 51114e 2 of C:\Users\hslaught\Desktop\123961\16WE0646.83 section O6-Reef:Wary Summary Analysts Regulation 3,Parts A,B Regulation 2,Part Cl,Section 11.9,F Regulation 7,Part°,Section ll.B.2e �_..., ... (See regulatory applicability worksheet for detailed analysis) Section 02.thMal and Periodic Sampling and Testing Requirements Using Gas Throughp.to Monitor Compliance Does the company use site specific emission(-attars based an 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 le.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"toitalTesting Requirement"to collect a site-specific gazsample from the equipment being permitted and conduct anemissionfactor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with Mrs application ms Are fat Illy w de permitted emissions of VOC greater than or equal to 40 tom per year in the ozone nonatta omen?area • OR are emissions greater than or equal to 90 tons per year In the ozone attainment area? If yes,the permit will contain: nMetrestlng Requirement"to coll.ta site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than orequal tothe emissions factors established with this application. • "Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct anemission factor analysis to demonstrate that the emission factors are less Manor equal to the emissions factors established with this application on an annual basis. NW the operator have a meter installed and operational upon startup of this point? lino,the permit will contains Conditanahat requires the operator to calculate gas throughput using the liquid throughput until the meter is installed andoperauonal(not to exceed leO days).This condition will use the"Volume ofwasre gas emitted per BBL of liquids throughput lscf/bbl)value In section 03. Ones the company request a control device eIciency greater than 9S%fore flare or combustion device? 70,,44.x „^ ° If yes,the permit will conin initial and periodic compliance testing in accordance with PS Memo 2002 • UN � ,� nip ';Y r " ..fit ,:.y.. i /Dif#R,..- q :. ....W Mme...:: ,.. .. (✓'r�,... ,. , r;„ KerlfialetaggiEi 3r: -ItelinL'iea'LI#iF 'i.,.,2,.s-IVIRO...: '- ,;..,.,fi"fY^.711 i Section 0a-Technical Analysis Notes se Based on the liquid n. two separator rucedtoasfeaier eat well mmheroo API numbaaare r o follows,ao)and r and hlaat1reatrer se ds:05-2or005 adedicliiedencl:Coxsed 5,API Number:separator eparat dad.heater treater vMkedunder to separate andte0phazs sepproduced the eyox 1omthe nly.Th ator routed ws abeurerrr sooe for ber2erzend begn Each ctior lot Oroarnber 205.er The Cootie 11 hasiotintoadotumd.eomsedmmbuothe.wbe modifi.and heategan prod00 onin 2015.Sder ine tht h005100ll ba producttl ett r Agusswellboth gas cor ig of the Cox 1separ Loran h ater eater is ubje tto COinoecembel2lPartD,S well has rot been refrxtured,recomple[ed..otherwise modified smcentbegan production in 2015.Since the Cox Swell began production alter August 1,2(114 the gas off the fox)separator t is subject to COAQCC Regulation art°,5ecUon 2.According to the application,a flow motor is installed and operational at the fachry.This Row meter only measure:the total two-phaase separator and three-phase heater treater gas produced from the Coal well, 3.The site specific sample used to espmateemistle s front this source was obtained from the facility on December 20,2015,This sample itrepresentasve of commigledtwo-phase and threephase separator gas.Additionally,the Cox well has not been refrazNred, ompleted,or otherwise mo6,hed since it began production In 2015,Asa result the sample is likely Mil ef emissions resuking from the well since it has lot been modified.However,initial sampling was deemed necessary and included in the permit for the following reasons:(I)The sample seas:Atained four years ago,so there is potential for the gas composition to have changed over that timefreme.(II)Facility wide permitted VOCemlsslons are very close to the 9otpy(89.9 tpyl threshold that results in initial and annual sampling.Due to Uhse reasvm,initial sampling was included in the permit toconfirm the emissions factors approved withthis application remain either ac{ivate or conservative. 4.There are no vapor recovery unfits(VRosfon location for separator gat As a.result,the operator has indicted the produced gas(min the two-phase separator and three-Ooze heater Neater is always routed to the enclosed combust.. 5.The previous issuance of this permitconverted the emission factors to units oftbfgtscf,but Incorrectly listed the units as Ih/MMscfin the rotes to permit holder.TMs was co0ected'm this issuance of the permit tithe heat content umdm.calculate NOx vsd CO emissions was taken tresHy from the sample analysis.The heat content calculation in the analyss demonstrates the methodology used to estimate heat content of the sample.While the calculations in this analysis do notmatch exactly with the value pnesentedon the sample report the difference is small enough to be considered negligible. 2.As indicated In Section 02above,facility-wide permitted VOL emissions are less than 90 My.As Indicated above,initial sampling will be included in the permit.However,annual sampling snot included iri the permit because:the facility wide permitted VOL emissions are less than 90 tpy, 9.The emission factor fors 005 was determined based on the assumptbn that 100%of the uncontrolled H2S emissions are converted to...The calculation to determine the 500 emission factor Is ae foltows:l1.436Y tie N2s/MMtofll64.oaalbsO211bmole)/(3408088 lb H25/Ibmoie)=22@/MMscf.TIus calculation method rezul onse eestmate ofSOx emissions compared to the 4242,mission factor of 0.616/MMset. 9.Benzere,toluene end n.hesane are the oNy HAP,above APEN reporting thresholds(>250 lb/year).As a result they are the only HA.for which emission factors are included in the permit. 10.NOx emissions are below APEN reporting thresholds(42 thy).Asa rasult,an emission lrmitand emission fa..for NOx aherwt included In the permit. I1.The NOS required by the firstissuasre of the permit was submitted to the Ofakionon 1SJo>/2018.Asa result,the NOS requirement hss been removed from this issuance of the permit Adgt.ialiy,the initial method 22opacity test was completed and included. with the self-certification submitted on 11/02/2018.Asa result,the initial opacity testing h.s teen removed from the permit - - 12.Periodic visible emissions checks for thernntml device are addressed by the ORM plan.Asa result the permit does not contain periodic opacity testing. :M.AVOC emission factor for pilot light combustion is not included in the permit bemuse the total VOC emissions associated with pilot light combustion are negligible)0.002 toy)and do not impact the oaerollVOC emissions. IA.Athroughput 11mit Is Included n the permt for pilot combustion.Emission factors andcalculatlon methods for pilot light combustion emissions are also included in the notes to permit holder.This informations inducted in the permit because pilot light emissions mntribute to the overall emissons from this source.Additionally It Is lmpottanttonclude this information because throughput traodngand emission calculation methods are different?tan those used to estimate emissions based on the condensate throughput This darlty is important for accurately quantifying actual emissions at this facility. 5.the operator was provided with admit permit and APEN redline to review prior to permit issuance.The operator reviewed both documents and expressed they had no comments. section 09-SCC Coding and Emissions Factors(For Inventory Use Only: AIRS Point. Process 4 5[code Pollutant Uncontrolled Emissions Factor Control% 003 01 MAIO P M2.5 SON -- _ VOC to Benzene Toluene Ethylbereaee - xyfen n-Hexane -224 IMP H25 3 of C:\users\hslaught\desktop\1239E51\u6WE064s.CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements .sour,...,,„i Op:Atta,su,cnt Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? Yes Source Requires an APES.Go to the next question 2. Are total facility uncontrolled VOC emissions greater than STPY,.NOx greater than 10TPY or CO emissions greater than 1O TPY(Regulation 3,Part B,Section 11.5.3)? Yes Source Requires a permit ISouite rl",Clteret a perm/ 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.I.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.5.2)? You tbet s ou rce is in the Atta k.lettt Ares - • Colorado Regulation 7,Part D,Section II 1. Was thew well newly constructed,hydraulically fractured r recompleted on or after August 1,2014? IYes. 'Source is subject,go to next question Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Emissions Control(Optional Section). a, Is this separator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? I{,,toraPAu.cvicc ruttiru si;rat'.0 to sir.ubl<,'.in PrIpriatitto,',Pat to'vu, , ,. Section II.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule 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/anguage 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 CCRP Operating Inc. County AIRS ID 123 History File Edit Date Plant AIRS ID 9E51 Ozone Status Attainment Facility Name Cox 22-B • 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 Flog CO Total REMARKS AIRS ID VOC HAPs VOC HAPs • Previous FACILITY TOTAL 0.1 0.1 0.0 0.0 14.5 1,146.1 0.0 38,0 36.8 0.1 0.1 0.0 0.0 4.7 72.8 0.0 18.4 2.1 Points 001-005 included in previous total. Previous Permitted Facility total 0.1 0.1 0.0 0.0 14.5 1,146.1 0.0 38.0 36.8 0.1 0.1 0.0 0.0 4.7 72.8 0.0 18.4 2.1 Points 001-005 included in previous total. 001 2.01/181.0,34 Nov(5)500 p.bl hied tool..rude rill slc,,1140 Modification-Add 000 208 bbl 510rage vcs0oi vessels 11 2 '102`. ;11 1 i 1 1 0 0.11 3 4 0.2 Update emission fa cto,s Update permit tlmm, Cancel UPOS 'I9W@.0077 Hyctroca,bon liquid 0010001 Cancel GPO and cover under rndovvtnuei permit. 13 11 117 0.2 Update throughput based on addition of new WOO. $1Yl"'1,(046 Natoclal gas 1100ltu from one(1)nee 1100se Decrease t'n coss hoot nom 1,8 MMihCI'toil 4 .n ator and one(1)three phaso heater 0.1 0,1 0 1,: 0.0 0.0 102# 3,8 2 6 ti Ia.1 O.{: O«13 2 8 0.1 MA/VSCF.Correct 8 080 loviode initial lest Eder ICcx#:) 1108 _(,.:....... .(Go(2)505 bbl and 000 i 1)100 hbi fined,00f Modrhr anon Add ens 080141 and one 1,1801a produced water storage vessels O.7 O 1 .. .. .„ 3 9 4 I • 0 5 1.0 2 3 Il,2 storage'vessel.Request trar,Lbonui Ireinni coverage.inr,,ease throughput. 0€')0 GP02 AU RIGA!!C.t,trnrl;irrs G5.8,4SRtt.58 HP.EN: '9',en:,tray vi,00mvrstttp room t:vts a bean CCM.., 73857873 Il.1 0..1 ._ 0,1 01 1.0 0.7 2 0 0 1 New i.+P02 appruvat hater...inn II-rtgme used ;as a Punt jack; Carl UP02 SI NICE Doosan D11.IL.4SRB,268 HP SN, No 01 SOW,e engnie uoed rer pOea,generation. 0 0 0.3 32 5 24 b 54 0.3 _ 1 9 11 t.4 EEIC 1706658 007 19VVE00'76 Natural gas venting from.one(1)two-phase New Swat:, aeprator and bare(1)three-phase heater 1.8 1.0 0,1 0.2,'. 11.2 2.882.8 .11 0 39.0 1 0 1 3 0 2 9 2 „a 41.8 0.8 treas0.,417,08#5) XA Separator Heaters 0.0 '0.0 0.4 0.0 0.4 0.0 0.0 0.0 0.4 0.0 0.4 0.0 Insignificant Source XA Fugitives 0.0 0.0 0.0 0.0 Insignificant Source 0.0 0.0 0.0 0.0 0.0 0.0 'FACILITY TOTAL VOC: Syn Minor(PSD and OP) • NOx: True Minor(PSD and OP) CO: True Minor(PSD and OP) 1.6 1.6 0.1 0.3 55.0 3,201.2 0.0 97.1 49.8 1.6 1.6 0.0 0.3 15.1 89.9 0.0 58.2 2.1 HAPS: Syn Minor(n-Hexane,Total HAP) HH: Area source-no affected sources 7777: Area source Permitted Facility Total 1.6 1.6 0.1 0.3 54.6 3,201.1 0.0 96.7 49.8 1.6 1.6 0.0 0.3 14.7 89.9 0.0 57.8 2.1 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions Modeling not required based on A change in 1.5 1.5 0.0 0.3 10.0 17.1 0.0 39.4 emissions.Pubcem is required b/c new syn minor limits are being established with this application. Total VOC Facility Emissions(point and fugitive) 89.96 Facility is eligible for GPO2 because 0 90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) 17.1 Project emissions less than 50 tpy Note 1 Note 2 • Page I of 2 Printed 8/4/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILI'T'Y EMISSION SUMMARY-HAPs Company Name Extraction Oil&Gas,LLC County AIRS ID 123 Plant AIRS ID 9E51 Facility Name Cox 22.5 Pad Emissions-uncontrolled(lbs per year) POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 20WE0634 Five(5)500 bbl fixed roof crude oil 642 470 17 221 5522 539 3.7 storage vessels 002 19WE0077 Hydrocarbon liquid loadout 48 425 0.2 003 16WE0646 Natural gas flaring from one(1)two- 295 369 90 205 4003 4 17 2.5 phase seprator and one(1)three-phase heater treater(Cox#1) 004 20WE0635 Two(2)500 bbl and one(1)100 bbl 1859 5841 3.9 fixed roof produced water storage vessels 005 GP02 SI RICE Cummins G5.9,4SRB,99 HP, 150 4 20.5 123 11 6 2...5 0.1 SN:73807873 006 GP02 SI RICE Doosan D11.1L,4SRB,268 HP, 601.3 61 d 771 46,5 89 8 0.4 SN:EEIOH706658 007 19WE0076 Natural gas venting from one(1)two- 4615 576B 1410 3205 62679 54 257 39.0 — phase seprator and one(1)three-phase heater treater(Cox#5) XA Separator Heaters 1 14 0.0 - XA Fugitives 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.4 0.1 0.0 3.8 3.3 0.8 1.8 39.2 0.1 0.3 0.1 0.0 49.8 I "Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text uncontrolled emissions<.de m:nlmus Emissions with controls(lbs per year) POINT IPERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H25 TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 20WE0634 Five(5)500 bbl fixed roof crude oil 32 24 1 11 276 27 0.2 storage vessels 002 19WE0077 Hydrocarbon liquid loadout 48 425 0.2 003 16WE0646 Natural gas flaring from one(1)two- 15 19 5 1I 201 1 1 0.1 phase seprator and one(1)three-phase heater treater(Cox#1) 004 20WE0635 Two(2)500 bb(and dne(1)too bbl 03 292 0.2 fixed roof produced water storage vessels 005 GPO) SI RICE Cummins G5.9,4SRB,99 HP, 150.4 20.5 19.3 11 6 _2.5 0.1 SN:73807873 006 GP02 SI RICE Doosan D11.1L,4SRB,268 HP, 601.3 51.6 77,1 4633 808 0.4 SN:EEIOH756656 007 19WE0076 Natural gas venting from one(1)two- 93 116 29 64 1254 1 6 0.8 phase seprator and one(1)three-phase heater treater(Cox#5) XA Separator Heaters 1 17 0.0 XA Fugitives 0.0 0.0 0.0 0,0 TOTAL(tpy) 0.4 0.1 0.0 0.2 0.1 0.0 0.0 1.2 0.1 0.0 0.0 0.0 2,1 2 1239091 0/4/2020 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details 0 For Division Use Only u Review Engineer: Harrison Slaughter Package 8: 390178 Received Date: 11/9/2018 Updated calculations received 06/21/19 Review Start Date: 8/22/2019 Section 01-Facility Information Company Name: CCRP Operating Inc. • Quadrant Section Township Range County AIRS ID: 123 NENW 22 12N- 64 Plant AIRS ID: 9E51 Facility Name: Cox 22-6 �-- .� Physical Address/Location: au qu,,,3nt Wit-, County: (Weld County l Type of Facility: Exploration&Production Well Pad -What industry segment>it&Natural Gas Production&Processing. - - Is this facility located in a NAAQS non-attainment area? No If yes,for what pollutant? Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already Issuance# Required? Action Remarks assigned) assigned) Permit Initial 007 Separator Venting Cox#5 Enclosed Flare Yes 19WE0076 1 Yes Issuance Section 03-Description of Project CCRP Operating Inc.(CCRP)submitted an application requesting to add a new source to an existing synthetic minor oil and gas well production facility located in the ozone attainment area.The following items are being requested with this application: 1.Transfer ownership of the facility from Extraction Oil&Gas Inc.to CCRP. 2.Add one new two-phase separator and one new three-phase heater treater to handle liquids produced from the new well drilled at this facility. Public comment is required for this permit because new synthetic minor limits are being established. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Fequesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer 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 s If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ D - O ❑ Title V Operating Permits OP) O O ❑ O O DOE Non-Attainment New Source Review(NANSR) ❑ ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) DODO ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ODD Non-Attainment New Source Review(NANSR) ❑ ❑ Section 0l-AdminlstraOve Information I007 FacilityAl.,O 23 961 County plan[ Point Section 02-Equipment Description Details Detailed Fmssons UntEesczpbon: Natural gas venting from one(1)two-phase separator and one(1)three-phase Heater treater. Emissian Control DCVICS Oscfiption: One(1)Enclosed fambusror(Make:Crimson Energy,1.1.Model:CE-1000,5th:CE1000-CCRP-01101 Requested Overall VOC&HAP Control Elhciency%: 90 limited Process Parameter Natural GasVented Gas meter Yes,meter%currently lnstalledrod operational r Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput- 56034062:2 MMscf per year Requested Permit Limit Throughput -52,6).6235476.5(MMser per year Requested Monthly Throughput= O. MMscf per month I - Potential to Emit(PTE)Throughput= -..MMscf per year Secondary Emissions Combustion Devlee(s)for Air Pollution Control Separator Gas Heating Value: 3510.2 Btu/scf Volume of waste gas emitted per RBI_of £• liquids throughput: Fyl scf/hbl Control Device Pilaf Fuel Use Rate: 22 scfh 5..ii MMscf/yr Pilot Fuel Gas Heating Value: 1510.237 Btu/scf 226.:MMBtu/yr ff Section 04-Emissions Factors&Methodolo¢ies scriptipn Th Coxhll .5(API k 0 12 3 419 3 we 5)produces to on(1)Inietw0 phaseseparator.Mixed liquid from the two phase seprators then routed to one(1)heatetreaterfor three-phase eparaton.TiTM gas esulting from the two-phase separator and three phase'Aeatertreater Is routedt0 and controlled by an enclosed combustor.Asite specific commingled twophase separator and three-phase heamr heater sample was ohtained from the Cox 1 well atthisfacltly en 12/20/2015...sample temperance and pressure were not provided:The weightXvalues and molecularweghtfrom the sample along with the displacement equation(shown below)were used to eslitrate emissions from Mrs source. IBM I 37.21511 biib-lOl Displacement Equation Ex=CO MW'X0/C -...,i. Weight% Hydrogen Sulfide 6, 2.9567 2 4.70 14411 N2 1.46 .+ 59,4411 methane 35.04 32.7]Z9 ethane 14.05 143336 M.P.. 23,22 1:5279 (sohuene 3.26 - 4.961 mbutane 10.60 0.8989 isopentane 238 0.9425 mpennne 2.50 - 0350 cydnpentane 0.13 - --.. 0.0377 ..: it-Hexane 0.49 . _ 0:2477 cydohexane 0,06 0.2073 Other hexanes 0.78 hePmnes 0.91 0.016 methylrydshexane 00043 0.09 i 22YTMP 0.00 0,0089 Benzene 0.. 0.0125 Toluene 0.05 0.0135 Ethylbenzene XVlenes 0.03 CM,Heavies 0.13 0.]543 Total __._ rM.0 VOC Wt 56 .':' — ' 0.0018 .. Emission Factors Separator Venting o :.nrO V,.,_..'e> Uncontrolled controlled Emissian Factor Source erica q'value es SSa, Pollutant (Ib/MMscf) (Ito/MMscf( (Gas Throughput) (Gas Throughput) VOC `+• Extended gas analysts Benzene fy Extended g Iy s Toluene = ...hiedg analysis Ethylbenzene Extended g analysis XVlene 'i. Extnna d Ras analysis n-Haxane - - X, Exedded gas analysis 224 TRAP .0.5 Extended gat analysts Hydrogen Sulfide kk Eafendedgm analysis nary Control Device wcgtr5llea Uncontrolled Pollutant (Ib/MM tut Ib/MMscf Emission Factor source (Waste Heat C ombusmdl (Gas Throughput) PM10 0.0075 AP-42 Table 1.42(PM10/PM.25).:: PM2.5 0.0075 AP-42 Table 1.4-21PMio/PM.7S) 905 0.0010 Other-Explain NOR .0680 4.42Chapter13 a t a1Fiares/hoo) Co 03100 .. AP-42001apter 00.5lorb.hialFlaras(C0) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ih/MMB0I Ib/MMscf Emission Factor Source (waste Heat C Ombustedl (Pilot Gas Throughput( PM10 0.0070 AP-42 TRIM,. PM2.5 0.0075 AP42 Tablel,4-2(0O10/PM.Z5) 50x 0.0006 AP-42Tabk 14.2(Soil NO5 0.080 AP47Chap0t045 industrial Harm Mx) 1100 0.0054 Ap-42 Table 1.40Z(VOC) CO 03100 .. AP42 Chapter 1351,0150,al Flares(CO) Section OS-Emissions Inventory Potential to Emit Actual Emissions Requested Permit limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled um.ntrolled Controlled Controlled (tons/year) limn/year) (Ions/year( (tom/year) (tom/year1 Ps/month( NOR ...... CO Pte al to Emit Actual Emissions Requested Permit limits Hazardous Air Pollutants Uncontrolled U tr011ed trolled Uncontrolled Controlled (Ibs/year) Bbe/year) ens/tear) llhs/year) pbs/vearl Benzene Toluene Ethylbenzene Xylene wHexane 224 TMP Hydrogen Sulfide , .. 004 C:\users\hslaught\Desktop\123961\ISW E0076.CP1 Fal'ain:,by ;ory Section a6-Re gulatory Summary Analysis Regulation 3,Paris A,e --... Regulation T,Part&Section ll.B,.F Regulation 7,Part D,Section 110.2.e (see regulatory applicability worksheet for defailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Thraughputto Monitor Compliance Does the company use sl to 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,tithe facility has not been modified(e g.,nonew wells brought on-line(,then it may be appropriateto use an older site-speclfics mple. If no,the permit will contain an"IndialTesting 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 thin or equal to the emission factors established with this application • Are fatality-wide permitted emission of VOC greater than or equal to 40 ton per year in the ozone tonattainmen[area - ORareemissiongreater than or equal to 90 tans per year in the ozone attainment area? Ifyes,the permit will contain: -An Initial Testing Requirement"to collect site-specific go sample from the equipment being permitted and conduct an emission factor analysts 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 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 arnuel basis. Will the operator have a meter installed and operational upon startup of this paint? If no,the permitwill contain a condition that requires the operator...date gas throughput ping the liquid throughput until the meter is Installed and operational(not to exceed 160 days).This condition will use the'Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. Wes the company requeste control device efficiency greater thanes%for a flare or combustion device? Ryes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20.02 gintraMiStiokyritAVOMMOBENVENWASESISINtittaINNIONINAPIONSORMOS Iri✓:b);;v 5J' 9„v., Ef� r,....,:Is'J..o.:k,4 L.'..r,s<.orz rki,&:U1; ....:.. i. r I A'y Cant. Section 09-Technical Anaysis Notes 1.Based on the applti:dld fion,two separa o produce tottlts facility.The well ramesase APIara numbers are as fsepara:or and heater treat r sends 05-32ns to a dere.)Nance:Wx S,API Number:separator and heater treater these re.ove covered ducesunder too pointseparatetwophase mparator.Mixed producdfromtheCx5Wellrom n separator ellwauted oaheater treater dinJune20rurthe0 separation.Oeohn inJulf2016,The and Swell neater been re recomsatederothed combustor.rwisemdified simeitrbegandheatecn In 206.Since the Cox well began production after August from the the gas The the Cx 5 separator and June 2018end began yrodu000rr iRJulya01&Tha Cox Swellhas not been rehactured,recompleted,orotterweemodlhed slice it began production ln2G16.Sine the CoeSeoellbeger production otter:August 1,2014 the gas coming off the C,ox55epatator and heater treater is 000ted to 000000 Regulation 7,Pert 0,Section II.F. 2Accordng to the application,a how meter.Is tretalled and operational at the facility:This How meter only mess es:the total two-phase separator and three-phase heater treater gas produced from the Cox 5 well 3.The sample used to estimate enthsi.s from this source was obtained from the Colwell an December 2o,2016.Since thtsample was obtained from a different well and prior to the first date of production for the Cox 5 well,the operator will be required to obtain an teal site specific extended gas enerd00from the separator that handles thepoducbon from the Cox 5 well in order to verity the emission factors used to establish the permit limits for this point. &There are no vapor recoveryurdoo(VRU.)on location for separator gas.Asa result,the operator has indicated the produced Ostrom the two-phase separator and three-please heater treater is0000ns routed tothe endoead combustor. 5.The heat content used le atoe calculate..and CO emission was taken directly from the sample arulysis.The heat content Rgulation in this analysis demonstrates the mrthodolagy used to estimate heat content of the sample.While the alcuiation in this analyse do not exactly match with thevalue presee nted onthe sample report the difference is small enough to be considered negfigible,' 6.The emesi0n factor for SOY was determined based on the assumption that 100%of the uncontrolled H25 emissions are converted to SO2.The alculatlan to determine the SOxemosien factor is as follows:(O,4361Ibn25/MMscf(e(64.0661b 502/Ibmoie)/(#,08008 lb 420/Ibmole)017 Ib/MMsd.This calculation method results in a conservative estimate of SOx emissions compared to 4roomdl emission fatter of 0.61b/MMscf. 7.224-IMP Is the only HAP below APED reporting thresholds(i.e.0250th/Year).As a result,'Olt the only HAP for which an emission factor is not included In the permit S.T he operator is req estlrga controleffriency of...Since this s greater than the standard 95%control effsle.%the operator will be required to perform an initial stack test harder to verity the requested efficiency.The application submitted indicates the operator performed gad,testing prior to submitting the application However,ow testing was not completed In accordance with the APCD Compliance Test M al:.In other words,e protocol was not submittedt.the Olvisian prior to stack testing end the 001ierontlid not have the opportunity to witne,ss trty.Finally,afnal test report was not sutrmitted to the Division far review and a pproval:We to them many factors,the permit will contain initial testing rasp the information provided by the operator.Purther,requests fora control efficiency greater than.95%also require annual sampling and stack testing be included in the permit.These conditions will be included In the permit:The annual samplinolnclurted In tiepermt 0Ny requires the dperetor to provide en ongoingcangiance demonstration for VOC.This determination was made because the facility-wide HAP emissions are not within 2096 of the major source thresholds(i.e.B tpy for individ.i HAP and 20 try for Total HAP).As a result wgarg sampling requirements for HAPs at this facility would provide minimal benefit at this time. 5,Nhiai and periodic visible mistral,checks for the control device are addressed by the O&M plan.Asa result,the permit does not contain initial or periods opacity resting. 10.A VOC emission facto for pilatiight00mbustion is not included in the permitberause the total VOC emission associated with pilothghtcombustion are negfigiblet0.0006tpyj and do not Impact the overall V0Cemission. 11.A throughput limit is included in the permit tor pilot combustion Emission factors and raiculat on methods for pilot light combustion emission are also included in the rotes to permit folder.Thls Information is induded in the permit because pilot light emissions ewnirbute to the overall emissionsfrom this source.Additionally it is important to include the information bemuse throughput tracking and emission calculation methods are different than those used to estimeteemissora based on the condensate throughput.This clarity is important for accuratelyquantifying actual emissions at the facility. .The operator was provided with afire!permit and APEN redline to review prior to penntissuance,The operator reviewed both docbmenls and expressed they had nocomments. section ors sec coding and Emissions Factors(For Inventory Use Only( AIRS Polo'. Processp 5 .de e.t.a. Uncontrolled Emissions Factor Control% Units 007 O3 .. PM10 _E PM2.5 SOit NOit VOC CO Benzene Toluene Ethylbenzene xylene n-Hexane ..224 TMP .-: -. H5 3004 00Users\hdaught\Desktop\1c39E51\19w000T6.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements ,..,__.h,in the Attantn,entATTAINMENT 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)? Yes ^lt`ISource Requires en APEN.Go to the next question 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,N0x greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section lI.D.3)7 Yes Source Requires a permit Perron NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section II.D.1.a)? ,2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than S TPY or CO emissions greater than it TPY(Regulation 3,Part B,Section 11.0.2)? .;_ilxated that xn:rre:as n',the Attreornent Area Colorado Regulation 7,Part D,Section II 1. Was thewell newly constructed,hydraulically fractured, r reeompleted on or after August 1,201.47 re'SSIVASource is subject,go to next question ittoorte-i sub is.t tv ttetehiaboh T,Nrt Ca, tiun ll ii.S, Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Emissions Control(Optional Section) a. Is this separator controlled by a ba k up or alternateb ti n device(i.e.,not the primary control device)that is not enclosed? 1 :1j JPi- ,1,dJliaNV:lul thin tahoiate....,Dut AaAro ,tertulatinil f,!_ Section II.B.2.n—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule 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/ega//y 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. • • Colomno Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 8: 390178 Received Date: 11/9/2018 Review Start Date: 6/25/2020 Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township _ Range County AIRS ID: 123 NENW 22 12N 64 Plant AIRS ID: 9E51 Facility Name: cox 22-B Physical Address/Location: . ou sh i ;12y9, --- County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment-,cni&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? No If yes,for what pollutant? Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already Issuance# Required? Action Remarks assigned) assigned) Permit Initial 002 Liquid Loading Loadout No 19WE0077 1 Yes Issuance Section 03-Description of Project CCRP Operating Inc.(CCRP)submitted an application requesting to modify an existing synthetic minor oil and gas well production facility located in the ozone attainment area.The operator is requesting to modify the crude oil storage vessels,produced water storage vessels,hydrocarbon loadout,separator venting sources,and engines.This analysis only addresses the hydrocarbon liquid loadout source.The operator is requesting the following modifications to the hydrocarbon liquid loadout: 1.Convert the existing'GP07 coverage to traditional permit coverage. 2.Increase the requested throughput due to the addition of one new well to the facility. Public comment is required for this permit because new synthetic minor limits are being established at this facility. 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 Requireme r 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: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 0000 ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ 0 ❑ 000 Non-Attainment New Source Review(NANSR) ❑ ❑ Is this stationary source a major source? No - 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) • ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review(NANSR) ❑ 0 Hydrr;CaCtiOr ?'.- ._ . Soi,zi°=€.^:velitOlV Section 01-Administrative Information 'Facility AlRs ID: ;123 9E51 002 County Plant Point Section 02-Equipment Description Details Detailed Emissions Unt Hydocarbon liquid loadout from storage vessels to tank trucks using fill. Description: vesse g Emission Control Device None Description: ' Is this loadout controlled? No Requested Overall VOC&HAP Control Efficiency% Section 03-Processing.Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= 241,338.Barrels(bbl)per year (Requested Permit Limit Throughput= 265,472 Barrels(bbl)per year Requested Monthly Throughput= .. Barrels(bbl)per month Potential to Emit(PTE)Volume Loaded= 265,472 Barrels(bbl)per year Secondary Emissions-Combustion Devices) MMBTU per year MMBTU per year MMBTU per year Control Device Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf .MMBTU/yr Section 04-Emissions Factors&Methodologies Does the company use the state default emissions factors to estimate emissions? V '_ Does the hydrocarbon liquid loading operation utilize submerged fill? ,- ,- • Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant Emission Factor Source (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC ,-._ 1,;:45,01 clout State E.F. Benzene _3•:E U4 dout State E.F. Toluene ... Ethylbenzene XVlene .• ..... n-Hexane „E 0 I d'. readout State E.F. 224 IMP ;t1: ....F•;+. Control Device Pollutant Uncontrolled Uncontrolled Emission Factor Source (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM2.5 • SOx _0Et0n NOx _,c • CO U-,i._ Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM10 PM2.5 SOx NOx VOC CO -. 2 014 C:\Users\hslaught\Desktop\1239E51\19WE0077.CP1 • Hyurocarton Loadcut Emissions li,vemtor)' • 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) (Ibs/month( PM10 L.UO 0.00 0.00 0.000 PM2.5 0.00 0.00 • 00 0;20 500 0.00 0.00 2 00 -. NOx 0.10 -0.00, c cc VOC 000 ,_.._ ' 0.,_ CO .. _._2 ... Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) Pas/Year) (lbs/year) (Ibs/year) Benzene Toluene ,:00 . Ethylbenzene Xylene n-Hexane 224TMP Section 06-Regulatory SummaryAnalysis Regulation 3,Parts A,B -.. Regulation 7 Part D Section ll.C.5. (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Section 08-Technical Analysis Notes 1.According to the application,lwo wells produce to this facility.The well names and API numbers areas follows:(i)Name.Cox 1,API Number:05-123-41933;(ii)Name:Cox 5,API Number 05-123-41935.According to COGCC data;the Cox 1 well was fractured in November 2015 and began production in December 2015.The Cox 5 well was fractured in June 2018 and began production in July 2018.The Cox 1 well produces from the Codell and:Fort Hays formations and the Cox 5 well produces from the Codell formation.COGCC also lists an average API gravity of less than 40 for both wells.As a result,the operator's classification of the liquid as crude oil is appropriate. - 2.Benzene emissions are below APEN reporting thresholds(i.e<250 lb/year).As a result,an emission factor will not be included in the permit for this pollutant. 3.As shown in the Regulatory Analysis section of this workbook,this source is subject to.Regulation 7,Part D,Section II.C.5.However,the facility was constructed prior to May 1,2020.Asa result,the control requirements listed in Regulation 7, Part D,Section II.C.5.a.are not required to be Implemented until May 1,2021.Asa result,the applicable regulation 7 requ irements will be included in the permit and the loadout will be permitted as an uncontrolled source.The operator will need to submit an updated APEN to reflect the use of a control device prior to May 1,2021 and apermit modification in order to take credit for the use of the control device. 4.The operator was provided with a draft permit to review prior to public comment.The operator reviewed the document and expressed they had no comments. Section 09-5CC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 002 - 0'00 _, -. n.,. - PM10 _ lb/1,000 gallons transferred PM2.5 -, lb/1,000 gallons transferred 500 -_ I. lb/1,000 gallons transferred NOx lb/1,000 gallons transferred VOC lb/1,000 gallons transferred CO _ lb/1,000 gallons transferred Benzene __-_ lb/1,000 gallons transferred Toluene 0._0 lb/1,000 gallons transferred Ethylbenzene 0.i0C 1 0 lb/1,000 gallons transferred Xylene 4/1,000 gallons transferred n-Hexane 3 0 lb/1,000 gallons transferred - 224 TMP 0 lb/1,00D gallons transferred 3 of 4 C:\Users\hslaught\Desktop\1239E51\19W E0077.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements 115,Attailo tie t Att. 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)? YeR Go to next question. 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.1.1)? Y,efi .•Go to the next question 3. Is the loadout operation loading less than 10,000 gallons 238 BBLs)of crude oil per day on an annual average basis? `p g g ( p y g Nd:: ,,;.�.Go to next question 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? BI.P;:(: *;Go to next question 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? Ip' '„�"''_,,Go to next question 6. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section II.D.3)? Vbx ,..:The loadout requires a permit Soul ccl rCq{tt₹rC5 u permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan 1 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 11.0.1.1)? 3. Is the bailout operation loading less than 10,000 gallons(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 from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.D.2)? c t„J i:,is't'cdi::tied tb.e,.:'cl':.t :i,' .. e 9,ia:.',P'P.f•a,.. Colorado Regulation 7 Part D Section 11.0.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility,natural gas compressor station or natural gas processing plant? Yes.:. Go to next question. 2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? 5.':. Source is subject to Regulation 7 Part D Section ll.C.5. i itt.5,5,U'ei"cc:t f iyc ris i:?,iSiiul'i:'Ctr'c i'.,.Pieic'tl`.ic 55,ii at.i3O iv.. ..c'c,55c'::It. Section II.C.S.a.(i)-Compliance Schedule Section I I.C.5.a.(ii)-Operation without Venting Section II.C.5.a.(iii)-Loadout Equipment Operation and Maintenance Section II.C.S.a.(iv)-Loadout observations and Operator Training Section II,C,6,a.(v)-Records Section II.C.5.a.(vi)-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule 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 Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 6: 433385 Received Date: 7/10/2020 Review Start Date: 6/24/2020. Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township Range County AIRS ID: 123 NENW 22 12N 64'. Plant AIRS ID: 9E51 Facility Name: Cox 22-B Physical Address/Location: County: - Weld County Type of Facility: Exploration&Production Well Pad What industry segment Oil&Natural Gas Production&Processing ` - Is this facility located in a NAAQS non attainment area? No If yes,for what pollutant? Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already If Required? Action Remarks assigned) assigned) Permit Initial 001 Storage Tank TNK 1-5 Yes 20WE0634 1 Yes Issuance Section 03-Description of Project CCRP Operating Inc:(CCRP)submitted an application requesting to modify an existing synthetic minor oil and gas well production facility located in the ozone attainment area.The operator is requesting to modify the crude oil storage vessels,produced water storage vessels,hydrocarbon loadout,separator venting sources,and engines.This analysis only addresses the crude oil storage vessels.The operator is requesting the following modifications to the crude oil storage vessels: 1.Addition of one new crude oil storage vessel. 2.Convert the existing 0P08 coverage to traditional permit coverage.All the crude oil storage vessels are no longer connected via liquid manifold.As a result, they no longer qualify for GP08 coverage. 3.Increase the requested throughput due to the addition of one new well to the facility. Public comment is required for this permit because new synthetic minor limits are being established at this facility. ry 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 Requiremer 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 Classificatioe Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ 1 ❑ ❑ Title V Operating Permits(op) 00000 000 Non-Attainment New Source Review(NANSR) ❑ ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 T5P HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ 0100 Non-Attainment New Source Review(NANSR) ❑ ❑ - Storage Tank si Emissions inve:?tory Section 01-Administrative Information Facility Al Rs ID: 123 9E51 001 County Plant Point Section 02-Equipment Description Details Storage Tank Liquid Detailed Emissions Unit A , .4 Five(5)SOo barrel fixed roof crude oil storage vessels. Description: Ix .i 45 , Emission Control Device it Enclosed Combustor() • q'VI d l• '"lv�'5```"DescdPt on: ra�'�i..:.:..yyw.�.,.... Requested Overall VOC&HAP Control Effcency"h. Limited Process Parameter Liquid Throughput Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= 229,403.0 Barrels(bbl(per year Requested Permit Limit Throughput= 115,283.0 Barrels(Ill)per year Requested Monthly Throughput= „5,._ Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= 275,283.0 Barrels(bbl(per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 3535.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced= 23.0 scf/bbl Actual heat content of waste gas routed to combustion device= .,,x1.35 MMBTU per year Requested heat content of waste gas routed to combustion device= c...:,>_7 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= - _:..>.2.`-)MMBTU per year Control Device Number of Combustors: a 2: Pilot Fuel Use Rate: -,44 17;scfh .=6 MMscf/yr Pilot Fuel Gas Heating Value: cc -µ.S1q 2q7 Btu/scf SMMBTU/yr Section 04-Emissions Factors&Methodologies ProMax Flow Rate 90,885.00.bbl/year EPA Tank Flow Rate 18,177.00 bbl/year Pollutant Flash Gas(lb/hr) Weight 96 W&B Gas (lb/year) VOC 6.109858371 100 2966.37 Benzene 0.018925 0.309746 3333 Toluene 0.0138462 0.22642 .. Ethylbenzene 0.00047596 000779003 Xylenes 0.006515693 0.1066423 33.33... , n-Hexane 0.162951 2.66702 ...-...__, 2,2,4'TMP ::-.0.01.58907. 0.260082.:... 499>'23 Will this storage tank emit flash emissions? Emission Factors Crude Oil Tank Uncontrolled Controlled Pollutant (16/,111 (lb/6611 Emission Factor Source (Crude Oil (Crude Oil Throughput) Throughput) VOC _ Site Specific E.F.(inclndes4ash) Benzene .4 -, 1'?. Site Specific E.F.(includes Bash) Toluene 1.%0E-03 v,., Site Specific E.F.(Includesfiash) Ethylbenzene 5.06E-05 121_ Site SpeciFl IF.((tidedes flash) Xylene 0.021-G4 Site Specific E.F.(includes-flash) n-Hexane 2,07-F 02 Site Specific E.F.(includes flash) 224 TMP Site Specific&F(Includestlash) Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Crude Oil combusted( Throughput) PM10 0.0075 PM2.5 0.0075 b PM25) 5Ox 0.0006 NOx 0.0680 '�''ovy P.f18 sea(NOt) CO 0.3100 .. 'AR4�h9 Ms(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lh/MMBtu( (b/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PMSO 0,0071 AR42.7kti k" 'PM.25) PM2.5 0.0075 R '00.2.5) SO0 0.0006 A '+ NOx 0.0600 6G os(NO.) VOC 0.0054 CO 0.3100 k".;"*."' I-i®,r. z�'l tires(CO) Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Umrts Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (eons/year) (ton:/year) (tons./year) (ton:/Year) (Ibs/month) PM10 __._ 333_3._ ... PM2.5 _ .. 0.,35 SOx 2 CV, _.077 NOx _ 0,v:a C..3 VOC .. .: ,1_ 9.315 13....' 5.1%'7 CO 29'61 7.339 3,539 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) llbs/year) (lbs/year) (Ibs/year) Benzene 6441.19 S__ 2 II 2-_ Toluene 469.39 - _ 23.45 Ethylbenzene 16.11 Xylene 220.79 9.26 .. - 11.74 n-Hexane 5520 7, 230.07 276.09 224 TMP 538.-17 _ 27.40 _.. 2692 2 of 4 C:\Users\hslaught\Desktop\1239E51\20WE0634.CP1 • Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7,Part D,Section l.C,O,E,F Regulation 7,Part D,Section I.G,C Regulation 7,Part D,5ection II.B,C.1,C.3 Regulation 7,Part D,5ection II.C.2 Regulation 7,Part D,Section Il C.4.a.(il Regulation 7,Part D,Sealon Regulation 6,Part A,N5P5 Subpart Kb ... Regulation 6,Part A,N5P5 Subpart 0000 NSP5 Subpart 0000a Regulation 8,Part E,MAR Subpart HH (See regulatory appliabilityworksheet for detailed analysis) Seaton 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors t 3- estimate emissions? 12u z _ _ __• If yes,are the uncontrolled actual or requested emissions fora crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the unc ontrolled actual or requested emissions for a condensate storage tank estimated to begreaterthan or equal to 80 toy? • Ys,N/A-the operator developed site specific emission factors It yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 1403. Does the company use a site specific emissions fartorto estimate emissions? if yes and if there are flash emissions,are the emissions factors based on a pressurized lilted sample drawn at the facility l being permitted(for produced waterta mks,a pressurize liquid sample must be analyzed using flash liberation analysis)?Thism wr,a fir}? sample should be considered p ntatve which generally means site-specific and collected within one year of the "s o ;,< 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 s to spec f oemple. - If no,the permit will contain an"Initial Compliance"testing requirement to develop a sitespeciflc emissions factor based an guidelines in PS Memo 14,03.. Does the company request a control deuce efficiency greater than 95%for a flare or combustion device? N the k will contain initial and periodic compliance testing i yes, perm perio p g m accordance with PS Memo 20.02 Section 08-Technical Analysis Notes 1 According to the appl cation,two wells produce to this fadlity.The well names and APlerumbers areas follows(i)Name:Cox 1,API Number:05-123.41933,(ii)Name:Cox 5,API Number:05-123-41935. According to CO6CC data,the Cox 1 well was fractured in November2015 and began production in December 2015.The Cox 5 well was fractured inone 2018 and began production in.July2018.The Cox l well produces from the Codell and Fort Hays formations and the Cox 5 well produces from theCodell formation.C0GCC also lists an average API gravity of less than 40 for both wells.As a resuh,the operator's classification of the liquid as crude oils appropriate. 2.The emissions from the crude oil stmagevessels a re controlled by two(2)dedicated enclosed combustors.As a result,pilot light emissions associated with the enclosed combustors era calculated in this analysis and included in the total emissionsforthis source.Since total CO emissions from thissoume are above APENteportingthres holds,a limit on the volume of pilot light combustion will be included in the permit. Emission factors and calculation methods for pilot light combustion emissions are abo induded in the notes to permit holder.This information b included in the permit because pilot light emissions contnbute to the overall emissions from this source_Additionallyit Is important to include this information because throughputtadiing and emission calculation methods are differentthan those usedto estimate emssions based on the crude ollthroughput.Tha clarity Is lmportanttor accurately quantifying actual emissions atthis fac3hy. 3.The operator developed site specific emission factors through the use of a site specific sample,ProMax and EPATanks.The site specific sample was used as an input for the ProMax simulation that was used to calculate the flash emissions fromthe stoagevessels.The sample used in the simulation was obtained from the outlet of the three-phase heatertreater forthe Cox 1 well at this facility on 02/13/2017.The sample temperature and pressure are 52IP and 24 pslg.The ambient pres re specified in the ProMax simulation is 12.1 psia.It should be notedthatthfs simulation was originally used Ye developthetotal emission factor for the storage vessels in an application submitted on 11/15/2015.With this application,the operatorcorreetedthe size of the storage vessels from 400 barrels to 500 barrels and added one additional storage vessel to the facility.Since rice the originalProMax simulation calculated working and breathing em ssionsbased on four(4)400 bares storage vessels,the calculation needed to be updated with this application due to the change to number and size of storage vessels In order to estimate working and breathing emissions,the operator utilized E PA Tanks 4.03d This simulation was designed for one storage vessel.Therefore,the --throughput specified In thesimulatior5is 1/5 of the total specified throughput of 90,885 tibl/year.The operator also specified the location as Denver,CO and the liquid as crude oil(RVP5).While It is preferable to use the same simulation for both flashand working and breathing emissions,EPATanks is still an accepted method for estimating working and breathing emissions.Addltionally,the input values specified In the EPATanks simulation by the operatorwere deemed ecceptabie.Therefore,the EPA Tanks simulation was accepted in lieu of the Tank Loss Stencil in ProMax.The results of the simulations along with the calculation methods used to estimate the emission factors are available for review in Section 04 above. 4.In order to calculate emissions associated with the combustion of storage vessel waste gas,the operator ised the Division defavltvalues of 3535 Btu/Scf(heat content)and 23 scf/bbl(GDR).The teal heat content specified in the ProMax simulation is 3014 Btu/scf-This heat content incorporates the heat content associated with the flash gas and working and breathing gas streams-Usingthe data the ProMax and EPA Tanks simulation,the GOR is typically calculated as follows:[(0.0010364 MM5CF/day)'(365 day/year)*(1,o00,OW scf/MMscf)/(90,885 bbt/year)]+[(2966.371b/year/tank)'(5tanksj/(50@/Ibmole)'(379 scf/Ibmole)/(90885 bbl/year))=5.399scf/bbl.Compared to standard methods of determining heat content and GOR,the operator's use of the Division default values is conservative and therefore acceptable for permitting purposes. 5.The permit All not contain initiator periodic opacity testngforthe enclosed combustor(s)because the O&M plan approved for this source requires periodic visible emissions observations of the enclosed ombustor(s). 6.The site specific sample used.,develop site specific emission factors In this application was obtained on 02/13/2017-This sample was obtained more than one year prtorto the submittal of this application and was obtained before all the active wells at this facility began production-As a result,the permit will contain initiatsampling requirements in orderto confirm the originally establishedvalues are either accurate or conservative. 7.It should be noted that all the storage vessels at thisfacllityare not connected via liquid manifold.Based on thefacility description,the Cox l wellproduces to two(2)500 barrel storage vessels connected via liquid manifold and the Cox 5 well produces to three(3)500 barrel storage vessels.In some Instances thesetwoseparate storage tanks would be permitted separately using differentsioe spedficsamples from each welkin this case,it was determined that a single sample obtained from the Cox 1,as described above,was acceptablefor estimating emissions from bathsets of storage vessels.This decision was madeforthe following reasons:(i)The separation steps for the fluid produced from each well prior to being sentto the storagevesseis is the same for each welkin other words,the fluid from both wells'passes through one(1) two-phase separator and one(1)three-phase heater treater prior to being sent to the stoagevasels.This means the flash emissions that occur at the storage vessels are likely verysimilar.(ii)The two wells et this facility were drilled to approximatelythe same vertical depth and produce from the same formation.As a result,thecomposIt ion between thetwo wells is likely very similar.(Ili)Based an CQGCC data,the API gravity between the two wells is very similar and less than 40 for both wells.Hem again,this supports the determinationthatthe wells likely have e very similar chemical make-up. 8.It should be noted that an emissioniactorfor VOC associated with pilot light combustion is not incorporated intothe permit,This Is due to the fact that the pilot light only results in a negligible contribution of VOC(0.001 toy).This minimal amountof emissions doe not impact the total VOC limit for this source and thereforecan be Ignored. 9.NOx emissions from thissource•areftelow APEN reportingthretholds.As a result,the permit will not contain limit or emission factors for NOx. 30.The operator was provided with a draft permit and APEN redline to review priorto public comment.The operator reviewed both documents and expressed they had no comments. Seaton 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point 8 Process A SCC Code _ Pollutant Factor Control%Units ._.. 01 4.04-803.42 Field%%ofTank,Crude Oil working.brealrft Rflashing loses , _ PM10 3 6/1,000 gallons Crude Oil throughput PM2.5 0,_71 0 b/1,Oo0 gallons Crude Oil throughput 50x 0330 b/1,000 gallons Crude Oil throughput NOx 0..2 0 b/1,000 gallons Crude Oil throughput VOC 17.81£ 95 6/1,000 gallons Crude Oil throughput CO 0bl 4- 6/1,000 gallons Crude Oil throughput Benzene 0,05 95 b/1,070 gallons Crude Oil throughput Toluene _. >, b/1,000 gallons Crude Oil throughput Ethylbenzene 6/1,000 gallons Crude Oil throughput Xylene 6/1,000 gallons Crude Oil throughput n-Hexane :. -. b/1,000 gallons Crude Oil throughput 224TMP __;: b/1,000 gallons Crude Oil throughput 3 of 4 C\Users\hslaught\Desktop\1239E51\20W E0634.CP1 Storage Tank PegalrtaPy Anelyals Worksheet The regulatory require rnents below are determined based an requested erniSslons. • ATTAINNINT 1.Are uncontrolled actual embpns from any alter.pmeuntsh°m the lntlbmual same greater roan z TPV lPenlaaan swnasctlonn.0.l.aly $54's` rye Peones an AMC mm the nest question rfale 04/30101 after 4/14/14 wlmanoaaankrn,vuehwttsssthan4a,Dp0ealmnspn Year/see PS Memo laozfo,aaeemndeuManaon[anernneraogl¢mI22 ia�e'.S.s'� Ootan¢rqunlnn 3.ae total taa'ny uncontrolled endssions greater than smy.xm greater than laity or CO emissions neatestnan SOTPS ln.eu6ten 3.Parte,Sear."11.0.31' yn._a...snw¢Pequlrnapeemu 1.Are uncontrolled emlmonanom anyahnu pollutant=nov,tMr ioarrdvalsvvr¢[rnrnthan l rx lReeulation Patna.Section ll.D.i.a1] 2.Is the art o4/1420/9 and not mod.tl atter a/ia/1410ha nonce tank throughput lm than 0aom omn:per year,See P5 Memo 1.3.r...Plant emaance on grandfather appoumlmlr g.xet ml n D[.mfaaunz n ea,tnan5mamD=maaan thou lorrryReemdln 1,P.n e.mrnanlln.nr Colorado lieggation 7.Pan D.section I C-pc G t- thiastoranotanir loactod in tho 8-hr oton•control area or any ozone ant/me area l@e[ulahon 7.Pad D.Sectionkadlg Storage rank Isnot Object.to Regulation,Part',xmonl you nave lndkatemne site.Moment name on the project summary sheet. 2.Is....tang beaked at ell and,kas operation[kat emhWmu lean,produced Water MP that are located at or upstream of a net ual gat processingPlant Pevulanun],Pan D,5e<tl°n eamgpl.��I�wetg„i.ronza.rclD,5mmm�,n11q Staa,.Isnot subject l°Pea..I.Pak D,semon LGrou ham inmmed WNW type n prole..summry meet, sh'�e�° uleA emisnons lfleeulatlor.pan O5ervonb g.aeuncgnrmle z an]t nzp nearvaelxegumrun].Partnrt Osminnl.oa.mu] Part D,S.ectlon I.C.1-General Pegultements for illrkolkstion Control Equipment-Pre...Mon of Leakage Pan,Section LE-MonNorlot Part%Section p e dkroonee Part 4 Seddon and h-General Psnuirements lorahr Pollution Control EquIpment-Prevantion of Leakage SPOIL,IL 1.Is this storage rank located at a .n/sea Proles a Is thisstonase tankL located at an oil and gas 3.Does x roof lPeeuvun➢LPart D.Rnwn HAMM'ta.Well proa°pbn funk v.nt mpr al drnaturalwp k plane meevlatlon 7.Part o,sananll.el] -You have end ranYty type ongraded ghee, a.Are uncontrolled actual ernigglons of this storage tank equal toy,greater than]mna per gear VOC gieguet onz PartO x..on et<li yn Source ssubject t°parrs of ueuaton],Part D,se..on.ILIAC..turtle nest q aim Part LI Seaton 11.11-General NovIglons for Pg Pogo...Cont., s.Dart ttmn[ y.61] I5°uran ubleo to all pmvtsens M Pervwbn,Pan D.Seaton II..sMomeae e isn n u D,smr.n lint Ina Part toring.for with r Pollution Control ment s.such et a well productegrn sal edit gasicompressor�station.in natural pas p,or®aedanoo,ssnded on awaerder i.013 rlvotea xa loon!rharwaemmdwa on or ahM Iddr1- D.Ha .'voce Tank subject um,on>.Pan D.Section II C.4 ia the controlled a touted ar ]PanD Yoti IIc4 ltp t atNa anticipated n ehpuwinM dew"quids produced t Maculation Moue,. eg ].1.gbz..uM1tnatana P m purvlh a nease In thrLM1yarom,ban le Itl•yr produ<etlw e .t ],water Pan D,Semm�ll[4.a.Ull1 eon°ratrereanua No ,, 40 CON Pal",schwa Porlormanoe for Volatile Organic trould Storage Vassals 1.Is Me indloidual nor,cease!aapacity greater than or equal to 75 cubic meters PO six DPul!no CPS sa.11bdlat, a.Doer[ 11O411 d m yn 5,e i nNlxrat,u61m x5p5gd. following Ivssthan Or m'l00 0 6841uk<d IPrg<IIPISSM'2(80822222promisnl4nrlrnlnn Dnnr In mgt.tandgeghrleIlned In®.311bz 3.W.thmstorage vessel constructed,reconstructed.or Isee derinItions aO crP,ggzlaherulyx.3ga4N0[FP6D.C10Pla111 NA NA e.w ,29.7 pad and Mot emission to the atmmphe¢16D.11ab12118)08 na- isthe storage vessel a pressure e designed to operate in...of m'1'gnegy ate tea ea 51 roil ptna and toreeapm id with ammonium true vapor or m'I-an gall bur esarnan 351 m'I^0n te11 era xioraaleu,a won ammonium uuevan,pre.um:less than 15.0 kwlgD.vwlbll] NA Dom design mpg.,IS greater...oF equal to 151 m,.salon steeramiquawItM1amasnum true vapor pros..greatermn o,equal to ss kwbur less than 5.2 xPa,oe - n= t alto75 NI'I-4]z aefl but less than lv m'l'VSD gay n stores liquid with.maximum true vapor pressure creator Planar equal to ls0.061 less than 22 Saa, xa ear, .. ,.. �1.Is thh storage vessel located at I agility In the onshore oil ana natural gag producton segment.aD cpP wnm,sudwrt000o/000on,sanaaMe drpddoren<.m.c,ua.ollana Nawralwa p,oeudlon,mnsmmlonanu ohylwaon natural 1 .xsm soon antis:wage se gment t 2.Wssthisstorase vessel constroared.towns-trussed,or inc..!see der indions wl between August 23.201 and Upland.,15.2015? 5,50000-net to themm.askant°unn the aetermmatmn of WS 0000a applrablkty. 3.Waktigs storage vessel constructed.reomskructed,ormodgletl Nee tlefinrtbna 40,60.2katterSeptembee zols] 4_Are potent's!Vac caissons.from the tons per 4O,3:v°ra<eink isnot sublenxms0000a. edlnhmnar Individual apaag�yeezer-',ergas4lawesalm]6m end'"' 6,Miss.orl eve with requirements mramrate assists PI 40[Wart goybpan nutm MISR6gsbgbmtex. Otf.�" • Inge:If storage vnsetla'prweusly daermined66.¢Meant 52050000/0000a doe to oMaenx above G tons oeryearv0c on this aPP1.abblaa.e,min lion data.ltxnwu nmaln sohl.n to x5P50000/0000.par 6o51s51.II11/n.nansalellxl wan P potential V0cembsons drop billow b conte,nnl part Macixx,ap and Gas Production Fa..' 1.time ants an awing=rnM,a. . ImnthomsPou have Indicated the source category on the Project Summary sheet. a.see lty ht rtprornxa.upeaenornorenMrommon.qu,d:Igs.JgDIaII111.0R 2_lathe...looted at a facility that la urelgsprto.mtne neat rtwhkA naturelen emmthe,aturd estransmbpon nest=aeesou,mares°rvoraaelrerearoann.lena omr'Igg.]ggallgx] coyer or MOPS swage Tan,ts not subject MaR Px-rhaewena SIACTSIM requirements,r„nkxa,a,eazaum, 3_Dyads...meet the danhion of',Wrap vessel'in 53.731r Doesthetank meet 'dense vessels!.the 1] arm 5.Is the ksublect to control requirements ents under m CR Part so,5utbpartr ea°rsubpartno0001 xpar'r_,tank n 1.1 Tahmx 4sg.eG EmIulvnl n ] s[gevl5tandaras 463.]°Pe<oeNmPlne RAPT Review PACT review is required IR.NlatIon]does not apply ANDametank6 In the nonare1nment area,Ilene cankm.n both MPeda,then review PAcl requirements. ISInclalmer Thisolocument...as/swabs aD4daily°rrme0,nquseenew0mueCtean tiAd.its rn0MDanwgrmrdeemtx ermavou.IMC°nbde¢nmasm repueta s.inne°toaradnwa a role nyarsi Y epnd 511 roe- ale,l atylaw,repw.nn angrlw.iybrepro,mew1 avid emiWWallye✓e�ene,In meatntdaty�r nxilw0ntbeenwaasedlnaeaameaagamea+ar ae�0eceanAirActbodalmplemetingnw,dma,s.. and Air reardatims!801,200,0,& slaluta o-regul.bat will control.n men0etey Inauegasaxh as 22,0, ne.']rer."sn°ub.'endou,;O2 002dda min°Ivrysuchas'TODTaM,equ�'are Wended la deseibecm6°0lrg re,0010 s 0Mathe I®msollheele.nAIActenef, Ouellye 02alGem.a 1ue Dl00 dui...mantas lepalydndpgrequ.rmants In aMdilaell Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: -Harrison Slaughter Package it 433385 Received Date: 7/10/2020 Review Start Date: 6/24/2020 Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township Range County AIRS ID: 123 NENW. 22 12N 64 Plant AIRS ID: 9E51 Facility Name: Cox 22-B Physical Address/Location: ,S County: Weld County Type of Facility: Exploration&Production Well Pad What industry segmentC5i&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? No If yes,for what pollutant? Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit if (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already if Required? Action Remarks assigned) assigned) Permit Initial- 004 Storage Tank PW 1-3 Yes 20WE0635 1 Yes Issuance Section 03-Description of Project CCRP Operating Inc.(CCRP)submitted an application requesting to modify an existing synthetic minor oil and gas well production facility located in the ozone attainment area.The operator is requesting to modify the crude oil storage vessels,produced water storage vessels,hydrocarbon loadout,separator venting sources,and engines.This analysis only addresses the produced water storage vessels.The operator is requesting the following modifications to the produced water storage vessels: 1.Addition of two new produced water storage vessels. 2.Convert the existing GP08 coverage to traditional permit coverage.All the produced water storage vessels are no longer connected via liquid manifold.As a result,they no longer qualify for GP08 coverage. 3.Increase the requested throughput due to the addition of one new well to the facility. Public comment is required for this permit because new synthetic minor limits are being established at this facility. 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 Requiremer 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 atrue 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) 0 0 0 0 0 ❑ Title V Operating Permits(OP) ❑ ❑ ❑ 0 ❑ ❑ ❑ ❑' Non-Attainment New Source Review(NANSR) ❑ ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) El ❑ ❑ ❑ ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ❑ El ❑ Non-Attainment New Source Review(NANSR) ❑ ❑ _,..lair r..- _ .,I.?.5 .s"i Section 01-Administrative Information (Facility AIRS ID: 123 9E51 004 County Plant Paint Section 02-Equipment Description Details Storage Tank Liquid- Produced Water Detailed Emissions Unit Two(2)500 barrel and one(1)100 barrel fixed roof produced water storage vessels. ' Description: ;. • Emission Control Device Enclosed Combesteo('s:-' \ - Description: ' Requested Overall VOC&HAP Control Efficiency%: ; .05.0 Limited Process Parameter ,t Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= 241,338.0 Barrels(bbl)per year Requested Permit Limit Throughput= 265,472.0.Barrels(hbl)per year Requested Monthly Throughput= -_....- Barrels(hbl)per month Potential to Emit(PTE)Condensate Throughput= 265,472.0 Barrels(bbl)per year , Secondary Emissions-Combustion Device(s) Heat content of waste gas= - e.- 1496.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced= 36.0 scf/bbl ' Actual heat content of waste gas routed to combustion device= MMBTU per year Requested heat content of waste gas routed to combustion device= MMBTU per year Potential to Emit)PTE)heat content of waste gas routed to combustion device= • MMBTU per year Control Device Pilot Fuel Use Rate: 17 sefh ,MMscf/yr Pilot Fuel Gas Heating Value: 1510.2378tu/scf . •.MMBTU/yr Section 04-Emissions Factors&Methodologies P^ '3= Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) ppedle_,es. 8,E.(includes hash):Front VOC 2.62E-01 .. ... gagge Prod '" E:F:(includes flesh) Front Benzene 7.00E-03 0 Toluene Ethylbenzene ti . Xylene ., 30 E.F.(Includes flash)-Front n-Hezene 2.20E-02 -:'•J 224 TMP .,,:0vc ,f.),,, , Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/hbl) Emission Factor Source (waste heat (Produced Water c omhusted) Throughput) PM10 . 0.0075 .}�'4 AP-42 Table 14-2(PM10/PM.2.5) PM2.5 0.0075 •:•f„ AP 42Talsle 1.4-2(PM1O/PM.2.5) SOx ,0,0006' ., AF 92r ;4-2(SOx) NOx ;OA680 , 3.S Industrial Flares(N(3x) CO r .0.3100 01- ,, ,13.5 Industrial Flares(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant )lb/MMBtu) )lb/MMscf( Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 0.0075 .'..`.5.-' AP-42 Table 1A-2.(PM10/PM.2.5) PM2.5 .0.0075. _-7520 AP-42Tabte1,4-2(PM10/PM.2.5) SOx 0.0006 „:85a AP-42 Table 1.4-2{Sax): NOx 0.0680 -_ ...= AP-42 Chapter 13.5 Industrial Flares(NOx) HOC 0.0054 3.40-1 AP-42 Table L4-2(VOC) CO 0.3100 _„0 1'35 AP-42 Chapter 13.5 industrial Flares(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) (Ibs/month) PM10 : , 0 PM2.5 „- - 9 SOx ').00 -, • NOx 39 + .- VOC :."e 1.'8 3020 CO _... _,.h -s - , Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) (lbs/year) (Ibs/year) Ohs/year) Benzene ERSO.):I _069 17 "'=3' Toluene r X10 v 00 i 00 0,•0 ,.- Ethylbenzene 1 Si' 0 0. ,36 Xylene -,c., .,- n-Hexane 0,0%08 _ 5 14 , s=4:-+, • - 224TMP .. .. .. :... 2 004 C:\Users\hslaught\Desktop\1239E51\20W E0635.CP1 Storz,ge Tank Section 06-Reeulatary Summary Arralvsls Regulation 3,Parts A,B Regulation 7,Part D,Section I.C,D,E,F Regulation 7,Part D,Section I.G,C. Regulation 7,Part D,Section 11.B,C.1,C.3 Regulation 7,Part D,Section ll.C.2 Regulation 7,Part D,Section II.C.a.(i) Regulation 7,Part O,Sedion Il.C.4.a.(ii) Regulation 6,Part A,N5P5Subpart Kb Regulation 6,Part A,N5PS Subpart 0000 N5P5Subpart OOOOa - Regulation B,Part E,MACTSubpart HH .. (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors to estimate emissions? - - rr aare If yes are the uncontrolled actual or requested emissions far a crude ail tank estimated to be greater than equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? N/A-this source consists of produced water storage vessels. lives,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines In PS Memo 14-03. ��— —j Does the company use a site specific emissions factor to estimate emissions? • If yes and If there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being III permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample . • should be considered representative which generally means site-specific and collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought an-line),then it may be appropriate to use an alder site-specific sample. IN/A-the operator used the state default emission factors to calculate emissions. If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? No If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes 1.According to the application,two wells produce to this facility.The well names and API numbers are as follows:(i)Name:Cox 1,API Number:05.123-41933;(I)Name:Cox 5,API Number.05-123-41935.According to COGCC data,the Cox 1 well was fractured in November 2015 and began production in December 2015.The Cox 5 well was fractured in June 2018 and began production in July 2018.The Cox 1 well produces from the Codell and Fort Hays formations and the Cox 5 well produces from the[oriel(formation. 2.The emissions from the produced water storage vessels are controlled by one fl)dedicated enclosed combustor.As a result,pilot light emissions associated with this enclosed combustor are calculated in this analysis and included In the total emissions for this source.Since total CO emissions from this source are above APEN reporting thresholds,a limit on thevolume of pilot light combustion will b included in the permit.Emission factors andcalculation methods for pilot light combustion emissions are also included In the notes to permit holder.This Information is included in the permit because pilot light emissions contribute tothe overall emissions from this source.Additionally it is important to include this information because throughputtracking and emission calculation methods are different than those used to estimate emissions based on the produced water throughput This clarity is important foraccurately quantifyingactual emissions at this fadlity.. 3.NOx emissions from this source are below APES reporting thresholds.Asa result,the permit will not contain a limit or emission factors for NOx 4.Initial and periodic visible emissions checks for the control device are addressed by the O&M plan.As a result,the permit does not contain Initial or periodic opacity testing. 5.It should be noted that an emission factor for VOC associated with pilot light combustion is not incorporated into the permit.This is due to the fact that the pilot light only results in a negligible contribution of VOC (0.0006 tpy)This minimal amountaf emissions does not Impact the total VOC l it for this source and therefore an be ignored. :6 The p t r was provided with draft p rmd and APEN redline to i w p to public t The operator d b th documents and expressed they had no comments. 1rs .. ,.� t �a _." r -u `. . ,r.�t,v....e.,� '"'s.,.rs "„0' .,,.;r'�P'";' .s uz1.'_„' 1 Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point 0 Process H SCC Code Pollutant Factor Control% Units 01 4-04-003-15 Fixed Roof Tank Produced Wafer,working+breathing+flashing fosses '.; I PM10 a b/1,000 gallons Produced Water throughput PM2.5 C_- i 6/1,000 gallons Produced Water throughput 5Ox _.-' 0 6/1,000 gallons Produced Water throughput Nog Cu= G 6/1,000 gallons Produced Water throughput VOC =25 fS b/1,000 gallons Produced Water throughput CO 5_:. - b/1,000 gallons Produced Waterthroughput Benzene C.'7 95 b/1,000 gallons Produced Water throughput Toluene 2 III., 95 b/1,000 gallons Produced Water throughput Ethylbenzene 95 6/1,000 gallons Produced Water throughput Xylene 0 Cv' 95 6/1,000 gallons Produced Water throughput n-Hexane ..52 95 6/1,000 gallons Produced Water throughput 224 IMP Cy'v 90 6/1,000 gallons Produced Water throughput 3 of 4 C:\Users\hslaught\Desktop\1239E51\20WE0635.CP1 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below ore determined based on requested emissions, 1.Are unconnoeed actual em's...imm any orrerx pollutants nommrs lnelvreualmuru{reale..x1,lleeubhoa3,PartA section lh2.l.alx Yeti,,,,,,*5aurreFtequirman mON.Go to the nett q enact 3.Met wIN,uncontrolled emrsswns v than vaav than WON or COemomns ereaterthan IOW(Meeuktbn 3,Pan e.smbn 11254 Y¢�a.,Yw¢aequhv apumu sn o vanmather neprerWms e»tonvt Mon mall lvr R t INVM[ neat iM1 - "- 1_Are uncontrolled emission..any criteria pollutants from to s Individual sour.greater than lTn lneeunon3 PartA.Uction 0.1 a1x 2.Produced Water ianla have no gran-dtathering 3.Are total faclilLy • urico.olled VOL enlIsslons greater than lin NOx greater than 5r7V or CO ernlislons greaterthan 10.72272 IReguaton3 NI 8.5.1105110W 1_Is Ns storage lank located in the S.hr azonacon.1 area or any want al r ant/realntenence gieematlon 7.Part O,YCIon I.A31> Swag,.Is not subject to Regulation],Pan2,Ynlon 1-You Oavemdlcatee the site attainment...the project summary sheet. 2.Is this storage tank located ak and aperatluna that collett,store,or handle hyeoca liquids orproduced water AVMNat are located at map eam5lanvuralgasa5euNepunt lReeuuwn].Part O.Ynlon l.Aitt • 3.is Ms storagetank located at a nanual ssing plant lReeatatbni Pan v n,saon gGlx x0raaerantunet wgetttoaqulmroex,Pan o. �vou navernerrmeafwnyrypeon Pr let rummarysFee. e asu'le.t m areal eon a 7.zM 5.Aovthhdm+s tan sto or means per nonx,eangulamn j. a aeumemro eO an nor oruemaaan2tons oervcarvoclReeulnwn],PartM,wont Maa 11] Part I.C.2 falmation procedures Part 11 Section 1.0-Empsslons Control Pegurrements Part I,...an Re oreke pine and Reponine • mlaVon>PaRn,sentenll 1.41.51s gouge beat.at a Ion/storage5,,er a ,Regulation .ion wellpreauttlon nn4ry.nvunl ps 0.p rmtnn ornatunl gaapro=vnne Pl Pat lReg intact].P.n 0.Ym5n➢edx tl s u Fave rnalntea�lkytyPe 5 pmAnsummat,5eer.3.Doe...rage WO have a Med roof Go to 6e next question P ry 222[IReeu aonx Parc 0,se52on i.tlx y i, .,,T sours Is%abaft(to parts of Regulation].PartO,senons.442,752.tn.next Quest= Ynion Pr5voror,s en<anal naenN0n 0150.4400. s.govt or rtlalYeunnen].Pan 2.52 24ltc.x.hl] IxO ''Source n subject tools prevuions of Reeubtmn].Pan 2,smron h,subseebns 042 esl alp ts.ea.suto n u tea lnneaselntb uueb7ut4rnvtlmormntipure 0rprmucaawvvlRvulonon x.Pan o.YerOn u,egajrlx g'mon atone.MavLz7 No ssO aeerantnnmsuerentO Reeulmion].Pan O.senbnxc.a,t In a t,xox control.umace no..t=a produclIonlacility.n.raleas compressorstation.or7tdrnnea.emthroe7gasprocessIngrhyaplant consn..an or allerlanuary 2021 anrrmtl4tadwatemaeeo lamed a2.senbnh1.tw was modified 5n Drafter lam N4 410.1.Is 0.04.1 storage Wessel cap..[realer than of equal to 75 cu. tars In i,172 o�x a01.s1IgO CPn60.310F1a11] x.Does the storage vessel meet,following uemption 15 .vblell9tPm Ves sr race mnkh not sudjett NSPs Od. a.Does the vessel har ides,capa,less than .1{P 1,55A,V9 m1'30,Ow OW MO let rmkum Or[0.11,41,Infetl.prorened.or treated pn cu stody n asaernea rna0.vibx a ernnonsm 2nR,6ail char yi.u0ala7uasaiimlallxNA DO5S(Ae WA 1b7 NA meal vualvoleeas dehnm In 60.11152 NA 6 Ida[^2n pot one wnnoutemrssronstome atmos7hera100.1i0blall]Ilx:a NnNA etulto m�l^se 4441 an us aNA 5.The design upa5,,Islreatertnaner equal te m'[-an 630 but less Man151.,1'750 Be l and newa liquid w.a maxmum true vapor prnure'ks.tnan 0.r,xPalfie.ssoblbpi DP om x.Does the rtorage tan,meet elther onefollowing rilons No control andsrequirements: d Mthamaelmum tmevaporprewra era.Yr man 5requal to3.sma butmss roan 5x xpal:or xn h,me design calla.",Is greata than or equalt0]sm'1,71061.1 but less than jai re.(.150➢ey and stores a Ilqulditha maximum true vapor pressure greater than or equalb x5041,bin less than 27.6 Oa? I Nn l anon.cart 60,Merest 0000/o0ooa,standards 5l pad moms.Incenses Miami Natural GV Pmanion,Tranrmhsbn and eRtnwrmn 1.Is this storage r.esse,i0,a,ed at a lacihty In the onshore all and natural cas preaunien seeme51.natural gas processing segment or natural gas trensmisslon and atoraee upnmtal the lneuslryx __ Pr51en Was Mr storage vessel cons,runed,reuenstrutted.or motlilied Iret 40 6,n.60,2155,45. x155,45 Allem 23 011 and Y7temher 10,x015] 5750000-Got°.next euestIon to milli,.de.nination of NSP5 o0a0aapplmbhey. 3.Was 011 storage veuel constructed,recneskruded,er modifiedm 0.11 after September l&x415i Yes Go tn.the next question a e 930/s0e m pert'arP N4 rage Tank znetr been Nsps Doom s.Isrne er'ga o 94090 ramen.for storage+meltn20C RPon4O subpart er25 CPR Pan 6390042 NN2 Rastorma venal ls;nevi.*deleonmoe to be 42gen to 00/2000....emissions above tors per marVOC on the aPplicah2h 0.va 22,,41 neon 4. 4 should rent aen a15 su2e NSP40000/o0ooa per 6053➢21442)/20.52265171122,5.n➢do0,26120444'22272 2,574.bw62.5s per years 90 CFR Pad 63, Pd.NN, and Gas Padunion Foc11111. 1.Rmea i RManp located at an.2 od and natural gas pr4dun15nmRlrn that meet:either of the fellowmgn➢era: I,. Iconhnue-YouFoeNdkatea the source category on the Project Summary sheet. a.gndlnv that processe v0r atoms hydrocarbon VOW 163.x60141121,08 Afacility that prosesses,pgrades or atoms natural gas prierno 0.4 point at which naturngaeeters natural gas tmnamra.bn and etorage source oteg.ry.rraeellaeatltoa final end user' 143]6wan3m 7_Is tank located a a'nifty that major'r NAP, Storage-rank Isnot subject MArrNN-mese are no IMMIX requirementslertanks at amsoursa 3.Nest,tank meet,definition of-stwagevaser.In 63.7617 S.1sthe 52,1,2 , 572042426842224742000021.4241464 t2 ax . lolrablez 403 rolstanaoraa 463]]3R norrnne . Pat 463.779 463.x]5-Aeponme Ping ileylevo RACTreeaw bre,.a wwletba]does not appl.°gthe lank 2 fntxsunonaroFment area.'MalanFmeets fmh crnerla,tnan r¢lew M4 mquhemenb. I, Disclaimer Tam t 9 7120 app0:ab➢ity requiems.recermin requiems of...an2224542 as rmpcamsel°regmeame e4aabo22ryCoreelDenlllsmes raxulawrss.Tnends v rgwe Damara mee.ysis 10.0.2107 mayrrd gogy 0 o yaticwvaduab'on based upon tins iMrviduellad.end cunmoam¢_TWasurrenl aura nal drapeaauhaGm2faam I�urrywarimw or any a.F4➢C Oy OSI Commission rwdramnl and b real I¢ally ankroaa..In Ne erml olany cm427 between 2re lanauw.,,lnia duumem anal Nat languope d Ne clean Ab Aci,i'2 inmlarrenbnp rwularimrs end Arlpuelly Cm e0ulallon42r8747.T n0etoylanaoape such as'recommend"'xy,"s75/.'an2-can,'2n22dearo ba25CO Fnlapelafimsanr4ammentlefions.M orwy4vehes'mdal'erq'rryWe,2422ended lodmvibeconVaingregalrevranl.under-the lvmsd Ow Clean arneta.Alr Ndl nte,es tormin pu®it'Con( Gnmmrzs]m rcguwtbmv,but.dooummla®.rwtestebllsh lepWybindlrgregrbevnmk]naMdlnallr �>aPHE Hydrocarbon Liquid Loading APEN � � Form APCD-208 CO .• Air Pollutant Emission Notice (APEN) and Application for Construction Permit AR sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. 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: . 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: 6 ci v1`E 00 77 AIRS ID Number: 123 / 9E51 / 002 Section 1 - Administrative Information Company Name': CCRP Operating Inc. Site Name: Cox 22-B Site Location Site Location: NENW, SEC. 22, T12N, R64W County: Weld Hereford, CO NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 717 17th Street, Suite 1525 Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720) 961-9100 E-Mail Address2: imyers@clearcreekrp.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. 390173 COLORADO l ,r Permit Number: AIRS ID Number: 123 /9E51 /002 Section 2 - Requested Action ® NEW permit OR newly-reported emission source ❑✓ 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 each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info a Notes: Source previously subject to GP-07;however,with addition of 2nd production well,requesting coverage be converted to a traditional construction 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-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Loadout of hydrocarbon liquid to tanker trucks. Company equipment Identification No. (optional): For existing sources, operation began on: 12/01/2015 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes ❑✓ 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? 0 Yes ❑ No If yes: Does this source toad less than 10,000 gallons of crude oil per day on an annual O Yes 0 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? ❑ Yes 0 No Coto R&®O Z Permit Number: AIRS ID Number: 123 /9E51 /002 Section 4 - Process Equipment Information Product Loaded: O Condensate ❑✓ Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 265,472 bbl/year Actual Volume Loaded: 241 ,338 bbl/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: Saturation Factor: Average temperature of F bulk liquid loading: Molecular weight of True Vapor Pressure: Psia 6Q`F lb/lb-mol displaced vapors: • If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft' Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft'/truckload 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. oo Permit Number: AIRS ID Number: 123 /9E51 /002 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.996623/-104.535017 Operator Discharge Height Above Temp. Flow Rate Velocity Stack ID No. Ground�evel (•F) (ACFM) (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) O Circular Interior stack diameter(inches): ❑Other(describe): 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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: Rating: MMBtu/hr hr Type: Make/Model: ❑ Combustion Device: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: _ COLORADO 4j mf Permit Number: AIRS ID Number: 123 /9E51 /002 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(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SOX NO,, CO VOC HAPs Other: Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL El Crude 0.104 Lbs/BBL 0.00018 O Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NO. CO VOC 0.104 Ibs/bbl CDPHE 12.55 12.55 13.80 13.80 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.00018 Ibs/bbl CDPHE 43.44 43.44 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.0016 lbs/bbl CDPHE 386.14 386.14 2,2,4- 540841 Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Amual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. 5 I coioRnoo Permit Number: AIRS ID Number: 123 /9E51 /002 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 wilt be operati in full compliance with each condition of General Permit GP07.• -N°J"Li Signature of Legally Authorized Person (not a vendor or consultant) Date Ian Myers VP Operations Name(print) Title Check the appropriate box to request a copy of the: o Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit 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 8O246-153O Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.gov/cdphe/apcd _, '. 6 I C0 RADO Received 07/10/2020 Crude Oil Storage Tank(s) APEN :,,,-';',..f- 0 44 Form APCD-210 C_ GOPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source(e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)website. 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: 20WE0634 AIRS ID Number: 123 /9E51 /001 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': r1CRf' Operating Irlr Site Name: Cox 22-B Site Location Site Location: NENW, Sec 22, TI2N, R64W County: Weld Hereford, CO NAICS or SIC Code: 211111 Mailing Address:(Include Zip Code) 717 17th Street, Suite 1525 Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720)961-9100 E-Mail Address2: imyers@clearcreekrp.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. a"!+ COLORADO Form APCD-210-Crude Oil Storage Tank(s)APEN-Revision 07/2020 1 I Ali►*Olt7°^�''�'"B�JIL b G.Mr-amt Permit Number: 20WE0634 AIRS ID Number: 123 /9E51 /001 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2 - Requested Action ❑r NEW permit OR newly-reported emission source ❑r Request coverage under traditional construction permit O Request coverage under General Permit GP08 If General Permit coverage is requested,the General Permit registration fee of S353.13 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 0 Transfer of ownership4 0 Other(describe below) -OR ▪ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ▪ APEN submittal for permit exempt/grandfathered source o Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info a Notes: Previous application had requested coverage under GP08, now requesting coverage under 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-104)must be submitted. Section 3 -General Information General description of equipment and purpose: Storage of crude oil on site prior to truck loadout. Company equipment Identification No. (optional): For existing sources, operation began on: 12/1/2015 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑ Exploration&Production(E&P)site ❑ Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes J No Are Flash Emissions anticipated from these storage tanks? El Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) O Yes 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 Yes ❑ No emissions a 6 ton/yr(per storage tank)? COLORADO Form APCD-21O-Crude Oil Storage Tank(s)APEN- Revision O7/2O2O 2 I `"Y'I Permit Number: 20WE0634 AIRS ID Number: 123 /9E51 /001 [Leave blank unless APCD has already assigned a permit tt and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bb►/year) (bbl/year) Crude Oil Throughput: 229,403 I 275,283 From what year is tire ositoci an;tiucf amount? 2018 Average API gravity of sales oil: 37.6 degrees RVP of sates oil: 4.91 Tank design: ❑� Fixed roof ❑ Internal floating roof O External floating roof Storage #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) TNK 1-5 5 2,500 08/2018 12/2015 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 41933 Cox 1 O 05 - 123 - 41935 Cox 5 O ❑ 1 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 APEN5,including APEN updates. 6 The E8P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.998623,-104.535017 O Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. cerator Stack Discharge Height Above Temp. Flow Rate I Velocity ID No. Ground Level (Feet) (°F) (ACFM) (ft/sec) 001-002 25 2000 75.7 0.10 Indicate the direction of the stack outlet: (check one) O Upward O Downward ❑r Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) Q Circular Interior stack diameter(inches): 48" ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑Other(describe): COOO Form APCD-210-Crude Oil Storage Tank(s)APEN -Revision 07/2020 3 1 �� I.s�`RaD° Permit Number: 20WE0634 AIRS ID Number: 123 /9E51 /001 [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: VOCs and HAPs Rating: 1A 05(each) MMBtu/hr Type: 2x Enclosed Combustor Make/Model: Cimarron 48" HV ECD ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: 800°F Waste Gas Heat Content: X535 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.03 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 (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -30 psig Describe the separation process between the well and the storage tanks: Separators separate the fluids and natural gas and heater treaters flash gases from the liquid. Redline per application. (HDS 07/29/2020) a COLORADO Form APCD-210-Crude Oil Storage Tank(s)APEN - Revision 07/2020 4 ( MOP "' � sum Permit Number: 20WE0634 AIRS ID Number: 123 i9E51 /001 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN forms. Is any emission control equipment or practice used to reduce emissions? IJ Yes O No If yes, describe the control equipment AND state the requested control efficiencies(report the overall,or combined, values if multiple emission control methods were identified in Section 6): Overall Requested Pollutant Control Equipment Description Control Efficiency i (%reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the i o g o ,,or re. re uc/ issions data? 2018 Use the following table to report the criteria pollutant emissions from source: Emission Factors Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled I Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions$ Emissions ' Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 0-752 Ibsibbl Site-Specific 86.27 4.31 1 103.52 5.18 NO. 0.068 Ib/MMBtu AP.42 0.65 0.65 I 0.78 0.78 CO 0.31 I lb/MMBtu I AP-42 2.96 I 2.96 I 3.54 3.54 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 7 Attach crude oil laboratory analysis, stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 9 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑No pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factors Actual Annual Emissions Abstract I Source Uncontrolled Controlled Chemical Name Uncontrolled Service(CAS) Units I (AP-42, Emissions Emissions8 Number Basis I Mfg.,etc.) (ibs/year) (lbs/year) Benzene 71432 0.002 Ibsibbl Site-Specific 534.41 — 26.72 Toluene I 108883 0.002 Ibslbbl Site-Specific I 390.99 19.55 Ethylbenzene 100414 5.86E-05 Ib&bbl Site-Specific 13.44 I 0.67 Xylene 1330207 8.02E-04 Ibslbbi Site-Sped9c 183.99 I 9.20 n-Hexane 110543 D.0201 Ibsibbl Site-Specific 4,601.48 i 230.07 _____ 2,2,4-Trimethylpentane 540841 0.0020 Ibsibbl I Site-Specific 448.73 —1 22.44 7 Attach crude oil laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees wilt be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. COLORADO Form APCD-210-Crude O5 Storage Tank(s)APEN- Revision 07/2020 5 Redlines per application. (HDS 07/29/2020) Permit Number: 20WE0634 AIRS ID Number: 123 /9E51 /001 [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 10 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If plis.is a registration for coverage under General Permit GP08, I further certify that this source is and will be opera: d' full ompliance with each condition of General Permit GP08. 3 9_ _ 20 Signature o egally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations 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$216.00 and the General For more information or assistance call: Permit registration fee of$353.13,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD-21O-Crude Oil Storage Tank(s)APEN - Revision 07/2020 6 I �,�"�;�. „ k'E l 1, ol 2019 CDPHE 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.An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. 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: 16WE0646 AIRS ID Number: 123 /9E51 /003 Section 1 -Administrative Information Company Namer: CCRP Operating Inc. Site Name: Cox 22-B Site Location: NENW Sec. 22. T12N. R64W Site Location Weld County: Hereford, CO NAICS or SIC Code: 211111 Mailing Address: 717 17th Street, Suite 1525 (Include Zip Cale) Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720) 961-9100 E Mail Address2: imyers@clearcreekrp.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.My changes wilt require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. cotoaaoo Gas‘e—r...1 AFE.`i Fes,I or 7 :C"3 11 A® Permit Number: 16W E0646 AIRS ID Number: 123 /tEs1/003 Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source -Oa- ✓0 MODIFICATION to existing permit(check each bas below that applies) O Change fuel or equipment O Change company name3 O Add point to existing permit 0 Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERAUT ACTIONS - • Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. '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: Combustion of gas from separator sent to enclosed flare. Company equipment Identification No. (optional): For existing sources,operation began on: 12/01/2015 For new, modified, or reconstructed sources, the projected start-up date is: ®Check this box if operating hours are 8,760 hours per year;if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Witt this equipment be operated in any NAAQS ❑ Yes 0 No nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of(HAP)Emissions? ❑ Yes Q No Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Q Yes O No _ totoe.oe r_ SPCC- :1 '.,rs Venl-nss a?�ri Revs:cn 7 2:31,?. 2 I m s 7 7 w w Permit Number: 16WE0646 AIRS ID Number: 123 bats-/003 Section 4 - Process Equipment Information Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gat/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Slowdown Events #of Events/year: Volume per event: MMscf/event [] Other Description: V 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? O Yes 0 No Vent Gas BTU/SCF Gas Venting Heating Value: IS t°1-- Process Parameters: Requested: 11.-1 MMSCF/year Actual: c. M Y MMSCi/ ear -0R- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters: Molecular Weight: 27.215 VOC(Weight%) 44.67 Benzene(Weight%) 0.03 b Vented Gas Toluene(Weight%) .045 Properties: Ethytbenzene(Weight 0.01 1 kl Xytene(Weight%) 0.0250 n-Hexane(Weight%) 0.411 2,2,4-Trimethyipentane O.OQQ4 (Weight%) Additional Required Information: O Attach a representative gas analysis(including BTEX l3 n-Hexane, temperature,and pressure) ❑ Attach a representative pressurized extended Liquids analysis(including BTEX&n-Hexane,temperature, and pressure) s Requested values will become permit limitations.Requested lim#(s)should consider future process growth. F r^ ^-� - AV COLOOA6e arc_. _, Gas't it ng:AE`! ?e.ts:on 7 2,72'3 3 Permit Number: 16WE0646 AIRS ID Number: 123 /9ES'/003 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.94503 1.104.457025 Operator Discharge Height Temp. Flow Rate Velocity Stack ID No. Above Ground Level rF) (ACFM) (fUsec) (Feet) Q04 32 2300 600 1.42 Indicate the direction of the stack outlet:(check one) ®Upward O Downward O Upward with obstructing raincap O Horizontal ❑Other(describe): Indicate the stack opening and size:(check one) ®Circular Interior stack diameter(inches): 36 Other(describe): 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: Size: Make/Model: © VRU: Requested Control Efficiency: 1l VRU Downtime or Bypassed: Pollutants Controlled: VOCs and HAPs Rating: 36 MMBtu/hr Tom: ECD Make/Model: Project Consultants.LLC/ECC•30 p Combustion Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 5{{5 Btu/sd Constant Pilot Light: 0 Yes O No Pilot burner Rating: MMBtu/hr O,w= .: Pollutants Controlled: OtherDescription: Requested Control Efficiency: IrlL dl1t shY1; kw- 0 Permit Number: 16WE0646 AIRS ID Number: 123 /sts'/003 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(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SOS NO„ CO - VOC ECO 95 HAPs ECD ... 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx t.1 Ib/MMSCF vws gin a.n*aa 0,Oi O.0l O.t)L om. NOx 0.068 lb/MMBtu AP•42 13.5-1 0.5t ©.61 p.trl 0-cal CO 0.31 lb/MMBW AP-42 13.5.1 L.3L t•32_ 1.."34 Z.'} VOC ')lcr,.vto Ib/MMSCF wsaast.+sios 1St.11 4..1.01 1St.1S4 4.i44 — Non-Criteria Reportable Pollutant Emissions inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Number Basis Mfg.,etc.) (pouidslyeor) (ponds/year) Benzene 71432 _ t.S.45 itilM0.15CF v.s gas asalstna 1.145.S rt..3 Toluene 108883 St..i1 Ib1MAMSCF %lot ass.a MJs 30...1 IS. . Ethylbenzene 100414 1,1 lb/MMSCF vs.sps.M+aniS 3s .$ Xylene 1330207 Ii•vc iWMMSCF vow gass.erans 11O.`1 6.5' - n-Hexane 110543 3+51.P1 IbrMMSCF wow tin«inns 33St.3 1 W.to 2,2,4- • 540841 D,to IhIMM5tf w.s..«s..sen. Trimethylpentane Z,°1 0.1 Other. 5 Requested values will become permit limitations.Requested timit(s)should consider future process growth. •Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave think. 0'S 5 I �� cowR�o• l Arm..: .t ,.:as�e,1ti...g aPEN - K'elmon i 'it4o.y .a%01161.1.51 j e, tO t'O •a. .c,u,.�w�. f_-/ 4,Ab EttiviltotO Permit Number: 16 W E0646 AIRS ID Number: 123 /%II/003 Section 8-Applicant Certification I hereby certify that ay/information contained herein and information submitted with this application is complete, true,and correct 1-ZB-ZvM Signature of Legally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations Name(please print) Title Check the appropriate box to request a copy of the: QQ Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee andlor 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 Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-81 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692.3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment hops://www.colorado.itov/ct /apcd ®� caiai�oo „ a= r 35 'yen ��'� ��.�,_. :,"3_ 6 l war ..,�s,,, Received 07/10/2020 Produced Water Storage Tank(s) APEN 440 Form APCD-207 C +CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities,including APEN updates. Incomplete APE%will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source(e.g. crude oil storage tanks,condensate storage tanks,hydrocarbon liquid loading,etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. 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: 20WE0635 AIRS ID Number: 123 /9E51 /004 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': CCRP Operating Inn Site Name: Cox 22-B Site Location Site Location: NENW, Sec 22, TI2N, R64W County: Weld Hereford, CO NAICS or SIC Code: 211111 Mailing Address: (Include Zip Code) 717 17th Street, Suite 1525 Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720)961-9100 E-Mail Address2: imyers@clearcreekrp.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on alt documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices wilt be issued by the APCD via e-mail to the address provided. COLORADO Form APCD-207-Produced Water Storage Tank(s)APEN Revision 07/2020 1 11== , Permit Number: 20WE0635 AIRS ID Number: 123 /9E51 /004 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2 -Requested Action 0 NEW permit OR newly-reported emission source ❑Q Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP05 O GP08 If General Permit coverage is requested,the General Permit registration fee of$353.13 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit O Transfer of ownership4 O Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit exempt/grandfathered source o Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: Previous application had requested coverage under GP08, now requesting coverage under 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-104)must be submitted. Section 3 -General Information General description of equipment and purpose: Storage of produced water prior to truck loadout Company equipment Identification No. (optional): For existing sources,operation began on: 12/01/2015 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: 0 Exploration&Production(EftP)site O Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? O Yes 0 No Are Flash Emissions anticipated from these storage tanks? 0 Yes O I No Are these storage tanks located at a commercial facility that accepts oil production I wastewater for processing? ❑ Yes 0 No Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? 0 Yes O No I 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. Areyou requesting≥6 ton/yr VOC emissions q g y (per storage tank),or are uncontrolled actual 0 Yes ❑ j No emissions≥6 ton/yr (per storage tank)? i COLORADO Form APCD-207-Produced Water Storage Tank(s)APEN - Revision 07/2020 2 I £''( I'^"°Mt. Permit Number: 20WE0635 AIRS ID Number: 123 /9E51 /004 [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' (bbUyear) (bbUyear) Produced Water Throughput: 241,338 265,472 From what year is the actual annual aunt' 2018 Tank design: ❑r Fixed roof ❑ Internal floating roof ❑ External floating roof Storage #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 (bbO Storage Tank(month/year) (month/year) PW 1-3 3 1,100 08/2018 I 01/2016 I Wells Serviced by this Storage Tank or Tank Battery6(E£tP Sites Only) API Number I Name of Well Newly Reported Well 05 - 123 - 41933 Cox 1 0 05 - 123 - 41935 Cox 5 0 0 I ❑ 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 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 -Geographical/Stack Information Geographical Coordinates { (Latitude/Longitude or UTM) 40.998623,-104.535017 0 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 Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) ("F) (ACFM) (ft/sec) 003 11.6 1200 20.83 0.028 Indicate the direction of the stack outlet: (check one) ❑Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑� Circular Interior stack diameter(inches): 48" ❑Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑Other(describe): `COLORADO Form APCD-2O7-Produced Water Storage Tank(s)APEN -Revision 07/2020 31 l; Permit Number: 20WE0635 AIRS ID Number: 123 /9E51 /004 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 6 -Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: %. VRU Downtime or Bypassed (emissions vented): % Pollutants Controlled: VOCs and HAPs Rating: 2 MMBtu/hr Type: Enclosed combustor Make/Model: S'imarmn/48" STD FCD O Combustion Requested Control Efficiency: 95 Devoe: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 500°F Waste Gas Heat Content: 1,496 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 0.03 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 (E6tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —30 psig Describe the separation process between the well and the storage tanks: Separators separate the fluids and natural gas and heater treaters flash gases from the liquid. Redlines per email. (HDS 07/29/2020) ;;.;.;. COLORADO Form APCD-2O7-Produced Water Storage Tank(s)APEN - Revision 07/2020 4 Permit Number: 20WE0635 AIRS ID Number: 123 /9E51/004 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? 0 Yes O No If yes, describe the control equipment AND state the requested control efficiencies(report the overall,or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Descri Description Overall Requested P Control Efficiency • (%reduction in emissions) V0C L ECD 95 NOx CO HAPs ECD 95 Other: Q From what year is the fohow n reported stu.xl annual fissions data? 2018 Use the following table to report the criteria pollutant emissions from source: Emission Factor? Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled AP-42, Basis Units ( Emissions Emissions$ Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 0.262 ibsibbi CDPHE 31'.62 1.58 . 34.78 1.74 1 NOx 0.068 lbs/NIM8tu AP-42 0.45 0.45 0.49 0.49 1 CO 031 Ibs/MMBiu 1 AP-42 2.05 2.05 2.25 2.25 1 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 APEN5,including APEN updates. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. Section 9 Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria ®Yes ❑No pollutants(e.g. HAP -hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor? Actual Annual Emissions 1 Chemical Name Abstract Uncontrolled Source Uncontrolled . Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions Number Mfg.,etc.) abs/year) (ibs/year) Benzene 71432 0.00) Ibs/bbl CDPHE 1,689.37 84.47 Toluene 108883 _ . - Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.022 lbs/bbl CDPHE j 5,309.44 265.47 12,2,4-Trimethylpentane 540841 J 7 Attach produced water laboratory analysis,stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. • COLORADO Form APCD-207- Produced Water Storage Tank(s)APEN - Revision 07/2020 5 I Iilwa 0 sown: am. per email. (HDS 07/29/2020) Permit Number: 20WE0635 AIRS ID Number: 123 /9E51 /004 [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 10 Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If thi is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will open ed in full compliance with each condition of the applicable General Permit. 1/1:/ I_U.." 2 024) Signature of Legally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$216.00 and the General For more information or assistance call: Permit registration fee of$353.13, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692.3175 Air Pollution Control Division OR APCD-SS-B1 (303)692.3148 4300 Cherry Creek Drive South Denver, Co 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment 4,11AI[OLORADO' Form APCD-207- Produced Water Storage Tank(s)APEN - Revision 07/2020 6i , '!°''r,Va""""IWU.i .. l w..y A cDPHE Gas Venting APEN - Form APCD-211 tzt- 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. 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.cot rada.Qnv,cdphe pcd. 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: f I u/E 007,6 AIRS ID Number: 123 /9E51 / )O'`7 ,1' t1r._ Ac kJ'l aire3' dti:' r 'D Section 1 -Administrative information Company Name': CCRP Operating Inc. Site Name: Cox 22-B ocation Site Location: NENW Sec. 22. T12N. R64W Site county: Weld Hereford, CO NAICS or SIC Code: 211111 Mailing Address:(Include Zip Cow) 717 17th Street, Suite 1525 Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720)961-9100 E-Mail Address2: imyers©clearcreekrp.com 'the 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.My changes will require additional paperwork. 2Permits,exemption letters,and any processing invokes will be issued by the APCD via e-mail to the address provided. 390175 `& t ( Aly fC011.0 mow.« Permit Number: AIRS ID Number: 123 /stash! — Section 2 - Requested Action permit OR newly-reported❑ NEW emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 O Add point to existing permit ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ED Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: CCRP performed an preamMuy stack test to detemMne the%deswctton removal that could be defined for the enclosed flare. Results indicated a greater than 99.9%destruction removal,thus,this appdcatton Is requesting 99%destructon removal for the source.Stack test results attached. 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: Combustion of gas from separator sent to endosed combustor. Company equipment Identification No. (optional): For existing sources,operation began on: 12/1/2015 For new,modified, or reconstructed sources, the projected start-up date is: ®Check this box if operating hours are 8,760 hours per year; if fewer,fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS O Yes 0 No nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of(HAP)Emissions? O Yes Q No Is this equipment subject to Colorado Regulation No.7, Section XVII.G? 0 Yes ❑ No W cocaeaao 2I 'I Permit Number: 1C‘ � AIRS ID Number: 123 /,F„ Section 4 - Process Equipment Information Q Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/past ❑ Blowdovm Events #of Events/year: Volume per event: MMscf/event ❑ Other • Description: 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? [J Yes 0 No Vent Gas 67O/SCF Gas Venting Heating Value: 5►0.1. Process Parameters$: Requested: Ill,.S" MMSCF/year Actual: tt t...zN Ye MMSCF/ ar -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5• Molecular Weight: 27.21 5 VOC(Weight%) 44.67 Benzene(Weight%) 0.03%. Vented Gas Toluene(Weight%) 0.045 Properties: Ethylbenzene(Weight 0.011 Xylem(Weight%) 0.0250 n-Hexane(Weight%) 0.4841 2,2,4-Trimethylpentane 0.0004 (Weight%) Additional Required Information: Q Attach a representative gas analysis(including BTEX&n-Hexane,temperature, and pressure) o Attach a representative pressurized extended liquids analysis(including BTEX&n-Hexane, temperature,and pressure) 5 Requested values will become permit Limitations.Requested limit(s)should consider future process growth. _, 3 I �, _ +,h 'm�•7c ,� aura ;,�,,-is '7� � ..` ;..4.11' re %�� +t't ;CA ti 041/4. 1 1 ND t ("lit*AO Permit Number: MRS ID Number: 123 has,I Ce1-- 106.0€ volke Section 5 - Stack Information Geographical Coordinates (Latitude/Lonpitude or UTM) 40.94503/-104.457025 Operator Discharge Height Temp. Flow Rate Velocity Stack ID No. Above Ground Level (.F) (ACFM) (ft/sec) (Feet) 005 35 005 35 2300 694 0.23 Indicate the direction of the stack outlet: (check one) Q 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): 96 []Other(describe): 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. Pollutants Controlled: Size: Make/Model: VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOCs and HAPs Rating: 42.5 MMBtu/hr Type: ECD Make/Model: Crimson Energy,LLC/CE-1000 Combustion 1 eice: Requested Control Efficiency: q$ % .a 1tx: 9— i'—0t Q, Manufacturer Guaranteed Control Efficiency: at least 98 % Minimum Temperature: Waste Gas Heat Content: i5la.L Btu/scf Constant Pilot Light: ✓[0 Yes O No Pilot burner Rating: MMBtu/hr Pollutants Controlled: Other: Description: Requested Control Efficiency: l Gi/IVR RPV 11"43 S'` `t 14DS. LA(Ib Permit Number: Iqu'1t AIRS ID Number: 123 /yes,/ t; 4 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('K reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (X reduction in emissions) PM SOx NOx CO VOC ECD s!'qr HAPs ECD e'r- Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM sox L.1 lb/MMSCF volt p.s.m,asns o.tt 04 t t_ o;tq a.1 NOx 0.068 Ib/MMSCF AP-42 13.5-1 .Vi t4N — 9. ot.ith CO 0.31 Ib/MMSCF AP-42 13.5-1 SS.(4- Yg,0t 4 i la t•ii 3, VOC 4 o.toto Ib/MMSCF wit c s.m,ss OnS 1.,t{4:4-•tX✓ 'SL.4 tSt4t.Sti 51•.L to Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Number Basis Mfg.,etc.) (pounds/year) (pounds/yead_ Benzene 71432 t.S.v5 uIMMSCF writ gas.mwiat. ytQ4 c0s,`t Toluene 108883 'St..5i b/MMSCF %Iowanwams Stilt.5 104.n¢ —_ Ethylbenzene 100414 1.e( IbMIMSCF w k Vent Iiti.5 1.C.1.0 Xylene 1330207 r4..g5 Ib1MMSCF vont ass nnls.wa,s 2'1ft.5 96.1 ` n-Hexane 110543 _551.i'1 Ib$AMSCF Vent ism omissions Stxckn,} ilSI.y 2'2'4- 540841 0.1 ti/MMSCF Vent oss*rowans 4.4%.11.0 Trfinethylpentane _ 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. AT cattail:Do Fle-t,AO:C. 4{t :_id aert'I APc,-:P 4't....,c;;)n 7 1^18 5 I Ana IteXM"-r--U tries-kies-Stol o•t, a?ckcickgot� t iCot3 0�.'t C.1»Ac+u I I . 1.1'1 014 i v f toLQ Permit Number: AIRS ID Number: 123 /ns,1 Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations Name(please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance El 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, ILC. 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 Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.ttov/cdphe/apcd 6 1 A c©�oA.so Hello