HomeMy WebLinkAbout20202711.tiff . .. COLORADO
to 4,400 Department of Public
te Health Er Environment
RECEIVED
Weld County - Clerk to the Board AUG 2 1 2020
1150O St
PO Box 758 WELD COUNTY
Greeley, CO 80632 COMMISSIONERS
August 17, 2020
Dear Sir or Madam:
On August 18, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
HighPoint Operating Corporation - RSU Anschutz Fed 4-61-4 NW Production Facility. A copy of this
public notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
kC O,
ti` 1 P.
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe 175
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director *. #,'.
P(JbI; c. Rev:e J CC:Q1,(TP) ►-ILC)S),pW(3-KmalCN/CK), 2020-2711
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oq loci/20 09/0 /20
Y Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
CDPHE
TM Comment
Website Title: HighPoint Operating Corporation - RSU Anschutz Fed 4-61-4 NW Production Facility - Weld
County
Notice Period Begins: August 18, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: HighPoint Operating Corporation
Facility: RSU Anschutz Fed 4-61-4 NW Production Facility
E�tP Wellpad
Lot 4, Sec 4, T4N, R61W
Weld County
The proposed project or activity is as follows: Applicant proposes the construction of a condensate storage
tank battery, a produced water tank battery, and liquid loadout of condensate to tank trucks.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0524 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Ben Fischbach
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
1 I ,00" Health&Enviromn nt
" COLORADO
Air Pollution Control Division
� Department of Pubiic I leatth&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0524 Issuance: 1
Date issued:
Issued to: High Point Operating Corporation
Facility Name: RSU Anschutz Fed 4-61-4 NW Production Facility
Plant AIRS ID: 123/A0E2
Physical Location: Lot 4 Sec 4 T4N R61 W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID Point Description
Twelve (12) 400 barrel fixed roof storage
Crude TKs 004 Enclosed Flare
vessels used to store crude oil
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
Page 1 of 10
C �&: COLORADO
Air Pollution Control Division
Department of Pubic Heath&tnvtronment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the 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
Crude TKs 004 --- 22.5 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 factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 10
.�: , COLORADO
iv tgliAir Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Crude TKs 004 Enclosed Flare VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
Crude TKs 004 Crude Oil throughput 1,314,000 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by
means of visual observation from the outside of the enclosed combustion device, or by
Page 3 of 10
. ;# ' COLORADO
Air Pollution Control Division
COME
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
other means approved by the Division, determine whether it is operating properly.
(Regulation Number 7, Part D, Section I.C.) (State only enforceable)
13. 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.
14. 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.
15. The storage tanks covered by this permit are subject to the venting and Storage Tank
Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section
II.C.2.
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 these points, the owner or operator must follow the most recent operating
and maintenance (0&tM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the 0&tM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 4 of 10
�—, COLORADO
410 '10110" Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. 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
GP10 123/A0E2/001 123/A0E2/004
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
•; Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more,above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. 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.
22. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
Page 5 of 10
-r�:•'L ' COLORADO
• W. Air Pollution Control Division
Department of Public I feattn&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
28. 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.
29. 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
C _ „,„....,•:-r. COLORADO
AID Air Pollution Control Division
Department of Public Heattn b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to HighPoint Operating Corporation
Synthetic Minor Facility
Page 7 of 10
-r,�:C _ z COLORADO
Air Pollution Control Division
Department of Public Health&Envtronrnent
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 2,767 138
Toluene 108883 1,817 91
Ethylbenzene 100414 241 12
004 Xylenes 1330207 485 24
n-Hexane 110543 21,287 1,064
2,2,4-
540841 9 0
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 0.0012 0.0012 AP-42 Chapter
CO 0.0055 0.0055 13.5
VOC 0.6839 0.0342
71432 Benzene 2.11 * 10"3 1.05 * 10"4
Page 8 of 10
. COLORADO
''i . ill Air Pollution Control Division
Department cf Public Health ET Environment
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
108883 Toluene 1.38 * 10-3 6.92 * 10-5
100414 Ethylbenzene 1.84 * 10-4 9.19 * 10-6
1330207 Xylene 3.69 * 10-4 1.84 * 10-5 Flash Liberation
110543 n-Hexane 1.62 * 10-2 8.14 * 10-4 Analysis + TANKS
4.0.9d
2,2,4-
5408417.10 * 10-6 3.55 * 10-4
Trimethyipentane
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
The uncontrolled emissions factors for this point are based on a Flash Liberation Analysis of pressurized crude oil to
account for flash gases, and a TANKS 4.0.9d model to account for Working and Breathing losses. Flash
liberation data is based on a FLA sample report which analyzed a pressurized oil stream at the RSU Anschutz
Fed 4-61-4 Facility. The sample was collected on 4/22/2020 at a pressure of 8.2 psig and 115F, and
analyzed 4/29/2020 under stock tank conditions of 12.2 psia and 89F. The TANKS 4.0.9d model used the
component"Gasoline(RVP 7)" based on the analyzed stock tank liquid RVP of 6.2.
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, CO, NOx, and n-Hexane
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC, NOx
MACT HH 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
Page 9 of 10
JA I COLORADO
410 allowl" Air Pollution Control Division
COP HE
Department cf Pubic Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
a .. COLORADO
t Air Pollution Control Division
Department at Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0525 Issuance: 1
Date issued:
Issued to: High Point Operating Corporation
Facility Name: RSU Anschutz Fed 4-61-4 NW Production Facility
Plant AIRS ID: 123/A0E2
Physical Location: Lot 4 Sec 4 T4N R61 W
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 TKs 005 Two (2) 400 barrel fixed roof storage Enclosed Flare
vessels used to store produced water
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
Page 1 of 9
�r���<,x� COLORADO
L �- Air Pollution Control Division
�-� Department of Public Health Ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.cotorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit atone 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,t VOC CO Type
PW TKs 005 --- --- 0.1 --- Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 9
ky COLORADO
>411, -.0-09. Pollution Control Division
1
I Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
PW TKs 005 Enclosed Flare VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
PW TKs 005 Produced Water throughput 788,400 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. No owner or operator of a smokeless flare or other flare for the combustion of waste gases
must allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. 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
Page 3 of 9
•r:',,c�� ICOLORADO
•^ kw Air Pollution Control Division
ttre Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
14. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (0&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the 0&tM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. 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
GP10 123/A0E2/001 123/A0E2/005
18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of 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
Page 4 of 9
.�: COLORADO
> Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4/V.A.7.B).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization section
of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
Page 5 of 9
.r:•K COLORADO
Air Pollution Control Division
�►� Department of Public Heattn&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions),-122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to HighPoint Operating Corporation
Synthetic Minor Facility
Page 6 of 9
C _, ,,,„...,::-r. COLORADO
ire Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 277 14
Toluene 108883 167 8
001 Ethylbenzene 100414 15 1
Xylenes 1330207 25 1
n-Hexane 110543 88 4
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 3.03 * 10-5 3.03 * 10-5 AP-42 Chapter
CO 1.38 * 10-4 1.38 * 10-4 13.5
VOC 0.0055 2.75 * 10-4
71432 Benzene 3.52 * 10-4 1.76 * 10-5 Flash Liberation
108883 Toluene 2.11 * 10-4 1.06 * 10"5 Analysis
100414 Ethylbenzene 1.97* 10-5 9.83 * 10"7
Page 7 of 9
-r,�:x COLORADO
I Vior ( Air Pollution Control Division
I Department of Public Health&Environment
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
1330207 Xylene 3.17 * 10-5 1.59 * 10-6
110543 n-Hexane 1.11 * 10-4 5.55 * 10"6
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
The uncontrolled emission factors are based on a Flash Liberation Analysis report which analyzed a pressurized water
sample from the RSU Anschutz Fed 4-61-4 Facility. The sample was collected on 4/22/2020 at a pressure of
130 psig and 133F, and analyzed 4/28/2020 under stock tank conditions of 12.2 psia and 60F.
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, CO, NOx, and n-Hexane
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC, NOx
MACT HH 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.Rov/
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
Page 8 of 9
•rC _ ,1•x. COLORADO
4110 itre' Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
•
Page 9 of 9
Ca‘-r.:*r COLORADO
t��/ Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0526 Issuance: 1
Date issued:
Issued to: High Point Operating Corporation
Facility Name: RSU Anschutz Fed 4-61-4 NW Production Facility
Plant AIRS ID: 123/A0E2
Physical Location: Lot 4 Sec 4 T4N R61 W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
ID Point Equipment Description Description
LOAD 006 Truck loadout of crude oil by Enclosed Flare
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 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 11
ter.-:•r- COLORADO
Air Pollution Control Division
I Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must 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:
AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
LOAD 006 --- --- 3.4 --- 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 factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 11
C _ ,,,,„...z.:-e- COLORADO
Air Pollution Control Division
Department of Public Flealtn&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Control Device Pollutants Controlled
ID Point
LOAD 006 Enclosed Flare VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing 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
LOAD 006 Crude Oil Loaded 1,314,000 barrels
The owner or operator must calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. 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.)
Page 3 of 11
-�.*:,v COLORADO
1 Air Pollution Control Division
ai�� Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
• 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 loss 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.
Page 4 of 11
C -r:•z- COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
• 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 Ft MAINTENANCE REQUIREMENTS
18. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (0EM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your 0EtM 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
19. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 5 of 11
C- ..,r,...,.,...:7- COLORADO
1. t Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Periodic Testing Requirements
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
GP10 123/A0E2/001 123/A0E2/006
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 (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.
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 6 of 11
-N:*r COLORADO
10 4h4A'01II Air Pollution Control Division
iii
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 (Reference: Regulation Number 3, Part D, V.A.7.B).
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.
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.
Page 7 of 11
C40
,,, COLORADO
Air Pollution Control Division
Department cf Public tfeatth&Er ironment
Dedicated to protecting and improving the health and environment of the people of Colorado
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: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to HighPoint Operating Corporation
Synthetic Minor Facility
Page 8 of 11
�•r,Y�:•z�� COLORADO
• *"1606,0" Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See:
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 237 12
006
n-Hexane 110543 2102 105
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Uncontrolled Controlled
Pollutant CAS # Emission Emission Source
Factors Factors
lb/bbl lb/bbl
NOx 1.89 * 10-4 1.89 * 10-4 AP-42
Chapter
CO 8.64 * 10-4 8.64 * 10-4 13.5
VOC 0.104 5.20 * 10-3
CDPHE
Benzene 71432 1.8 * 10"4 9.00 * 10-6
Page 9 of 11
xa� COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
Pollutant CAS # Emission Emission Source
Factors Factors
lb/bbl lb/bbl
n-Hexane 110543 1.6 * 10-3 8.00 * 10"5
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, CO, NOx, and n-Hexane
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC, NOx
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.govi
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
Page 10 of 11
COLORADO
Air Pollution Control Division
Dewy
Department at Pubtte Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Son Fischbach
Package#:
Received Date:
Review Start Date: 7/1:3/2020
Section 01-Facility Information
Company Name: Sighnoint Operating Corporation Quadrant Section Township Range
County AIRS ID: 123: 4 51W
Plant AIRS ID: 40E2 Lot4
Facility Name: ft-U Av;chutz fed 4-61-4 SW Production Facility
Physical
Address/Location: _ _.
County: Weld County
Type of Facility: Eataraiion&Production Well Pad
What industry segment?=031&Natural Gas Production&R-ocessing ,..
Is this facility located in a NAAQ5 non-attainment area? Yes
If yes,for what pollutant? .Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
Permit#
AIRS Point#
Emissions (Leave blank unless Issuance Self.Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit tn;r al
004 Storage Tank ,.....z ifs Yes 20W5052- I Yes Issuance
Analysis Page
Hidden in this
,'Jurkbpok-see
Per Rem& VVE0525.CP1.
1105 - Storage"tank MN I Yes 2OWF.175.l5 _ Yes Issuance PA for analysis
Analysis Page.
Hidden in this
Workbook-see
Permitltd₹''uf 20WE0526.CP1
006 Liquid loading LOAD Yes 20WE05?5 Yes Issuance PA for analysis
•
Section 03-Description of Project
Facility started up 2/20/202e via a GPt0 which was received 2/3/2020.
Applicant proposes the construction of a condensate stol-age tank battery,a prof-ed wafer tank battery,and lic, lit ixdout of condensate to-tank trucks
Operator included a rassina Method 22 observation demonstration form in permitapplication,so initial resting of this source is not required.
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Fes
If yes,why? Fsisia'icy Synthetic Minor PeNnit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? '.iva If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stalionary 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 VOperating
of acing Permit Deterioration(PSD) E - 9 1 1 ® ❑ ❑
Title V Operating Permits(OP) i�JT
Non-Attainment New Source geview(NANSR) f
Is this stationary source a major source? Na
If yes,indicate programs and which pollutants: 502 NO, CO VOC
PM2..55 PM10 TSP HAPs
Prevention of Significant Deterioration IPSO) 7 El - 1=1
❑
Title V Operating Permits(OP) , ₹El
Non-Attainment New Source Review(NANSR)
EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3)
Ex=Ct.MW.Xz/C
Ex=emissions of pollutant x
Q.Volumetric flow rate/volume of gas processed
MW=Molecular weight of gas=SG of gas*MW of air
)(4=mass fraction of x in gas
C=molar volume of Ideal gas(379 scf/Ib-mo1)at 60F and 1 atm
IMW 49.1059 Ib/Ib-mol
Throughput 365 bbi/year
Gas-to-Oil Ratio(GOR) 5.5 scf/bbl
mass fraction(%) Emission Factor(lb/bbl( Emissions(Ibs/year) 109500 bbl/yr - '
Helium 1.13 364.:e?3
CO2 0,54 1 00 R..3 ::i "p:076Cv6D27 lb/bbl W&B emissions
N2 5.90 •0 70,0 7,
H25 ,.^•.r-C, 8392.11 lb/yr ue&b
methane 0.54 0..0..4i.4
ethane 6.58 313. ,. .
propane 30.43 1 00465,, ^
isobutane 6,71 ar ., . .. '..l}*„s'"
n butane 23,92 I.?f:,,?: FLASH \roB
,
Isopentane 6.2% 4.46•I...:_ . an
n-pentane 7.19 ,:+ 1241000 9,000006 6,90E07 _
cyclopentane - 0.65 I,,-E' 6ellO ne 0101670' 2:01E-04l `
n-Hexane 202 " ' 7 •:• Takuenx ,(3.086€228 1.32E-04 " vt
ne 0.47 •'. Best '-IZCtle 0,000166 1,79E-05 •
it_
cyl h
Other h nes 3.56 , ,. Xy'000E 0000327' 3,53E-05
hoptanes 1.34 ,_ ., Si 0alYl x0143600 1,55E-03 :1'7,4
"i
methylcyclohexane 0.42 ..x...a
224-IMP 0410 .4C: .o
Benzene 0,26 1,8••'::i Vi7C :: -0:60728 7.66E-02 . x. f. 2'
Toluene 0,17 :.'3r•.3 _
Ethylbenzene 0412 n.,t• ,
Xylenes 0.05 3.:'c+`. ..
C8 0.53' ._ 1 47
C9 0,09 ,..,0:4 ,.t
010 0.50 15;"_'Js 1
C11+ 0 0001.,00 )40
Total Total
VOC Wt% :. ........ ". -.,..Opy
J:.cr-tti ._ _s.. nvLf1tci•V
Section 01-Administrative Information
(Facility AIRS ID: 123 AOE2 004
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid i '
Detailed Emissions Unit Twefve[12)4DD•7sla4CcU4em yt p-dgetalitts.
Description:
Emission Control Device EGO '
Description:
Requested Overall VOC&HAP Control Efficiency%: 85.0
Limited Process Parameter Fey id throb- v •
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= 1,095,000.0 Barrels(bbl)per year
(Requested Permit Limit Throughput= 1,614,000.0 Barrels(bbl)per year Requested Monthly Throughput= .__I.^ Barrels(bbl)per month ,
Potential to Emit(PTE)CondensateThroughput= - „A14;000.D Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 26D&.0 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced=
Actual heat content of waste gas routed to combustion device= ., -- :MMBTU per year I,x:9-r Calc Sheet Listed(Used in calculations below)
Requested heat content of waste gas routed to combustion device= 0r I MMBTU.per year 7.I:I r Cale Sheet Listed(Used In calculations below)
Potential to Emit(PTE)heat content of waste gas routed to combustion device= ,MMBTU per year -i 20:.,Cabo Sheet Listed(Used in calculations below)
Control Device
Pilot Fuel Use Rate: 156 scfh :a MMscf/yr
Pilot Fuel Gas Heating Value: 1519 Btu/scf 2.o ,MMBTU/yr
Section 04-Emissions Factors&Methodologies
will this storage tank emit flash emissions? r,,-z,.ar,..ti,
Emission Factors Crude Oil Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Crude Oil (Crude Oil
Throughput) Throughput)
VOC E..DUE-G1 i T. 'Flash Liberation Analysis+W&B through TANKS 4.0.9d
Benzene 2.110803 - Flash Liberation Analysis+W&B through TANKS 4.0.9d
Toluene 39003. . � 3k I��, Flash Liberation Analysis+W&B through TANKS4.0.9d
Ethylbenzene 144E-0d T i' -Flash Liberation Analysis+W&B through TANKS 4.0.9d
Xylene 3.53E-04 .,V N i Flash Liberation Analysis+W&B through TANKS 4.0.9d
n-Hexane 1.620E-02 Ak Flash Liberation Analysis+W&B through TANKS 4.0.9d
2247MP 7.10E-08 , r i5' ,-:Flash Liberation Analysis W&B through TANKS 4.0.9d
Control Device
-
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Crude Oil
combusted) Throughput)
PM10 , .
PM2.5 3 0133 ia- 600 -i'+aE,999.79 49899,7
SOx
98999,49.91891,99
NOx .0,.0680 8.3810
CO 0.1100 _.,8 S q
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (ib/MMBtu) (lb/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 _ >>=0
PM2.5 0 48970
SOx :.....,_
NOx 0.0660 _ U Crsptpr135
VOC 9 7S77,
CO 0.3100 449 78 7 AP-42 Chapter 13 Inch.,r:-!
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) )bs/month)
PM10 1.1 s3 10 00 1c ..
PM2.5 0 1 1.1 C U D 1 1 3 ].0
SOx .. .__ 311 0 9 ,_ 0.0
NOx 7 L_. 1 07 fry 114.3
VOC 7871, 4.1934 _2..7 _.....
CO .. 100 3 51 _-_
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (lb./year) (Ibs/year) (Ibs/year( (lbs/year)
Benzene 20'07 11 _315.1 315 3 2157 a_E
Toluene -8:7 3 • 1591.4 73/ 0817 =.
Ethylbenzene Si u 151 2 10'! 2.11 -.
Xylene 184 A 113 A 2:2 .13S 7.1
n-Hexane _1280.8 17739 3 ,07 0 2128%
2247MP 0.3 4 3 0.405
3 of 7 K:\PA\2020\20WE0524.CP1
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B
Regulation 7,Part 0,Sectlon I.C,D,E,F
Regulation 7,Part D,Section 1.6,C
Regulation 7,Part D,Section II.B,C.1,C.3
Regulation 7,Part D,Section II.C,2
Regrifatlon7, While this OPEN is dated after
Regulation.7,Part D,Section Tt.C,4,a.Gi-_. - -.�x _. �.. - May 1,2020,these APENs were
Regulation 6,Part A,NSPS Subpart Kb .,. _ submitted to move equipment
over from a OP10 to mdi4Adual
Regulation 6,Part A,NSPS Subpart 0000 - _,.. st.. -'-: permits,As the tank battery
has not been modified to
NSPS Subpart 00000 +., s , - _. increase capacity since the
Regulation 8,Part E,MAC.Subpart OH _ ,.' z .i'__, original Onto application,and
(See regulatory applicability worksheet for detailed analysis) since the original GPEO
application date preceded May
Section 07-Initial and Periodic Sampling and Testing Requirements 1,2020,this tank battery is not
subject to lI,C.4.a(i)
For condensate or crude oil tanks,does the company use the state default emissions factors to
estimate emissions? S a
If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or 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 60 tpy?
If yes,the permit Will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-07.
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
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 receiveddate.However,if
the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample.
If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14'13.
Ey l
Does the company request a control device efficiency greater than 95%fora flare or combustion device? 4 :tr
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
Site-specific emission factors are based on,a combination of a flash liberation analysis to account for flashing losses,and a TANKS 4.0.9d Model to accountfor W&&losses
Flash liberation data is based on a FtA sample reportwhich analyzed a pressurized oil stream at the HSU Anschutz Fed 4-61-4 Faciliy,The sample was collected on 4/22/2020 at a pressure of 8.2 psig and lISF,and analyzed
4/29/2020 under stock tank conditions of 12.2 psia and 86F.The flash liberation results reported a CUR of 5.5 sef/bbl.
Operator used TANKS 4.0.9d to estimate W&B emissions,based on the assumed component Gasoline(SOP 7),which is conservative and acceptable,giVen areported HOP of 62 for line stock tank liquid properties,also
provided by th flash liberation analysis.report,
Operator included a passing Method 22 observation demonyrration form in permit application,so initial testing of this source is not required. - -
Section 09-5CC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process# 5CC Code Pollutant Factor Control%Units
01 .. PMI0 lb/1,000 gallons Crude Oil throughput
PM2.5 lb/1,000 gallons Crude Oil throughput
505 ., Ih/1,000 gallons Crude Oil throughput
NO0 Hi lb/1,000 gallons Crude Oil throughput
VOC f,__ lb/1,000 gallons Crude Oil throughput
CO a.. lb/1,000 gallons Crude Oil throughput
Benzene .,_ .. lb/1,000 gallons Crude Oil throughput
Toluene 11 lb/1,000 gallons Crude.Oil throughput
Ethylbeazene tr. Ih/1,000 gallons Crude Oil throughput
Xylene ., ' lb/1,000 gallons Crude Oil throughput
n-Hexane _. lb/1,000 gallons Crude Oil throughput
224 TMP „ as lb/1,000 gallons Crude Oil throughput
4 of 7 K,\PA\2020\20W E0524.CP1
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions.
Colo rest deRegulation 3 Parts A and B-APEN and Permit Requirements
ATTAINMENT
3. Are uncontrolled actual emissions from any drceda pollutants from this individual source greaten than 2 II,(Regulation 3,Part A,Section ll.O.I.a), Source Requires an SPIN.Go to
2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 with a storage tank throughput less than 40,000 gallons per year(See PS Memo 14 03 for additional guidance on grandfather applicabilrtyl t Co to next question
3. Are total facility uncontrolled VOC emissions greater than S WPY,NOx greater than 20 IVY or COem,ssions greater than lO TPY(Regulation 3,Part%,Section 8.0.3)1 Source Requires a permit
NON-ATTAINMENT
1 Are uncontrolled emissions from any criteria pollutants horn the individualsoui cP greater than l TPY(Regulation.3,Part A.Section 1n D.1.a)? Ye. Source Requires an API N.G°to
2 Is the construction date prior to 4/14/2014 and not modified atter 4/14/14 with a storage tank throughput less than 40,000 gallons per year(See PS Memo 1403 for additional guidance on grandfather applicability), Ne Go to next question
3. Aretotelfacilhy uncontrolled VOCemusrons greater than 2 TFY,NOx greater than S TPY or co emissions greater than l0TPy(Regulation 3.Part 0,Section e.D.2)1 net Source Requires a Persia
Colorado Regulation],Part D.Section I.C-F&G
1. Is this storage tank located In the R hr ozone control area or any prone non attainment area or attainment/maintenance area(Regulation 7,Part D,Section I.A.1), Continue-You have indicated th
2. Is this storage tank located atoll and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation 1,Part O,Section 1.5.117 Continue You have indicated th
3. Is this storage tank located eta natural gas processing plant(Regulation/,Part D.Section I.G)? Storage Bank is not subject to Re
4. Dues this storage tank contain rondensatet
Does this storagetank exhibn"Hash"leg.storing nor-stabilized liquids)emirions(Regulation 7,part 0.lesion kG 2)1
6. Are uncontrolled actualemusrons of this storagetank equal to or greater than 2 tons per year VOC(Regulation Part D learns LD.3.aln1)? :Yes
Part D,Section l.C.1 General Requirements for Air Pollution Controlfquipmen[ Prevention of leakage
Part 0,Section I.C.2-Emission Estimation Procedures
Part D,Section I.D Emissions Control Requirements
Parto,Section LE Monitoring
Part D,Section IF Recordkeeping and Reporting
Part D,Section I.G.2 Emissions Control Requirements
Part 0,Section 1.0.1.5 and b General Requirements for Air Pollution Control Fquienient Prevention of leakage
Colorado Regulation 7.Part D.Section II
1. Is this storage tank located at a transmission/storage Iacdrty, Continue You have indicated th
7. Is this storage tank'located at an nil and gas exploration andprodurtinn operation,well production facility.natural gas rempressmstaonn'or natural gas processingplant°(Regulation I.Part D.Section II(11 Gate the next question You ha
3. Does thrtstorage tank have atixed roof(Regulation l Part D,Section ll.A 10)1 Yes Go to the next question
4 Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tore per year VOC(Regulation/.Part D,Section R.(Lc)? ,t es Sourer is alined to parts of Reg
Part O.Section ll.B General Provisions for Air Pollution ControlFgmpment and Prevention of Emissions
Part D,Section il.C.1 E missions Control and Monitoring Provisions
Part D,Section II.C.3 Recordkeeping Requirements
5 Inner the storage tank contain only'stabilized•liquids(Regulation J,Part O,Section II.C.2.b)1 Nt• 'Source is subiect to all provision.
Part controlled
star Capture tanaatd at a well ro Storage Tanks titatdal a compir ressor
Control or natural
Is the controlled storage tank located atawell production facility,natural gas compressor station.or natural gas processing plant sonstased an or after May 1,J010 or located at afacilrty that was modified on or after May 1,2020,such
E that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon hquads or produced water(Regulation J,Part D,Section rl.C.4.a.6), Nix Storage Tank c not subject to Re
Is the controlled storage tank located at a well production faults.natural gas compressor station,or natural gas processing plant constructed on or after hessian/1,2021 or located at afautrty that was moddred on or after January 1,
1 2021,such that an addOronal controlled storage vessel is constructed to recewe an anticipated increase is throughput of hydrocarbon hqurds or produced water(Regulation 1.Part D,Section ll.C 4.e.(n)? No
40 CFR.Part 6a.5u6parc Kb,Standards of Pedgrmancefor Volatile Organic liquid Storage Vessels
1 Is the individual storage vessel capacity greater than or equal to lS cubic meters ims)I-4/2 Milts](40 CFR 60110b(a)11 'ear. Storage lank is notcubiett MPS
2 Does the storage vessel meet thefuilowing exemption in 60.111b(d)(4)1
a.Does the vessel has a design capacity less than or equal tot,589874 in'[-10,000BBL]used for petroleums or condensate stored,processed,or treated prior to custody transfer'asdefreed in 60.11lb,
3 Was this storage vessel constructed,reconstructed,or modified(see definition 40CFR,60 2)after July 23,1984(40(IR6O 110b(a))?
4 Does the tank meet the defmniun of"storage vessel"'in 60.1116,
5 Does the storage vessel store a"volatile organic liquid(VOL)"tact defined in 601111,
6 Does the storage vessel meet any one of the following addrtionalexempeons'
a.is the storage vessel a pressure vessel designed to operate in excess of 104 9 kPa(-29.1 par;and without emissions to the atmosphere(60.110b(d)(J)17;or
b.The design uparrty is greater than or equal to 151 m'(^9S0 oni'and stares a liquid with amaxnmum true vapor pressure`less than 3.5 kpa(60 t10b(bl),;or
c.The design capacity a greater than or equal to IS Mn[-412 BSI,but less than 151 m'I'950 RBI;and stores a liquid with a maximum true vapor pressure'less than 15.0 kPa100.110b(b)lo
/ Does the storage tank meet either one of the following exemptions from control requirements:
a.The design tenacity is greater than or equal to 151m'("950 BBL)and stores a liquid wrth a maximum true vapor pressure greater than or equal to 3.SkPa but less than S.2 knot.or
b.The design capacity is greater than or equal toISMd["4/2 HB11 but less than 151 meI-9S0 BC and stores a liquid wrth a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 21.6 kPa?
40 CFR,Pen 60,Su6part 0000/0000e,Standards of Performance far Crude Oil and Natural Gas Production,Transmission and Distribution
1 Is this storage vessel located at a fanlito in the onshore oil and natural gas production segment,natural gas processing segment or natural gm transmission and storage segment of the industry, Continue You have indicatedth
2. Was the storage vessel constructed.reconstructed,or moddied(see definitions 40CFR,60.2)between August 23,2011 and September 18,2015, Net Storage Tank is not subiect NSPt
1. Was this storage vessel constructed,reconstructed.or modified(see deftrutions 40lER,60.21 after September 18,201S, yes Go to the next question
4. Are potentialVOCemneionst Pram the individual storage vessel greater than or equal to 6 tons per yearn No Storage lank s not subject NSF'
S. Does this storage vessel meet the definition of"storage vessel"'per 60.5430/60.5430a,
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 4,10 R Part 60 Subpart Kb or 40 COY Part 63 Subpart Nil?
[Note:If a storage vessel Is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS(moo/Doom,per
60.5365(e)12)/60.5365e(e)(2[even if potential VOC emissions drop below 6 tons per year]
40 CFR.Part 63,Subpart MAR NN,Oil and Gas Production Facilities
1 Is the store etank located at an oil and natural gas production facility that meets ether of the following criteria: Continue You have indicated th
a. Facility that processes,upgrades or stores hydrocarbon liquids'(e3.i6D(a)(21);OR
b. facility thatprocesses,upgrades or stores natural gas prior to the poiat at which natural gas enters the natural gas transmission and storage source category or Is delivered to a final end user'(63.160(4)0)),
2. Is the tank l sated at a iacilny that is malorxfor Ws? Nu 'Storage Tank is not subject MAC
3. Dues the to k meet the definition of"'storage vessel"'in 63./61,
4 Does tneta k meet the definition of"storage vessel with the potential for flash emissions'per 63./61,
S Is the tanks bleat°control requirements under 40CFR Part 60,Subpart Kb or Subpart 0000?
ubpart A,General provisions per 463.164(a)Table 2
63.166 Emissions Control Standards
§63.773 Monitoring
§63.774 Recordkeeping
463.775 Reporting
RACT Review
RAW review is required If Regulation 7 does not apply AN0 if the tank is In the nonattainmeM area.If the tank meets both criteria,then review PACT requirements.
Disclaimer
This document assts operators with determining appecabiity of certain requirements of the Clean Air Act.its implementing regulabons.and An Quaid},Control Cormnssion regulations.This document isnot
a nde orregulahon.and the analysis it contains may not apply toe perticularsduahon based upon the ind edual facts and circumstances This document does not change or substitute for any law.regulation.
or any other legallybmdng 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 regulabons.the language of the statute amputation will control The use ofnon-mandatory language such as'recommend.-may.'should'and'can.-is intended to
describe APCO interpretations and recemmendahans Mandatory terminology such as•must'and'required'are intended to describe controlling requirements under the tams of the Clean Arr Act and Ad
Quality Control Commission regulations.but this document does not establish legally balding requirements in and of itself
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name HighPoint Operating Company
County AIRS ID 123 History File Edit Date 8/1912020
Plant AIRS ID A0E2 Ozone Status Non-Attainment
Facility Name RSU ANSCHUTZ FED 4-61-4 NW
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 0.8 0.8 0.0 0.0 98.2 625.6 0.6 105.1 29.2 0.8 0.8 0.0 0.0 14.7 36.9 0.6 24.7 3.2
Previous Permitted Facilit total 0.4 0.4 0.0 0.0 93,0 625.1 0.0 100.8 29.1 0.4 0.4 0.0 0,0 9.5 36.4 0.0 20.4 3.1
Crude Oil Storage Tank(12)4800 bbl 0.0 0.0 Now permitted under 20WE0524 point 004
Produced Water Stporage Tank(2)800 0.0 0.0 Now permitted under 20WE0625.-point 005
bbl •
001 GP10 Hydrocarbon Loading 0.0 0.0 Now permitted under 20WE0526-point 006
Engine Cat 63408 Generator 0.0 0.0 Now permitted under GP02-Point 002
Engine Cat G3408 Generator 0.0 0.0 Now permitted under GP02-Point 003
Fugitives - 0,0 0.0 Insignificant Source
VRU Blowdowns: 0.0 0.0 Insignificant Source
002 GP02 RICE 4SRB Caterpillar M:G3408 TA SN: 0.2 0.2 46.0 2.7 47.9 0.9 0.2 0.2 3.9 2.7 7.7 0.9 No change
6NB01913
003 GP02 RICE 4SRB Caterpillar M:G3408 TA SN: 0.2 0.2 46.0 2.7 47.9 0.9 0.2 0.2 3.9 2.7 7.7 0.9 No change
6N801213
004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 0.8 449.3 3.6 13.3 0.8 22.5 3.6 0.7 Moving from GP10 to Construction Permit
005 20WE0525 Two(2)400-bbl Produced Water Tanks 2.2 0.3 0.1 0.0 Moving from GP10 to Construction Permit
006 20WE0526 Crude Oil Loadout to Trucks 0.1 68.3 0.6 1.2 0.1 3.4 0.6 0.1 Moving from GP10 to Construction Permit
0.0 0.0
0.0 0.0
XA External Combustion Devices 0.4 0.4 5.2 0.3 4.3 0,0 0.4 0.4 5.2 0.3 4.3 0.0 Insignificant Source
XA Fugitives 0.6 0.0 0.6 0.0 Insignificant Source
XA VRU Slowdowns 0.2 0.0 0.2 0,0 Insignificant Source
0.0 0,0
0.0 0.0
0.0 0.0
FACILITY TOTAL 0.8 0.8 0.0 0.0 98.1 525.7 0.6 104.3 16.6 0.8 0.8 0.0 0.0 13.9 31.9 0.6 23.9 2.5 VOC: Syn Minor(NANSR and OP)
NOx:Syn Minor(NANSR and OP)
CO: Syn Minor(OP)
HAPS: Syn Minor n-Hexane
HH: Area
7777: Area
Permitted Facility Total 0.4 0.4 0.0 0.0 92.9 525.2 0,0_ 100.0 16.5 0.4 0.4 0,0 0.0 8.7 31.4 0.0 19.6 2.5 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions 0.0 0.0 0.0 0.0 -0.8 -5.0 0.0 -0.8 -0.6 Pubcom&modeling(not)required based on (A
change in emissions)and addition of GP02.
Total VOC Facility Emissions(point and fugitive) 32.5 Facility is eligible for GP02 because v 90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -5.0 Project emissions less than 25/50 tpy
Note 1
Note 2
•
Page 6 of 7 Printed 8/10/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Corman Name HiahPointODeratinu Comoarty
County AIRS ID 123
Plant AIRS ID 40E2
Faoilito Name RSU ANSCHUTO FED 4.61.4 NW
Emissions-uncontrolled(lbs per year)
IPOINTI PERMIT (Description Forma.. Aeeeles,vae Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane Me0H 2.4 TOF H2S TOTAL
SW
Previous FACILITY TOTAL 1.5 0.1 0.1 3.1 2.1 0.3 0.5 21.6 0.0 0.0 0.0 0.0 29.1
Crude Oil Storage Tank(71J 4800 bbt _ - A.0
Produced Water Siparage Tank(2) 0.0
800 bbl ..
001 GP10 Hydrocarbon Loading 00..
Engine Cat G3408 Generator 0 0
Engine Cat 03408 Generator 0,0
Fugitives 0.0
VRU 6IOWdAWns 0.0
002 GP02 RICE 4SRB Caterpillar M:G3408 TA 1468.0 60 0 80 0 39(1 14 0 I 0 0 0 28 0 75 4 0.8
SN:86601913
003 GP02 RICE 4SRB Caterpillar M:63408 TA 1468.0 HO 08 11 38.8 14 8 1 U 8 0 28 0 18 8 0.9
SN:ON601213
004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 2767.0 1817,0 2410 485.0 21287,0 90 13.3
005 20WE0525 Two(2)400-bbl Produced Water 277.0 1870 150 200 980 0.3
Tanks
DOB 20WE0526 Crude Oil Loadout to Trucks 237.0 21020 1.2
0.0
0.0
XA External Combustion Devices 0.0
XA FuglRves 40 80 3.0 10 :2/0 0.0
XA VRU Slowdowns 2 0 I.0 0 0 0 0 0 0 0,0
0.0
' 0.0
0.0
TOTAL(tpy) 1.5 0.1 0.1 1.7 1.0 0.1 0.3 11.8 0.1 0.0 0.0 0.0 16.5
`Total Reportable=all HAPs where uncontrolled emissions>de mimmus values
Red Text uncontrolled elreseions ode mimmus
Emissions with controls(lbs per year)
POINTI PERMIT I Desorption Formaldehyde Aoeradenyae Acrolein Benzene Toluene Ethylhenzene Xylenes n-Hexane Me0H .%4 Ter H2S TOTAL
(1ld)
Previous FACILITY TOTAL 1.5 0.1 0.1 0.2 0.1 0.0 0.0 1.1 0.0 0.0 0.0 0.0 3.1
... ., -Crude Cl Storage Tank(12)4800 bbl 0.0
Produced Water Stporage Tank(2) 0.0
800 bbl
801 GpiO Hydrocarbon Loading - 0.0
Engine Cat G3408.Generator 0.0
Engine Cat G3408 Generator ' 0.0
Fugitives ... 0.0
k/Rtd Slowdowns 0.0
002 5002 RICE 4SRB Caterpillar M:G3408 TA 1468.0 60 0 80.(1 38 0 14 0 1 0 5 0 20 0 /S 0 0,9
SN:6NB01913
003 0002 RICE 4SRB Caterpillar M:63408 TA 1468,0 06 0 110 L' 39 0 14 0 1 0 0 0 20 0 75 9 0.9
SN:6NB01213
004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 138.0 91.0 1%0 24.0 1064.0 0.0 07
005 20WE0525 Two(2)400-bbl Produced Water 14.0 60 10 10 4U 0,0
Tanks
006 20WE0526 Crude 011 Loadout to Trucks I/O 105.0 0.1
0.0
0.0
XA External Combustion Devices 0,0
XA Fugitives 1 40 0 0 30 90 270 0.0
XA VRU Slowdowns 20 {u 0 0 0 0 9 U 0.0
0,0
0.0
0,0
TOTAL(tpy) 1.5 0.1 0.1 0,1 0.1 0.0 0.0 0.6 0.1 0.0 0.0 0.0 2.5
7 20WE0524.CP1 8/10/2020
'. faadc)Air Permitting rojesct
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer Per xsciabach r.
Package It: 4315Cs
Received Date �/2(,5202t
Review Start Date' 7/3/2 art
Section Ol-Facility Information
Company Name: PigilEritit Opera t_aoseeration Quadrant Section Township Range
County AIRS ID: 12,1 ;v aN seism
Plant AIRS ID: AC.za Lot 4
Facility Name: PJc archaic-ea af.4.t.1 Preciectien Ferrite
Physical ....
Address/Location. -,, .,
County: Weld County
Type of Facility: ExylorationP F"dPi ye'WaillPad
What industry segment?Oi,,5 regtacrel Gas ProdirriiY,&itrecossing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? O;r' 'INCA 8O/0„,C)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
Permit#
AIRS Point q
Type Equipment Emissions (Leave blank unless Issuance Self Cert Engineering
(L
eave blank unless APCD Emissions SourceT E tName Control? APCD has already q Re Action
has already assigned) Required? Remarks
assigned)
ionsists Page
Vie-slating See:
Permit Initial 20WEktS24,CI
004 0torage:srak -rode`at sea aliglE0524 'run l.st=ance ..1*=_r....',iS:s..
Perini
:DS Sara,e taatt cox Tv, Yes.' 2.t„ELtiti23 Yes sssiter,,e
Aaat;,,.,rage
.Risen ir,this
arksOSr see
Permit i lt,nl «'a'c,i 33.C-A'
.clef; aC,.:iid toan:r.g- _Oise) Yes:. 2,,'AL 5 3>, Yes _ssi₹2..C& p.Y a L,'SI$
Section 03-Description of Project
riacility started up 2/20//.,2Civia a CiPle girich wrap received,'3t_.-ti
s,l,_a t pi:grates tilec?a„ ,1,.,.a,Or adp,-.avf,>ta.,ae'Lark _"Yr.. _c Prater d En4Fd inerieat„ ..ate cepa tiu:fsc
Operate:incturieri,t„uss rl liiletren 22 abse.roatior rierneristratiisia perrn itat,ra testing talc s .4 n<i I
Sections 04,OS&06 For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? ,'Yes
If yes,why? it' i s₹ g Serrehs ic?-u6rior itiesitnit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? tsc'.
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? .ran
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: $02 NOv CO_V0C_PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) �� 1
Title V Operating Permits(OP) 11 [1 1 II I
Non-Attainment New Source Review(NANSR)
Is this stationary source a major source?
If yes,indicate programs and which pollutants: 502 NOx CO SOC_PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) l
Title V Operating Permits(OP)
Non-Attainment New Source Review(NANSR)
EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3)
,Ex=C2*MW•Xx/C
Ex=emissis of pollutant
0.=Volumetric flow rate/volume of gas processed
MW=Molecular weight of gas O SG of gas'MW of air
Xx=mass fraction oft in gas
C=molar volume of ideal gas(379 scf/Ib-mot)at 60E and 1 atm (,
IMW 26.9171 lb/lb-mel
Throughput 365 bbl/year -
(Gat) 00 Gas-to-Oil Ratio(Gat) scf/bbi \ _
mass fraction(%) Emission Factor(ib/bbl) Emissions(Ibs/year) 1095W bbl/yr
Helium 6666_6666.
CO2 2753 _ _ 744 lb/bbl W&B emissions
N2 87.49 _6666
H25 _ 8392.11 lb/yr w&b
methane 30.12 .. ....
ethane 9,32
Profane 6.59.
Isobutane 0.39
n-butane 2.60: PLASH W+B
Isopentane 0.49
n-pentane 0.6E - _ 224-'MP 0 025720 0.00E+00 22 t•�J1;.
cydopentane 0.25 . Beater. 3.525-0I 1.76E-05 5.93E-06 Be..
n-Hexane 0.91 Soluene 15-04 1.06E-05 ...3.56E-06 T0i. -
cyclohexane 039 5.11741nontere 1.975 05 9.83E-07 3.32E-07 Et
u. n
Other hexanes 030 .. ;47!..665 .3_179-05 1.59E-06 5.36E-07 X76`-$ s.
heptanes 0.21 n:H=at,. 1.11E 04 5.55E-06 1.87E-06
s. -
methylcyclohexane 0.13 126586-3" ' 4.t
96.31,1961616300,3322-6221132
224-TMP 0-20 0000E+00 6666.
Benzene 0.94 3.517E-04 .. 5._0551 9.30E-05 sYOC ' `7:'0.00561''..
Toluene 0.65 2.112E-04 I.
Ethylbenzene 0.96 1.9696.05
Xylenes 0.04 3.175E-05 _..
CO 0.21 7.398E-05 _0
C9 0.97 21556:40 0A_
C10 0.31 4.54
6114 0.00 _
Total •. :_' ZEZ'f Jfff,� Intel
VOC Wt% tpy
7 l u Emissions s Ii e.tu j
Section 01-Administrative Information
'Facility AIRS ID: 52.3 ASUD ""
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid Jit0r,P y, V ., .;*nr1-:,
Detaied Emissions Unit Twn(2)400-05)produced waterstoragetanks
Description:
Emission Control Device ECU
Description:
Requested Overall VOC&HAP Control Efficiency%:
Limited Process Parameter Fr6 "•
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= 607,000.0 Barrels(bbl)per year
Requested Permit Limit Throughput= 788,400.0 Barrels(bbl)per year Requested Monthly Throughput= 665.?'0 Barrels(bbl)per month
Potential to Emit(PTE)Condensate Throughput= 728,400.Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 892.2 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced= 0.5 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= c-. 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
Will this storage tank emit flash emissions? ` ^_'s`. •
Emission Factors Produced Water Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Produced Water (Produced Water
Throughput) Throughput)
VOC 0.0055 00003 '-.. _��Y}Ta
Benzene 0.00015 !3 OJfl0 _
Toluene 0.00021 •0.0000 n Operator's calculations agree within rounding error of my own.v
Ethylbenzene 0.00000 0.0C0L' z"�;�' �rt These are acceptable and will he used in permitting.
Xylene 0.00003 0-0000 b.i
n-Hexane O.00.... .,..;Olio i,C
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/bbl) Emission Factor Source
(waste heat (Produced Water
combusted) Throughput)
PM2.5 0.0000
SOx ,,r_;. sY
NOx 0.0f:30 'T*—0`
CO 0...310C 11j1,411.11115'.k1WV.10, 1
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 q0000
PM2.5 07000
Sox 0.0000
NOx ^_.0000
VOC 00000 v
CO 0.0000
3 of 7 K:\PA\2020\20WE0525.CP1
Sto H^t. TD.1:.!.:;':. ElniS5'.0nS inventor
•
Section OS.Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly[knits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
I (tons/year) (tons/year) (toms/year) (tons/year) (tons/year) (lbs/month)
PM10 I 5 1 n f.i 0 __ I_.,
PM2.5 I 1."3" -.., _ _-. 1._
Sox I 3.`. 5.0 _ 0
NOx 3..3 .-.,.- *-._' _,E...
VOC ..._t 3 8 l. .4,n _._ :_4
CO _.E4 0.05 i._. ..,- 1 O ..._
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
fibs/year) (lbs/year) (16s/year) (lbs/year) (lbs/year)
Benzene -., 1Y_ _. . _.
Toluene v_.. .3?,.k 6.- t_x 3
Ethylhenzene I ._9, _._ 1.r' .5 ,
Xylene I 2.5 C ___ 5 51
n-Hexane I 8?3 73.. 9.9 .,_ a
224TMP I
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B ?... _.
Regulation 7,Part D,Section IC,D,E,F _ - --
Regulation 7,Part D,Section 1.G,C
Regulation 7,Part D,Section II.B,C.1,C.3
Regulation 7,Part D,Section II.C.2 ,..,-.aimacf to Regulatimo .Pant 0.9 39_
Regnlatiou:7,Pit o;SeCtion ll.C,4.a,)i). _4.',Mira tin, ".'s 7 Pert 03 99.9 3--7 9• - ,
R g latlorfXi 2EMISection g,C.4 a 03
Regulation 6,Part A,NSPS Subpart Kb . ,.. While thy APES is dated after
May 3,2020,these APENs were
Regulation 6,Part A,NSPS Subpart OOOO _ . ...32, submitted to move equipment
over from a GP10 to individual
NSPS Subpart 0000a . . ..+5 permits.As the tank battery
Regulation 8,Part E,MACE Subpart HH Proahava'0iaffi.9avrag9 ii.an_.-s.ffit 499)9, 99),V) has not been modified to,
(See regulatory applicability worksheet far detailed analysis) increase capacity since the
original GP10 application,and.
Section 07-Initial and Periodic Sampling and Testing Requirementssince.the original GP10
application date preceded May
For condensate or crude oil tanks,does the company use the state default emissions factors to 1,2020,this tank battery is not
estimate emissions? subject to 11.4.4 a(i)
If yes,are the uncontrolled actuator requested emissions for a crude oil tank estimated to be greater than or 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?
If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being
Ii permitted(far 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 on-line{,then it may be appropriate to use an
older site-specific sample.
If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor 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? 3
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
Flash liberation data is based on a FIA sample report which analyzed a pressurized water stream at the RSU Anschutz Fed 4-61-4 Facility.The sample was collected on 4/22/2020 eta pressure of 13O psig and 133F,
and analyzed 4/28/2020 under stock tank conditions of 12.2 ps a and,60F.The flash liberation results reported a GOR of 0.5 scf/bbl and an eXact duplicate GWR(i.e.a 0%deviation between calculated results).
Rana cursory PWT WAR.analysis model using TANKS 4.0.9d and added those emissions to those calculated in the FLA.Using my combined emission factors which factor in the W&B model results in the same tpy
values down to the tenth place,and were entered and used in this PA far reference.Considering the operator's APEN reported values result in the same permit limits,Will use APEN reported Values for permitting.
Operator included a passing Method 22 observation demonstration form in permit application,so initial testing of this source is not required.
Section 09-SCC Coding and Emisions Factors(For Inventory Use Only)
•
Uncontrolled
Emissions
AIRS Point# Process# 5CC Code Pollutant Factor Control% Units
81 PM10 lb/1,000 gallons Produced Water throughput
PM2,5 1 lb/1,000 gallons Produced Water throughput
5Ox -. lb/1,000 gallons Produced Water throughput
NOx _ . lb/1,000 gallons Produced Water throughput
VOC :-- :.. lb/1,000 gallons Produced Waterthroughput
CO _.._ . lb/1,000 gallons Produced Water throughput
Benzene 5 lb/1,000 gallons Produced Water throughput
Toluene ').v lb/1,000 gallons Produced Water throughput
Ethylbenzene vs lb/1,000 gallons Produced Water throughput
Xylene 'o lb/1,000 gallons Produced Water throughput
n-Hexane ..-' -, lb/1,000 gallons Produced Water throughput
224 TRIP ::;t: 1. lb/1,000 gallons Produced Water throughput
4 of 7 K:\PA\2020\20W E0525.CP1
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APES and Permit Requirements
ISaari._5.'.ka 4,1 Cz6i=_n^.L its
ATTAINMENT
1 Are unrtntrolled actual emissions from y criteriapolluter.f rom this d d I source grerterthan 2TPY(Rgulation 3,Part A,Sectmn IlDia)? Source Requires an APES.Gott
2 Produced Water Tanks have no grandfatheringoo Go to next question
3 Aretotalfacilrty uncontrolledVOC emissions greater h 5 TPY, greater than 10 TPY or CO missions greater than 10 TPY(Regulation 3 PartO Section Il.D.3)? Sour re Requires a permit
NON-ATTAINMENT -
1. Are uncontrolled emissions from any criteria pollutants from thb individual source greaser that'll-Pi(Regulation 3,Part A,5ettlon l.D.i.ai? ,: Source Requires an APES.Go to14114
2. Produced Water Tanks have no grandfatherng provisions
3. Aretotalfacilhy uncontrolled VOC emissions groaterthen 2TPY,NCa greater than 5TPY or CO emissions greater than 10TPY(naauAtion 6,Part B,5ection 11.0.2]? Pii.Y:s.Source Requires.permit
[Sarre 7rnfa.e per ur
Colorado Regulation 7,Part O.Section I.C-F&G
1. Is this storagetank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part D,Section L.A.1)? V. Continue-You have indicated tit
2. Is this storage tank located at oil and gas operations that collect,stare,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a naturalgas processing plant«Regulation 7,Part D,5ecnio'IAA)? ths Continue-You have Indicated th
3. Is this storage tank located at a natural gas processing plant(Regulation 7,Pan D,Section Le)? No Storage Tank is not subject to Re
4. Does this storage tank contain condensate?
5 Does the storage tank exhibit'Flash(eg storing non-stabilized liquids)emissions(Regulation 7,part 0,Section 1.0.217
6. Are uncontrolled actual emissions of the storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part O,Section
Part D,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
PartD,Section I.C.2—Emission Estimation Procedures
Part 0,Section I.0—Emissions Control Requirements
Part 0,Section LE—Monitoring
- Part D,Section l.F—Recordkeeping and Reporting
Part 0,Section I.5.2-Emissions Control Requirements
Part 0,Section I.C.l.a and b—General Requirements for Alr Pollution Control Equipment—Prevention of Leakage
Colorado Regulation 7,Part D.Section II
1. Is this storagetank located at a transmission/storage facility? Nu Continue-You have indicated th
2. Is this storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressorxtationsor natural gas processing plant°(Regulation 7,Part D,Section RC)? 9. Go to the next question-You ha
3. Does this storage tank have a₹ixed roof(Regulation 7,Pan O,Section ll.A.20)? YO-A`3.; 5 co to the next question
4 Are uncontrolled actual emissions ofth's storage tank equal to or greater than 2tons per year AOC(Regulation 7,Part D,Section 11.C2.c)? iith ',3 Storage rank.not subject to Rs
Part 0,Section AB—General Provisions feign Pollution Control Equipment and Prevention of Emissions
Part D,Section II.C.i-Emissions Control and Monitoring Provisions
Part DS lion llC3 RecordkeepingR t
5 Does the[rag tank contain only"stabilized"liquids(Regulation 7 Part S SeourlkC.2.b)? I-"t u�5torzge Tank is not subject to Re
Part 0,Section II-C.2.Capture and Monitoring for Storage Tanks fitted withAir Pollution Control Equpment
Is the controlled storage tank located at a well production facility,natural g pressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified on or after May 1,2020,such
6 that an additional controlled storage vessel b constructed to receive an anticipated Increase in throughput of hydrocarbon II Ids or produced water(Regula[on 7,Part 0,SectionRC4.a ll? MM-404.s.Storage Tank isnot subjectto RE
Is thecontrolled storage tank located at a wellp d facilM,naturalg pressor rtrtion,or natural gas processing plant comtructed on or afterlanurty 1,2021or located at afaclrcythat was modified on or after January 1, 3,k.'
7. 2021,such that additional controlled rage vessel redanticipatedncrease in throughput of hydrocarbon liquids or produced water(Regulator i,Pan 0,Section ll.C.4a()? P14v"61,aa
40 CFR,Part 60.Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the storage vessel capacitygreaterthan or equal to 75 cubic meters(mil[`472 BBI.)(40CFR 60.1106(3))? iPas Storage Tank s rot subject NSPS
2. Does the storage vessel meet the following exemption in 60111b(d)(4)? .`",,*"*u"
a.Does the vessel has a design capacity less than or equal to 1,589.874 m''[910,000 BBL].used for petroleum'or condensate stored,processed,or treated prior to custody transfer'es defined in 60,.1116?
3 Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23.1984(40 CFR 60 tnthla//? tr!r-f,:'
4. Does the tank meet the definition of"storage vessel"'in 60111O ,°'at��ak�-`,
5. Does the storage vessel store a"volatile organic liquid 9/01.)"'as defined in 60.11lb? trir
6 Does the storage vessel meet any one of the following additional exemptions: "y"„.,;
a.Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa['29.7 pail and without emissions to the atmosphere/60.110b(d)(2))7;or PANNWitl
b.The d g p y greater than or equal t 151 [-950 BBL]and stores a liquid wink a maximum true vapor pressures @ss than 3.5 its(60.110h(b)l?or i
c The d gcapacity'greater than orequal t 75 M[472 BBL]but less than 151 ms[-950 BBL]and stores alguid with a maximum true vapor pressures less than 15.0 kPa(60.110b(bi/? >s
z Does the storage tank meet either one a the Illowng exemptions from controlrequrements sm' "L",fytr/,1'
a.The design capacity is greater than or equal to 151 m'[9950 BBL]and stores a liquid with a max mum true vapor pressure greater than or equal to 3.5 kPa but less than 52 We?;or ;gulf a- ,c`1
b.The design p y is greater thanequal to 75 M'1"472 BBL]but less than 151ma[9950 BBL]and stores a I'qu d wth a maximum true vapor pressure greater than or equal to 15.0 Oa ma less than 27.6 kith? <
E,V.1"51
40 CFR,Part 60,Subpart0000/00003,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution
1. Is this storage vessel located et a facility In the onshore oll and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Res Continue-You have indicated th
2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? - '`b7/?e�'"Storage Tank is not subject NSPS
3. Was this sorage vessel constructed,reconstructed,or modified(see definitions 40 CFA 60.2)after September 18,2015? ,:"M Go to the neat question
4. Are potential VOC emissions'from the fndiuldual storage v sel greater than or equal to Gross pot year? zit=s Storage Tank is notsublect NSPS
S. Does th.storage vessel meet the definition of"storage vessel'per 60.5430/60.5430.7
6. Is the storage vessel subjectto and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CT-R Part 63 Su bpart HH?
[Note:If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS 0000/00000 per
6c.S365(e)(2)/60.SSeSo(e)(2)even If potential VOC emissions drop below 6 tons per year]
40 CFR,Part 63,Subpart Must NH,Oil and Gas Production Facilities
1. Is the storage tank located at an o?and natural gas production facility that meets either of the following criteria: Yes Continue-You have Indicated th
e.A facilirythat processes,upgrades or stores hydrocarbon liquids'(63.760(x/(2/);OR
b Afaclity that processes,upgrades or stores natural gas prior- to the point at which natural gas enters the natural gas transmission and storage source category ors delivered to a heal end user'(53.760(a)(3))7
2. the tank l ated at a facility that major'for HAPs? Storage Tank's not subject MAC
3. Da.the tank meet the definition of"storage vessel""In 63761?
4. Does the tank meet the definition of storage vessel with the potential f f mss0 per 63761?
5. Is the tank subject to control requirements under 40 CFR Part 60,Subpart'Kb or Subpart 0000?
Subpart A,General provisions per§63.764(a)Table 2
§63.766-Emissions Control Standards
§63.773-Monitoring
§63.774-Recordkeeping
§63.775-Reporting
PACT Review
PACT review is required if Regulation 7 does not apply AND if the tank is In the non-attainment area.I₹thetank meets both criteria,then review RACT requirements.
Disclaimer
This document'assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not
a mle orreguletion,end 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 enylaw regulation,
or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the 5550age of this document and the language of the Clean Air Act„its implementng regulations.
and Air Quality Control Commission regulations,the language of the statute orreguletion will control.The use of eon-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 termsof the Clean Ai-Act and Air
Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name HighPoint Operating Company
County AIRS ID 123 History File Edit Date 8/10/2020
Plant AIRS ID A0E2 _ Ozone Status Non-Attainment
Facility Name RSU ANSCHUTZ FED 4-61-4 NW
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 0.8 0.8 0.0 0.0 98.2 625.6 0.6 105.1 29.2 0.8 0.8 0.0 0.0 14.7 36.9 0.6 24.7 3.2
Previous Permitted Facility total 0.4 0.4 0.0 0.0 93.0 625.1 0.0 100.8 29.1 0.4 0.4 0.0 0.0 9.5 36.4 0.0 20.4 3.1
Crude Oil Storage Tank(12)4800 bbl 0.0 0.0 Now permitted under 20WE0524-point 004
Produced Water Stporage Tank(2)800 0.0 0.0 Now permitted under 20WE0525-point 005
bbl
001 GPIO Hydrocarbon Loading 0.0 0.0 Now permitted under 20WE0526-point 006
Engine Cat G3408 Generator 0.0 0.0 Now permitted under GP02-Point 002
Engine Cat 03408 Generator 0.0 0.0 Now permitted under GP02-Point 003
Fugitives 0.0 0.0 Insignificant Source
VRU Blowdowns _._. 0.0 0.0 Insignificant Source
002 GP02 RICE 4SRB Caterpillar M:G3408 TA SN: 0.2 0.2 46.0 2.7 47.9 0.9 0.2 0.2 3.9 2.7 7.7 0.9 No change
5N901913 _
003 GP02 RICE 4SRB Caterpillar M:G3408 TA SN: 0.2 0.2 46.0 2.7 47.9 0.9 0.2 0.2 3.9 2.7 7.7 0.9 No change
6NB01213
004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 0.8 449.3 3.6 13.3 0.8 22.5 3.6 0.7 Moving from GP10 to Construction Permit
005 20WE0525 Two(2)400-bbl Produced Water Tanks 2.2 0.3 0.1 0.0 Moving from GP10 to Construction Permit
006 20WE0526 Crude Oil Loadout to Trucks 0.1 68.3 0.6 1.2 0.1 3.4 0.6 0.1 Moving from GP10 to Construction Permit _
0.0 0.0
0.0 0.0
XA _External Combustion Devices 0.4 0.4 5.2 0.3 4.3 0.0 0.4 0.4 5,2 0.3 4.3 0.0 Insignificant Source
XA Fugitives 0.6 0.0 0.6 0.0 Insignificant Source
XA VRU Blowdowns 0.2 0.0 0.2 0.0 Insignificant Source
0.0 0.0
0.0 0.0
0.0 0.0
FACILITY TOTAL 0.8 0.8 0.0 0.0 98.1 525.7 0.6 104.3 16.6 0.8 0.8 0.0 0.0 13.9 31.9 0.6 23.9 2.5 VOC: Syn Minor(NANSR and OP)
NOx:Syn Minor(NANSR and OP)
CO: Syn Minor(OP)
HAPS: Syn Minor n-Hexane
HH: Area
7777: Area
Permitted Facility Total 0.4 0.4 0.0 0.0 92.9 525.2 0.0 100.0 165 0.4 0.4 0.0 0.0 8.7 31.4 0.0 19.6 2.5 Excludes units exempt from permits/APENs
(0)Change in Permitted Emissions 0.0 0.0 0.0 0.0 -0.8 -5.0 0.0 -0.8 -0.6 Pubcom&modeling(not)required based on (5
change in emissions)and addition of GP02.
Total VOC Facility Emissions(point and fugitive) 32.5 Facility is eligible for GP02 because v 90 tpy
(5)Change in Total Permitted VOC emissions(point and fugitive) -5.0 Project emissions less than 25/50 tpy
Note 1
Note 2
Page 6 of 7 Printed 8/10/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name HighPoint Operating Company
County AIRS ID 123
Plant AIRS ID AOE2
Facility Name RSU ANSCHUTZ FED 4-614 NW
Emissions-uncontrolled(Ibs per year)
POINTIPERMIT IDescripbon Formaldehyde Acetaldehyde Acroleln Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpyl
Previous FACILITY TOTAL 1,5 0.1 0.1 3.1 2.1 0.3 0.5 21.6 0.0 0.0 0.0 0.0 29.1
Crude Oil Storage Tank(12)4806 bbl _..0.0
Produced Water Stporage Tank(2) 0.0
800 bbl
001 GP10 Hydrocarbon Loading 0-0
Engine Cat G3408 Generator , 0.0
0.0
•Engine Cat G3408 Generator - - -
Fugitives 0.0
VRU Blowdowns - 0.0
002 GP02 RICE 45R0 Caterpillar M:G3408 TA 1468.0 59 0 65 0 'rU 0 14 C. 1 0 5 0 28 0 78 9 0.9
SN'58801913
003 GP02 RICE 45RB Caterpillar M:G3408 TA 1488.0 69 0 6510 39 0 14 0 I 0 5(1 28 0 75 0 0.9
SN:68001213
004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 2767.0 1817.0 241 0 485.0 21287.0 0 0 13.3
005 20WE0525 Two(2)400-bbl Produced Water 277 0 180 0 15 0 20 4 85 0 0.3
Tanks
006 20WE0526 Crude Oil Loadout to Trucks 2370 2102.0 1.2
0.0
00
XA External Combustion Devices 0.0
XA Fugitives 4e 8.5 3C' b0 2r0 0.0
XA VRU Blowdowns 24 10 0122 00 60 _ 00
0.0
0.0
0.0
TOTAL(tpy) 1.5 0.1 0.1 1.7 1.0 0.1 0.3 11.8 0.1 0.0 0.0 0.0 16 5
I
'Total Reportable=all HAPs where uncontrolled emissions>de minimus values
4'ep Text tl,,:.entrulled a:ntsstcrs 5 de minnnus
Emissions with controls(Ibs per year)
POINT(PERMIT (Description Fameidehyde Acetaeehyde Acroleln Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 2241MP H2S TOTAL(VW
Previous FACILITY TOTAL 1.5 0.1 0.1 0.2 0.1 0.0 0.0 1.1 0.0 0.0 0.0 0.0 3.1
Crude Oil Storage Tank(12)4800 bbl 0.0
Produced Water Stporage Tank(2) 0.0.
800 bbl
001 GP10 Hydrocarbon Loading 0.0
Engine Cat G3408 Generator 0.0
Engine Cat G3408 Generator 0.0
Fugitives 0.0
VRU Blowdowns. • .. .-: 0:0.
002 GP02 RICE 45RB Caterpillar M.G3408 TA 1468.0 850 000 140 10 50 280 -..t 0.9
SN:6N601913
003 GP02 RICE 4SRB Caterpillar M:G3408 TA 1468.0 890 65.0 ''390 140 10 50 280 /59 0.9
SN.68801213 l'004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 138.0 91.0 12 0 24 0 1064.0 0.0 0 7
005 20WE0525 Two(2)400-bbl Produced Water 14.0 80 10 10 4n 0.0
Tanks
006 20WE0526 Crude Oil Loadout to Trucks 100 105.0 0.1
0.0
0.0
XA External Combustion Devices 0.0
XA Fugitives 4 0 8.0 3 0 9 0 27 0 0.0
XA VRU Blowdowns 20 10 00 00 00 0.0
0.0
0.0
00
TOTAL if 1.5 0.1 0.1 0.1 0.1 0.0 0.0 0.6 0.1 U.S 0.0 U.S 2.5
)
7 20WE0525.CP1 8/10/2020
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Ben Fischbach
Package#: 431567
Received Date: 5120/2020
Review Start Date: 7/17/2020
Section 01-Facility Information
Company Name: HighPcmt Operating Carpo-aticn Quadrant Section Township Range
County AIRS ID: 123 4N bi;^a
Plant AIRS ID: AOE2 Lot4
Facility Name: PSI.)Aessrhutr.Fed 4-51.4 NL+%%Frog*sc*sen L an?av
Physical
Address/Location: - ,.
County: Weld County
Type of Facility: Pxpintvrion&Production Well Pod
What industry segment?=na Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOM&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
Permit#
AIRS Point#
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned) assigned)
Analysis Page
Hidden in this
Workbook-see
Perrrtiti ntIial 20 W E05 24.C P t
004 Storage'rank Crude TKs '{es 2.0610524 1 Yes 4esttonce PA for analysis
• Analysis Page
Hidden in tins
Workbook-see
Permit Initial 2OWEO525.CP1
005 Storage Tank PW TKs Yes 20W15525 1 Yes issuance PA for analysis
Perniit tninlI
006 Liquid Loading LOAD .Yes 20WE0_i25 1. Yes lsmacce
Section 03-Description of Project
Facility started up 2/20;'2020 via a GP10 which was received 2/3/2020.
Applicant proposes the construction of a condensate-storage tank battery,a produced hater tank battery.and llquid ieadout of condensate tokanc..trucks
,p=!ator included owing Method 22 observation demonstration form in permit a pri.,c ion,so initial test nr of thi,soot c'e is notrequired.
Sections 04,05&06 For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? yes
If yes,why? end I Farre,t
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 Nov CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(no) ���
Title V Operating Permits(OP)
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.S PM10 T5P HAPs
Prevention of Significant Deterioration(PSD) �1 ' I
Title V Operating Permits(OP) t-7 I
Non-Attainment New Source Review(NANSR)
Hydrnca:ticti ioodo'at Emissions inventory
Section 01-Administrative Information
HOED 1100
Facility AIRs ID:
County Plant Paint
Section 02-Equipment Description Details
Detailed Emissions Unit quid loading ofcude l into tank tracks -
Description:
Emission Control Device ECD
Description: .,
Is this Loadout controlled?
Requested Overall VOC&HAP Control Efficiency%: 85
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= 1,095,000 Barrels(bbl)per year
Requested Permit Limit Throughput= 1,314,000 Barrels(bbl)per year Requested Monthly Throughput= Li_d_. Barrels(btl)per month
Potential to Emit(PTE)Volume Loaded= 1,314,000 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 3535 Btu/scf
Actual Volume of waste gas emitted per year= 2,021:scf/year
Requested Volume of waste gas emitted per year= 'C35.352 scf/year
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: scfh _)MMscf/yr
Pilot Fuel Gas Heating Value: ./ Btu/scf u i MMBTU/yr
Section 04-Emissions Factors&Methodologies
Does the company use the state default emissions factors to estimate emissions? •if 14;
Does the hydrocarbon liquid loading operation utilize submerged fill?
Emission Factors Hydrocarbon Loadout
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Volume Loaded) (Volume Loaded)
VOC 1„,'5.11 5.?rr, - dosstState E.
Benzene 1.30c`4 ,+c._ - adopt State E,F.
Toluene
Eth'benzene Out e
Xylene 000* r30
n-Hexane
224 TMP O.00C-CO - 000F.00
Control Device
Uncontrolled - Uncontrolled
Pollutant )Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat comhusted) (Volume Loaded) _.
PM10 U 00E+00
PM2.5 000E+C
SOX Or;0t r00
NOx 0.06680 1.89E.04 apOor S.I 1U45 K I"r'are it)_i
CO 0.3103 ,, -s4[0a.r - .
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source
(Pilot Gas
(Waste Heat Combusted) Throughput)
PM10
PM2.5 'O00U
SOx 0 0000
NOx 0.0000
VOC ;7.001n
CO 0 00'00 .,
2 006 K:\PA\2020\20WE0526,CP1
Hydrocarbon i o-dout Emissions Ir;ve tort'
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 0.00, o.0i 0.00 C.00 0.03 0
PM2.5 7.00 A :;.`i90.172 !).SO
SOz (WO 7 37 r
NOx 0.1t 0.10 _ __2 27
VOC ca._.- tots t.ot =a72 ...
CO _ G,.1/ .. J.S
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled. Controlled Uncontrolled Controlled
(Ibs/year) (lbs/year) (Ibs/year) (Ibs/year) (lbs/Year)
Benzene 237 1v, _. 2,3 _<
Toluene 0 c 11
Ethylbenzene
Xylene O
n-Hexane 2102 !?,5
224TMP .. ..
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B S.iprca re�.;uires a.rc-,,>
Regulation 7 Part D Section II.C.5. 78z-hydrocarbon.lau)oa L,vcto,source_is su u(ect i0O 7 a.
(See regulatory applicability worksheet for detailed analysis)
•
Section 07-Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95%for a flare or combustion device? e^e' .4. .
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
Section 09-SCC Coding and Emissions Factors For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process It SCC Cade Pollutant Factor Control% Units
006 01 PM10 5.00 - lb/1,000 gallons transferred
PM2.5 3.70 3 lb/1,000 gallons transferred
SO0 0.0 _ III/1,000 gallons transferred
NOx 11-,;. 3, lb/1,000 gallons transferred
VOC _:S i5 lb/1,000 gallons transferred
CO ._3_ 0 lb/1,000 gallons transferred
Benzene 6.17 Silb/1,000 gallons transferred
Toluene 75 lb/1,000 gallons transferred
Ethylbenzene _ lb/1,000 gallons transferred
Xylene = . :. lb/1,000 gallons transferred
n-Hexane 06 1s5 lb/1,000 gallons transferred
224 TMP 7S. lb/1,000 gallons transferred
•
3 of 6 - K:\PA\2020\20WE0526.CP1
Hydrocarbon Loadout Regulatory Analysts Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
Colorado Regulation 3 Parts A and a-tteN and Permit eeg
kaor°is iu the Non:Mammas Mad
ATTAINMENT
Are uncontrolled actual emissions from any criteria pollutants from this Individual source Part
rll.(Regulation 3,Part A,Section 11.0.1.°17
5. out located at en explaation and production site(e.&,all peg(Regulation 3,Part e,Section II.01,7 •
3. Is the load.operation loading ImstMn 10,005 gallons(333B6341 of crude oil per day on anantwal average basis'+
4. Is the Ioadwt operation loading Taman 3,750 bob per year of condensate Na splash RIM
5. Is the bzdatoperation loading lass than 1-°308 obis per year d condensate via submerged fill',osmium,
e. Any to facility uncontrolled VOCemissiora greater thane 1133,NOM greater than to TIM orCO emissions greater than lO TAY(Regulation 3,Part El,...on lia3)7
s,t mhilleated:MTso.mo'e-t._Maameam°tea
NONATsAuMENT
any...pollutants from this individual source greater Nan 1 TM'(Regulation 3,Part A,section II.O.l.a)a _1 Isr'alo a.,located at an exploration and productionsite leg.,at pad)lRegulatlon 3,Part B,Section 0.Q.1.11? to the next question
3. s the loadautnperatlon loo ns(233 ttLsl Ofcr e oil my day on an annual average Man? =='va.Go to next purttion •
4. Istto load.operation loading less than 6,750al,per year of condenat via splash fill? ' 1AMSTAY Go m next questlun
3. Is the loadout operation loading less than 16,308 bas per year of condensate via enttrterged Ell procedure? T`Y.ks_' ueston
fi uncontrolled VOL emissions front t.greater an 2 TPY ter Nos grea thane TOY or CO emissions greater than so My(Regulation 3 cart a non.O.2i Kiettetiettn The ads.requires a permit
kart,:mut,a anon
colored°Reeulatlon_P55r p,gsp/er 11,03,
s this condensaMstorage hnk hydrocarbon uids swell production omits,,natural Rasa pressor station naturag Processing pn,T y$dr,','3SGstonex
2. Goss the hcility have°throughput ofhydrocarrbonlieutltlsuloadoudiotansport vehicles greater Nanor equal to 5,000 barrels? -(Source is subject to guladon 2 Part[action ll.C,5.
va Re
Motion ILCS.a-07-Compliance Schedule
Seam lly.5.a.rii-Operation etenre Venting
Section .a.fil-ioadout Eqguipment Opemaaead EeARteeRem
Mrtion S.a.liv)-bailout obsernlions and OpeatorTairing
secticon.c.s.a.lvt-
Emu,ii,C.5.a,ivil-Requirements for Air Pollution Control Equipment
Disclaimer
This document assists comb's with determining applicability of certain requirements d the Clean Air Act,its implementing regulations and Air Quality Sante,Commission regulators.This document is rasa
rule amgulaloe.end lye analysis itcatains may not apply b s particular situation based upon the Ind'vlduel recta and circumstances This document does net charge or substitute tue any law,eguletion.Or
eny other legal&binding requirement end is not legally enforceable In the event deny contact between the language on this documenrand the language d the Clean Air Act„its implementing regulations,
and Air Quality Cabs/Commission regulations,the language of the statute or regulation will control.The use ofna.medetsy language such as'recommend'"may""shcud,'end"can,"is intended to
descnbe SIPCO idapretafons and recommendations.Mandatory termindogy such as tnasr and"required'ere intended todeurice cannoning requirements under.tams attire Clean Air Act end Air
Quality Control Commission regulations,hd this document roes not establish legalrflind a requltahents in and oritself.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION•
FACILITY EMISSION SUMMARY
Company Name HighPoint Operating Company
County AIRS ID 123 History File Edit Date 8110/2020
Plant AIRS ID A0E2 Ozone Status Non-Attainment
Facility Name RSU ANSCHUTZ FED 4-61-4 NW •
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 0.8 0.8 0.0 0.0 98.2 625.6 0.6 105.1 29.2 0.8 0.8 0.0 0.0 - 14.7 36.9 0.6 24.7 3.2
Previous Permitted Facilit total 0.4 0.4 0.0 0,0 93.0 625.1 0.0 100.8 29.1 0.4 0.4 0.0 0.0 9,5 36.4 0.0 20.4 3.1
Crude Oil Storage Tank(12)4800 bbl - 0.0 0.0 Now permitted under 20WE0524-point 004
Produced Water Stporage Tank(2)800 0,0 0.0 Now permitted under 20WE0525-point 005.
bbl
001 GP10 Hydrocarbon Loading 0.0 0.0 Now permitted under 20WE0526-point 006
Engine Cat G3408 Generator 0.0 0.0 Now permitted under GP02-Point 002
Engine Cat G3408 Generator 0.0 0.0 Now permitted under GP02-Point 003
Fugitives 0.0 •
0.0 Insignificant Source
VRU Blowdowns 0.0 0.0 Insignificant Source
002 GP02 RICE 4SRB Caterpillar M:G3408 TA SN: 0.2 0.2 46.0 2.7 47.9 0.9 0.2 0.2 3.9 2.7 7.7 0.9 No change
6NB01913
003 GP02 RICE 4SRB Caterpillar M:G3408 TA SN: 0.2 0.2 46.0 2.7 47.9 0.9 0.2 0.2 3.9 2.7 7.7 0.9 No change
6NB01213
004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 0.8 449.3 3.6 13.3 0.8 22.5 3.6, 0.7 Moving from GP10 to Construction Permit
005 20WE0525 Two(2)400-bbl Produced Water Tanks 2.2 0.3 0.1 0.0 Moving from GP10 to Construction Permit
006 20WE0526 Crude Oil Loadout to Trucks 0.1 68.3 06 1.2 0,1 3.4 0.6 0.1 Moving from GP10 to Construction Permit _
0.0 0.0
0.0 0.0
XA External Combustion Devices 0.4 0.4 5.2 0.3 4.3 0.0 0.4 0.4 5.2 0.3 4.3 0.0 Insignificant Source
XA Fugitives 0.6 0.0 0.6 0.0 Insignificant Source
XA VRU Blowdowns 0.2 0.0 0.2 0,0 Insignificant Source
•
0,0 0.0
0.0 0.0
0.0 0.0
FACILITY TOTAL 0.8 0.8 0.0 0.0 98.1 525.7 0.6 104.3 16.6 0.8 0.8 0.0 0.0 13.9 31.9 0.6 23.9 2.5 VOC: Syn Minor(NANSR and OP)
NOx:Syn Minor(NANSR and OP)
CO: Syn Minor(OP)
HAPS: Syn Minor n-Hexane
HH: Area
•
7777: Area
Permitted Facility Total 0.4 0.4 0.0 0.0 92.9 525.2 0.0 100.0 16.5 0.4 0.4 0.0 0.0 8.7 31.4 0.0 19.6 2.5 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions 0.0 0.0 0.0 0.0 -0.8 -5.0 0.0 -0.8 -0.6 Pubcom&modeling(not)required based on (A
change in emissions)and addition of GP02.
Total VOC Facility Emissions(point and fugitive) 32.5 Facility is eligible for GP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -5.0 Project emissions less than 25/50 tpy
Note 1
Note 2 •
•
•
•
Page 5 of 6 Printed 8/10/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name HighPoint Operating Company
County AIRS 10 123
Plant AIRS ID AGED
Facility Name RSU ANSCHUTZ FED 4-61-4 NW
Emissions-uncontrolled(lbs per year)
POINT'PERMIT I Description redeaioenyde.Acalaeebyde Acrolein Benzene Toluene Ethylbenzena Xytenes n-Hexane McOH 224TNP H2S TOTAL
FreYIoUs FACILITY TOTAL 1.5 0,1 0.1 3.1 2.1 0.3 0.5 21.6 0.0 0.0 0.0 0.0 29.1
Crude Oil Storage Tank(12)4800 bbl 0,0
, ProduoedWater Stporape Tank(2)' 00
ROE bb -
001 Gpio Hydrocarbon Loading 0.0
Engine Cat G3408 Generator 0.0
Engine Cat G3408 Generator 0.0
FugSves 0.0
VRU Slowdowns 0.0
— _002 GP02 RICE 4SRB Caterpillar M:G3408 TA 1468.0 09 0 05 0 39 0 14 0 I 0 5 0 28 0 75 0 0.9
SN:661801913
003 GP02 RICE 4SRB Caterpillar M:G3408 TA 1468.0 (390 0050 390 140 1.0 5,0 280 .-59 0.9
SRI 6NB01213
004 20WE0524 Twelve(12)400-bbl Crude Oil Tanks 2767.0 1817.0 2410 485.0 21287,0 90 13.3
005 20WE0525 Two(2)400-bbl Produced Water 277.0 16:0 150 250 88.0 0.3
Tanks ,
006 20WE0526 Crude Oil Loadout to Trucks 2370 21020 1.2
0.0
0.0
XA External Combustion Devices 0.0
XA Fugitives 40 90 30 A0 270 0.0
XA VRU Slowdowns '0 I0 00 00 H0 0.0
0,0
0.0
0.0
TOTAL(tpy) 1.5 0.1 0.1 1.7 1.0 0.1 0.3 11.8 0.1 0.0 0.0 0.0 16.5
'Total Reportable=all HAPs where uncontrolled emlesonS s de minimus values
Red I not uncgnucted erwsswns•de.nuvnlus
•
Emissions with controls(lbs per year)
POINT'PERMIT I Descnpbon -r,ealwnrde sseleH me Acrolein Benzene Toluene Ethylcoreone Xytenes n-Hexane McOH 228 TNP H25 TOTAL
Ph
Previous FACILITY TOTAL 1.5 0.1 0.1 0.2 0.1 0.0 0.0 1.1 0.0 0.0 0.0 0.0 3.1
Crude Oil Storage Tank(12)4800001 00
Produced Water Steerage Tank,(2) g,0
800 bbl
001 GP10 Hydrocarbon Loading... 0.O
Engine Cat G3408 Generator 0.0
Engine Cat G3408 Generator 0.0
Fugitives 0,0
VRU.BIowdowns _ 0.0___
002 GP02 RICE 4SRB Caterpillar M:G3408 TA 1468.0 00 0 05.0 39 0 14 11 1 5 5 0 28 0 70 9 0,9
SN 6Ne01913 _
003 GP02 RICE 4SR8 Caterpillar M:G3408 TA 1468.0 600 05,0 '390 140 1C 5.0 280 ;59 09
SN:614801213
004 20WE0524 Twelve(12)400-bbl Crude Oll Tanks 138.0 91,0 12.0 24.0 1064.0 0.0 0.7
005 20WE0525 Two(2)400-bbl Produced Water 14.0 (10 10 10 40 0,0
Tanks
006 200050926 Crude Oil Loodout to Trucks 1'3:0 1050 01
0.0
0.0
XA External Combustion DeWees 0.0
XA Fugitives 40 30 30 90 270 0.0
XA VRU Slowdowns 2.0 1 U 0 0 0 0 0.0 0.0
00
-
0,0
0.0
TOTAL(tpy) 1.5 0.1 0.1 0.1 0.1 0.0 0.0 0.6 0.1 0.0 0.0 0.0 2.5
1
6 28WEOS26.CP1 8/10/2020
Crude Oil Storage Tank(s) APEN
Form APCD-210
CDPHE 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 wilt 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: 2 OW 5 ZL�, AIRS ID Number: 1 23/AOE2 / e o
Section 1 -Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: RSU Anschutz Fed 4-61-4 NW Production Facility
Site Location
Site Location:
Lot 4 Sec. 4, T4N, R61 W County: Weld
NAlC5 or SIC Code: 211111
Mailing Address:
(Include Zip Code) 555 17th Street, Suite 3700
Denver, Colorado 80202 Contact Person: Marsha Sonderfan
Phone Number: (303) 312-8524
E-Mail Address2: CDPHE_Corr@hpres.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
431 563
® COLORADO
Permit Number: AIRS ID Number: 1 23/A0E2/
Section 2 - Requested Action
El NEW permit OR newly-reported emission source
[a Request coverage under traditional construction permit
❑ Request coverage under General Permit GPO8
If General Permit coverage is requested,the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership4 O Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes:
3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Twelve (12) - 400 bbl crude oil storage tank battery
Company equipment Identification No. (optional):
For existing sources,operation began on: 02/20/2020
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: Q Exploration is Production(EEtP)site 0 Midstream or Downstream(non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? [a Yes O No
Are Flash Emissions anticipated from these storage tanks? 9 Yes 0 No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) [3 Yes Q
805 series rules?If so, submit Form APCD-105. No
Are you requesting a 6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual ❑
emissions a 6 ton/yr(per storage tank)? I Yes No
COLORADO
Permit Number: AIRS ID Number: 1 23/A0E2/
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit limits
(bbl/year) (bbl/year)
Crude Oil Throughput: 1,095,000 1,314,000
From what year is the actual annual amount? 2020
Average API gravity of sales oil: 36.5 degrees RVP of sales oil: 6.2
Tank design: (] Fixed roof ❑ Internal floating roof 0 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)
Crude TKs 12 4,800 01/2020 02/2020
Wells Serviced by this Storage Tank or Tank Battery°(ESP Sites Only)
API Number Name of Well Newly Reported Well
See attached well list (Addendum) 0
O
0
- ❑
0
5 Requested values wilt 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)
40.346070, -104.224873
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°f) (ACFM) (ft/sec)
ECDs -20 N/A N/A N/A
indicate the direction of the stack outlet: (check one)
9 Upward 0 Downward 0 Upward with obstructing raincap
❑Horizontal 0 Other(describe):
indicate the stack opening and size:(check one)
n
❑✓ Circular Interior stack diameter(inches): 84
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
me COLORADO
Ndl.s Bn,:ewnkn.
Permit Number: AIRS ID Number: 123/A0E2/
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:
0 Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed(emissions vented):
Pollutants Controlled: VOC, HAPs
Rating: TBD MMBtu/hr
Type: ECD Make/Model: $4" Cimarron/Big Hurt
Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: NSA Waste Gas Heat Content: 2,608 Btu/scf
Constant Pilot Light: Yes 0 No Pilot Burner Rating: 0.24 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Descriptiore
Control Efficiency Requested
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -8.2 psig
Describe the separation process between the well and the storage tanks: Crude oil from the 3-phase
inlet separators goes to the heated flash gas separators (heater treaters) then to the vapor recovery
towers ("VRTs"), and lastly to the crude oil storage tanks.
COLORADO
Permit Number: AIRS ID Number: 1 23/AOE2/
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? []Yes O No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (X of total emissions captured (X reduction of captured
by control equipment) emissions)
VOC ECD 100% 95%
NOx
CO
HAPs ECD 100% 95%
Other:
From what year is the following reported actual annual emissions data? 2020
Use the following table to report the criteria pollutant emissions from source:
Emission Factor7 Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Units ( 2, Emissions Emissions8 Emissions Emissions
Basis Mfg.,etc.)
(torts/year) (tons/year) (tons/year) (tons/year)
VOC 0.6839 Ib/bbl Eng.Est. 374.45 18.72 449.34 22.47
NO„ 0.068 Ib/MMBtu AP-42 0.67 0.79
CO 0.31 Ib/MMBtu AP-42 _ 3.06 3.61
5 Requested values will become permit limitations or wilt 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 El Yes O 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
Chemical Name Abstract Source Uncontrolled Controlled
Uncontrolled
Service(CAS) lled Units Emissions8
Basis (AP-42, Emissions
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0.00211 Ib/bbl Eng.Est. 2,306.10 115.31
Toluene 108883 0.00138 _ lb/bbl Eng.Est. 1,514.28 75.71
Ethylbenzene 100414
Xylene 1330207 0.00037 Ib/bbl , Eng.Est. 403.81 20.19
n-Hexane 110543 _ 0.01620 lb/bbl Eng.Est. 17,734.24 886.71
2,2,4-Trimethylpentane 540841
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.
COLORADO
5 I
Permit Number: AIRS ID Number: 1 23/AOE2/
Section 10 -Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP08.
Marsha Sonderfan Digitally signed by Marsha Sonderfan 5/19/2020
Date: 2020.05.19 13:35:52-06'00'
Signature of Legally Authorized Person(not a vendor or consultant) Date
Marsha Sonderfan Senior EHS Specialist
Name (print) Title
Check the appropriate box to request a copy of the:
9 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, 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
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
Am COLORADO
6 1 D=1,',"d hwc
Produced Water Storage Tank(s) APEN
.41:14x.
Form APCD-207
,_ 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 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
fora 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: L to E7`S2 AIRS ID Number: 1 23/A0E2 / bCc
Section 1 -Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: RSU Anschutz Fed 4-61-4 NW Production Facility
Site Location
Site Location: '
Lot 4 Sec. 4 T4N R61 W
' County: Weld
NAICS or SIC Code: 211111
Mailing Address:
(Include Zip Code) 555 17th Street, Suite 3700
Denver, Colorado 80202 Contact Person: Marsha Sonderfan
Phone Number: (303) 312-8524
E-Mail Address2: CDPHE_Corr@hpres.com
Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
43 .563
WCOLORADO
Permit Number: AIRS ID Number: 1 23/A0E2/
Section 2 - Requested Action
El NEW permit OR newly-reported emission source
El Request coverage under traditional construction permit
O Request coverage under a General Permit
O GP05 ❑ GP08
If General Permit coverage is requested,the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PIE)
Additional Info£t Notes:
3 For company name change, a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Two (2) - 400 bbl produced water storage tank battery
Company equipment Identification No. (optional):
For existing sources, operation began on: 02/20/2020
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: El Exploration Ft Production(E&P)site 0 Midstream or Downstream(non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? ❑ I Yes 0 No
Are Flash Emissions anticipated from these storage tanks? [] Yes 0 No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing? ❑ Yes 0 No
Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? El Yes 0 No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes ❑ No
805 series rules?if so, submit Form APCD-105.
Are you requesting z 6 ton/yr VOC emissions (per storage tank),or are uncontrolled actual
emissions z 6 ton/yr (per storage tank)? ❑ Yes 0 No
Alfilk COLORADO
Permit Number: AIRS ID Number: 1 23/A0E2/
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl year) (bbl/year)
I Produced Water Throughput: 657,000 788,400
From what year is the actual annual amount? 2020
Tank design: Q Fixed roof O Internal floating roof O External floating roof
Storage t 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)
PW TKs 2 800 01/2020 02/2020
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
See attached well list (Addendum) O
O
O
O
s Requested values wilt 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 EaP 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)
40.346070, -104.224873
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.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec)
TBD —20 N/A N/A N/A
Indicate the direction of the stack outlet: (check one)
Q Upward O Downward O Upward with obstructing raincap
[�Horizontal O Other(describe):
Indicate the stack opening and size:(check one)
❑✓ Circular Interior stack diameter(inches): $4."
O Square/rectangle Interior stack width(inches): Interior stack depth(inches):
o Other(describe):
oCOLORADO
Permit Number: AIRS ID Number: 1 23/A0E2/
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: VOC, HAPs
Rating: TBD MMBtu/hr
Type: ECD Make/Model: 84" Cimarron/Big Hurt
a Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: NA Waste Gas Heat Content: 892.2 Btu/scf
Constant Pilot Light: Ei Yes 0 No Pilot Burner Rating: 0.24 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7- Gas/Liquids Separation Technology Information (E&tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -130 psig
Describe the separation process between the well and the storage tanks: The commingled liquids
from the wells flow to inlet separators and produced water then flows to the produced water storage tanks.
COLORADO
Permit Number: AIRS ID Number: 1 23/AOE2/
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency
P (%of total emissions captured (%reduction of captured
by control equipment) emissions)
VOC ECD 100% 95%
NOx
CO
HAPs ECD 100% 95%
Other:
From what year is the following reported actual annual emissions data? 2020
Use the following table to report the criteria pollutant emissions from source:
Requested Annual Permit
Emission Factor Actual Annual Emissions Emission Limit(s)5
Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis ( 2,Units Emissions Emissions8 Emissions Emissions
Mfg.,etc.) (tons/year) (tabs/year) (tons/year) (tons/year)
VOC 0.0055 lb/bbl Eng.Est. 1.81 0.09 2.17 0.11
NOx 0.068 Ib/MMBtu _ AP-42 0.01 0.01
CO 0.31 lb/MMBtu AP-42 _ 0.05 0.05
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 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 0 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
Chemical Name Abstract Source Uncontrolled Controlled
Uncontrolled
Service (CAS) Units 8
(AP X12, Emissions Emissions
Number Basis Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432
Toluene 108883
Ethylbenzene 100414 _
Xytene 1330207 -
n-Hexane 110543 _
2,2,4-Trimethylpentane 540841
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.
�' Hoeft :'Nk III
Permit Number: AIRS ID Number: 1 23/AQE2
Section 10-Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Marsha Sonderfan Digitally signed by Marsha Date:2020.05.1913:4:37-0 Sonderfan 5/19/2020
Signature of Legally Authorized Person(not a vendor or consultant) Date
Marsha Sonderfan Senior EHS Specialist
Name(print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
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
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
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: HighPoint Operating Corporation
Source Name: RSU Anschutz Fed 4-61-4 NW Production Facility
Emissions Source AIRS ID2: 123-A0E2
Wells Serviced by this Storage Tank or Tank Batter(E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-46726 RSU Anschutz Fed#4-61-04-4040C ■
05-123-46727 RSU Anschutz Fed#4-61-04-0909CS ■
05-123-46728 RSU Anschutz Fed#4-61-04-0808C ■
05-123-46729 RSU Anschutz Fed#4-61-04-2525C ■
05-123-46730 RSU Anschutz Fed#4-61-04-0909CN ■
05-123-46731 RSU Anschutz Fed#4-61-04-2424C ■
05-123-50078 RSU Anschutz Fed#4-61-5-0909CN ■
05-123-50079 RSU Anschutz Fed#4-61-5-2421C ■
05-123-50080 RSU Anschutz Fed# 4-61-5-2528C ■
05-123-50081 RSU Anschutz Fed#4-61-5-4040C ■
05-123-50082 RSU Anschutz Fed#4-61-05-0909CS ■
05-123-50083 RSU Anschutz Fed#4-61-5-0808C ■
O
O
0
0
O
D
O
O
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD,enter
NA
Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver.7-29-2014
Hydrocarbon Liquid Loading APEN ,„ , f\
v' Form APCD-208
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks,etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN
options wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD)website.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, 11.C. for revised APEN requirements.
Permit Number: 2 a NE QS S2, AIRS ID Number: 123 / A0E2 / 004,-,
Section 1 - Administrative Information
Company Name: HighPoint Operating Corporation
Site Name: RSU Anschutz Fed 4-61-4 NW Production Facility
Site Location
Site Location: Lot 4 Sec. 4, T4N, R61 W County: Weld
NAICS or SIC Code: 211111
Mailing Address:
(Include Zip Code) 555 17th Street, Suite 3700
Denver, Colorado 80202 Contact Person: Marsha Sonderfan
Phone Number: (303) 312-8524
E-Mail Address2: COPHE_Corr@hpres.com
I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name
pay 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.
4315E
�, ,, COLORADO
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Permit Number: AIRS ID Number: 123 /A0E2/
Section 2 - Requested Action
NEW permit OR newly-reported emission source
0 Request coverage under construction permit ❑ 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 O Change company name3
O Change permit limit O Transfer of ownership4 O Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PIE)
Additional Info ii Notes:
3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Crude oil loading into trucks
Company equipment Identification No. (optional):
For existing sources, operation began on: 02/20/2020
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? ❑i Yes O No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes 0 No
emissions?
Does this source load gasoline into transport vehicles? O Yes 0 No
Is this source located at an oil and gas exploration and production site? 0 Yes O No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes 0 No
average?
Does this source splash fill less than 6,750 bbl of condensate per year? O Yes 0 No
Does this source submerge fill less than 16,308 bbl of condensate per year? O Yes 0 No
COLORADO
rr Ar CCU 2i)8 Hycr;;car bon Liquid Loading g AP .N Revision 12 2019 2 >
Permit Number: AIRS ID Number: 123 /A0E2/
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: 1,314,000 bbl/year Actual Volume Loaded: 1,095,000 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:
Average temperature of
Saturation Factor: bulk liquid loading: 'F
True Vapor Pressure: Psia ®60 "F Molecular weight of tb/lb-mot
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/ft3
Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload
5 Requested values wilt 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.
Section 5 -Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.346070,-104.224873
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.
Operator Discharge Height Above Temp. Flow Rate Velocity
Stack ID No. Ground Level(Feet) (F) (ACFM) (ft/sec)
ECDs -20 N/A N/A N/A
Indicate the direction of the stack outlet: (check one)
0 Upward O Downward O Upward with obstructing raincap
❑ Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter(inches): 84"
❑Square/rectangle Interior stack width(inches): Interior stack depth (inches):
❑Other(describe):
ise COLORADO
FO! n /'1'„_ ,;'� HV . .( FO ,.1 i3 7 L):3 r1, APEN Re,, 12 3
Permit Number: AIRS ID Number: 123 /A0E2/
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.
0 Loading occurs using a vapor balance system: Requested Control Efficiency:
Used for control of: VOC,HAPs
Rating: TED MMBtu/hr
Combustion Type: ECD Make/Model: 84"Cimarron/Big Hurt
❑ Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A °F Waste Gas Heat Content: 2,608 Btu/scf
Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 0.24 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
Section 7- Criteria Pollutant Emissions Information
Attach alt emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑i Yes 0 No
If yes,describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined,values if multiple emission control methods were identified in Section 6):
Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency
p (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
Sox
NO.
CO
VOC ECD 100% 95%
HAPs ECD 100% 95%
Other:
❑✓ Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
0 Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑i Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? 2020
Use the following table to report the criteria pollutant emissions from source:
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (A"'42, Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tonslyear) (tonslyear)
PM
SOx
NOx 0,068 Ib/MMBtu AP-42 0.12 0.15
CO 0.31 Ib/MMBtu AP-42 0.56 0.67
VOC 0.104 Iblbbi PS Memo 14.O2 76.55 3.83 91.87 4.59
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 alt APENs,including APEN updates.
6 Annual emission fees wilt be based on actual controlled emissions reported, If source has not yet started operating,provide
projected emissions.
e� COLORADO
Fa( F 'gip:_,' 208 - `'3 . c,irpo? ._1`.1;i .r '' I'+;r r'€4 R „s' `f /201a ' MP
nw'nsr„�
Permit Number: AIRS ID Number: 123 /A0E2/
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria o Yes O 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
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions6
Number Mfg.,etc.) (ibs/year) (ibs/year)
Benzene 71432
Toluene 108883 -
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543 0.00160 lb/bbl PS Memo 14-02 1752.0 87.6
2,2,4-Trimethylpentane 540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 9 -Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true,and correct. If this is a registration for coverage under General Permit GP07, i further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
Marsha Sonderfan Digitally signed by Marsha Sonderfan
Date:2020.05.1913:39:24-06'00' 5/19/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Marsha Sonderfan Senior EHS Specialist
Name(print) Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, i1.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
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
MIL COLORADO
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