HomeMy WebLinkAbout20202324.tiff COLORADO
44,0
Department of Public
C. nail, Health&Environment
Weld County - Clerk to the Board
1150OSt
PO Box 758 RECEIVED
Greeley, CO 80632
July 6, 2020 JUL 0 9 2020
COMMISSIONERS
Dear Sir or Madam:
On July 7, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
HighPoint Operating Corporation - Anschutz Equus Farms Fed 5-61-34 NESE 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 & Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
f�> W�
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe /, ` :;),
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director 4
Pub: ; C Rev..et,) cc:P4(7'P) (0s) pw(stt/ER,/ ,cx) 2020-2324
off/o3/20 oGCsM)NL
Air Pollution Control Division
• *. Notice of a Proposed Project or Activity Warranting Public
GDPHE
Comment
Website Title: HighPoint Operating Corporation - Anschutz Equus Farms Fed 5-61-34 NESE Production
Facility - Weld County
Notice Period Begins: July 7, 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: Anschutz Equus Farms Fed 5-61-34 NESE Production Facility
Exploration and Production Well Pad
NESE Section 34 T5N R61W
Weld County
The proposed project or activity is as follows: This source newly drilled nine (9) wells, which first began
producing on September 16, 2019. These permitting requests are for initial permit coverage for the crude oil
storage tanks and the crude oil loadout. Concurrently, this source has requested GP08 coverage for 2-400
bbl produced water storage tanks. The tanks have all been constructer prior to May 1, 2020. This facility in
synthetic minor for VOC (NANSR and OP) and n-hexane.
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 20WE0202 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
! , COLORADO
1 IOW `" Depatnnent of Public
Health 6 Environment
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0202 Issuance: 1
Date issued:
Issued to: High Point Operating Corporation
Facility Name: Anschutz Equus Farms Fed 5-61-34 NESE Production Facility
Plant AIRS ID: 123/A0C9
Physical Location: NESE SEC 34 T5N R61W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
Equipment Description
ID Point Description
Crude Oil 002 Truck loadout of crude oil by Enclosed Combustion
Loading submerged fill Device
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act(C.R.S. 25-7-101 et seq), to 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.cotorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 11
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
4. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID AIRS Tons per Year Emission
Point PM2.5 NOX VOC CO Type
Crude Oil 002 --- --- 3.4 --- Point
Loadout
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.
7. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Page 2 of 11
r• COLORADO
40 'AO Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Equipment AIRS Control Device Pollutants Controlled
ID Point
Crude Oil 002 Enclosed Combustion Device VOC and HAP
Loadout
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 ID AIRS Process Parameter Annual Limit
Point
Crude Oil Loadout 002 Crude Oil Loaded 985,500 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.)
• 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
Page 3 of 11
C1111
COLORADO
Air Pollution Control Division
Ntte Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
that includes, at a minimum, operating procedures for each type of loadout control
system.
15. The owner or operator must retain the records required by Regulation Number 7, Part D, Section
II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon
request.
Page 4 of 11
Cr�r� COLORADO
l444140661 Air Pollution Control Division
ite Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution, required
under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
16. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
17. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single,annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING a MAINTENANCE REQUIREMENTS
18. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
19. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 5 of 11
C rR »,... COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted.
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. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
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.
Page 6 of 11
�. COLORADO
Air Pollution Control Division
Department of Public Heath E,Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
By:
Lauraleigh Lakocy
Permit Engineer
Page 7 of 11
Cr.~*»- COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to HighPoint Operating Corporation
Page 8 of 11
. : COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s)operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions` Emissions
(lb/yr) (lb/yr)
Benzene 71432 442 22
002 Toluene 108883 320 16
n-Hexane 110543 3,501 175
Note: AU non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Uncontrolled Controlled
Pollutant CAS # Emission Emission Source
Factors Factors
lb/bbl lb/bbl
AP-42,
VOC 0.1398 6.99E-03 Chapter
5.2 Et Flash
Benzene 71432 0.00045 2.25E-05 Liberation
of
Pressurized
Toluene 108883 0.00032 1.6E-05 Crude Oil
Sample
n-Hexane 110543 0.00355 1.775E-04 Taken
10/16/2019
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version
1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 3.3559 psia
M (vapor molecular weight) = 68 lb/lb-mol
T (temperature of liquid loaded) = 512 °R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
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, n-hexane
PSD True Minor Source
Page 10 of 11
C COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
NANSR Synthetic Minor Source of: V0C
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
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
C ,,,..;,..... COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the heath and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0203 Issuance: 1
Date issued:
Issued to: HighPoint Operating Corporation
Facility Name: Anschutz Equus Farms Fed 5-61-34 NESE Production Facility
Plant AIRS ID: 123/A0C9
Physical Location: NESE SEC 34 T5N R61W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID Point Description
Crude TKs Q03` Ten (10) 400 barrel fixed roof storage Enclosed Combustion
vessels used to store crude oil Device
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS)form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and
can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self-certification form and guidance on how to self-certify
Page 1 of 10
r.': COLORADO
r -44klitrii00Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
4. The operator must 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,t VOC CO Type
Crude TKs 003 --- --- 16.6 2.7 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
Page 2 of 10
»4, COLORADO
11P 4.46,4 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Crude TKs 003 Enclosed Combustion Device 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 Proces Process Parameter Annual Limit
Equipment ID Point s
Crude TKs 003 01 Crude Oil throughput 985,500 barrels
02 Combustion of pilot light gas 1.3 MMSCF
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
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
Page 3 of 10
: . COLORADO
1,t:0 Air Pollution Control Division
iii Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, 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 Et MAINTENANCE REQUIREMENTS
17. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
Page 4 of 10
rvv, COLORADO
Aix Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen-minute period during normal
operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23)
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. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
Page 5 of 10
7.; COLORADO
40, Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
21. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide'final.' authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a ,
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
Page 6 of 10
r.Y COLORADO
®j Air Pollution Control Division
�� Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to HighPoint Operating Corporation
Page 7 of 10
Cr. COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRSUncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 2,134 107
Toluene 108883 1,543 77
003
Xylenes 1330207 446 22
n-Hexane 110543 16,887 844
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
e
:. COLORADO
oIti Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
Process 01: Crude Oil Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 4.82E-03 4.82E-03 AP-42, Chapter
13.5
VOC 0.6745 3.373E-02 Site-specific
71432 Benzene 0.0022 1.1E-04 flash liberation
108883 Toluene 0.0016 8.0E-05 analysis (taken
1330207 Xylene 0.0005 2.5E-05 10/16/2019) and
Tanks 4.0.9d
110543 n-Hexane 0.0171 8.55E-04 Simulation
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Process 02: Combustion of pilot light gas
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMSCF lb/MMSCF
CO 488.25 488.25 AP-42, Chapter
13.5
Note:The CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 CO
emission factor(0.31 lb/MMBtu)by a heat value of 1,575 Btu/scf.Actual emissions are calculated by multiplying the
emission factors in the table above by the total fuel flow of the pilot gas. Pilot tight fuel flow is based on a constant
rate of 50 scf/hr, There are a total of three combustors used to control emissions from the crude oil storage vessels. As
a result, the total pilot gas fuel flow is 150 scf/hr.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, n-hexane
PSD True Minor Source
Page 9 of 10
C , ,,,i„....r...:: COLORADO
4110 4111611' Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
NANSR Synthetic Minor Source of: V0C
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: jLeura!eigh Lalcocy
Package 6: 423256
Received Date: 12/37/2019
Review Start Date: 5113/2020
Section 01-Facility Information
Company Name: HighPoint Operating >-ooraticn Quadrant Section Township Range
County AIRS ID: 123 - N.ESE. 34 34 61
Plant AIRS ID: AOC-9
Facility Name: -nschutz Equus Farr.Fed 3-61-34 NESE Preductior Facility -Physical
Address/Location: _ - ,
County: Weld County
Type of Facility: Expioration&Production Weil Pad
What industry segment?Oil&Natural Gas Produc_'or&Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NON&MOP
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 initial
002 Liquid Loading. Crude Ai Loading Yes 20W60202 I Yes Issuance
Permit initial
003 Storage Tank Cruder v Yes IOVJE0203 I Yes Issinvice
Section 03-Description of Project
This source newly drilled nine(9)wells,nhicis first began producing o'September 16,2019,These permitting requests,are for intial permit coverage for fhe crude
oil storage tanks and,the crude oil loaaot,t:'Concurrently,this source has GPOY coverage for 2-400 bbl produced water storage tanks,The tanks have all
been constructer prior to May 1.,2020.
This facility in syntltt3c minor for VOC(NANSR and OP)and n-hexane.
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? 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? T No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) O O O O O O
Title V Operating Permits(OP) O O O O O ❑ ❑ O
Non-Attainment New Source Review(NANSR) O O
Is this stationary source a major source? No
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PMZ.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ O O O O O
Title V Operating Permits(OP) O O O O O O O O
Non-Attainment New Source Review(NANSR) ❑ ❑
•
•
•
Hydrocarbon Loadout Emissions Inventory
Section 01-Administrative Information
(Facility Allis ID: 123 AOC9 CO2
County Plant Point
Section 02-Equipment Description Details
Detailed Emis3ions Unit C ude O I Loadin
Description: _. • _ ., _ .. - � _ .x 1, -
Emission Control Device Erdbsed Cvn,nr I D �-s a9'ab ,.n,. 7
Description: as '•" 1 '; _t :*
is this Loadout controlled?
Requested Overall VOC&HAP Control Efficiency%: -0,.t , :.pa^
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= 821,250 Barrels(bbl)per year
'Requested Permit Limit Throughput= 985100 Barrels(bbl)per year Requested Monthly Throughput= 33700 Barrels(bbl)per month
Potential to Emit(PTE)Volume Loaded= : 985,599 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 25th Btu/scf
Actual Volume of waste gas emitted per year= 6x001^scf/year
Requested Volume of waste gas emitted per year= 28013 scf/year
Actual heat content of waste gas routed to combustion device= ,..'3'..MMBTU per year
Requested heat content of waste gas routed to combustion device= 357 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= ;?MMBTU per year
Control Device Accounted for with Crude Oil Tank
s P _:. IL d I li /i'" i J - 13 HJ J J rz %��`i
. °b dha' .wd,'Xital" :Li.�Afi�'�a�tl...'&indim..,.,. :mmi1twildimm fib°w...i Jx. .t/.4600.``l .,f
Section 04-Emissions Factors&Methodologies
Does the company use the state default emissions factors to estimate emissions? ahhWaM
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being
permitted? _. The.stabilfted hydrocarbon Iigvrd sample Is valid for develop-Ng site-specific emissions factors
Loading Loss Equation
L=12,48'5'P*M/T
Factor Meaning Value Units , Source
5 Saturation Factor tiedicatcri NormaaSera civt'S,-;s6))
P True Vapor Pressure 3,3559 psis `rAP-42'Chhpfer7,Teblo73729c--od[vi for temperature)
M Molecular Weight of Vapors 68 Ib/Ib-mol UP-41 Cheater 7,T=_tcle 7.1-2
Liquid Temperature 512.45 Rankine Lich cl lain l:Tempe,2'ure per EPA Tanks 4.0.97
Loading Losses ::_lb/1000 gallons
lb/bbl
Component Mass Fraction Emission Factor Units Source
Benzene 0.000210884 la -,..;_lb/bbl
Toluene 0.002321,04 lb/bbl
Ethylbenzene 0.000319299 - Ib/bbl
-,a ari HAP rracticiiII,A3 via l par aiimacii Gas,Sa 71017i 10,6'1010:
Xylene 0.000671589 - -=lb/bbl
n-Hexane 0.02040409, lb/bbl
224 IMP 1.53169E-05 _ :£,lb/bbl
Hydrocarbon Loadout
Uncontrolled Controlled
Emission Factor Source
Pollutant
(@fb61) (lb/bbl)
(Volume Loaded) (Volume Loaded)
-,P.,83(0).8 3AP-42i Ch pt r 5 2.;E s 1
•. '.2i € 9 MEM= `. y
i=iEMZE pL,5y t1
t tc-i3P-42 a is .n q..
Control Device _
Pollutant Emission Factor Source
(waste heat combusted) (Volume Loaded)
®
0.0000 ®-' ��.�.- 4,04,1,a (0006:
H ®` )e.t m0 I I < 0
rNINEM,rimE :� ,7/ r•writr r rr r in aNEIM•rarmv. :-SIS
twipmEmompo�/ccr� ;sPr� g 5.5a �N€rdo�dydt940✓riO u9 � oP9v r rr r :,r
r a bs,hc' �Pe+'niaY't�v ./i
EMEN
ri 7L. _,s isv.PA k`�'.
X; "s i
Or'-PMFAxidefOlIME fi x , igNi I t ` w�'
:...:.... gam. _.. -./blitaritineffirlggarayeagaitmili
2 of 12 C:\Users\Ilakocy\Desktop\Remote Working Docs\Package 8423156\20W E0202.CP1
Hydrocarbon i o?doot Emissions Inventory
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) (noes/year) (tons/year) (tons/year) (tons/year) lbs/month)
PM10 0.0:i 2222-, 0.,. 0.01 _2C 1
PM2.5 0.01 :3A1 0.017 0.01 1
sox 0,90 0.00 .,,_3 0.00 3 7 1
NOx 0,07 0.00 .,.32 0.07 :.. 1.
VOC 68.91 57.42 1237 58.90 _ 5
CO 0.30 0.21 2.__ 0.30 2 32 52
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
ribs/year) (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year)
Benzene 442 309 13 1
Toluene 020 257 23 55.
Ethylbenzene 44 37 2 2
Xylene 33 77 - 93
n-Hexane 3501 2557 3501 _-_
224TMP 2 2 _ 2 C.
Section 06-Regulatory Su mmary Analysis
Regulation 3,Parts A,B Seurce requires a per-r'
'Regulation 7 Part D Section ll.C.5. 3152.Y-,„rucarbon liqu:1,dude).xiti ce 15 sublecc Sc eguid_:",7 Pa.,___cton Ii.G5. 1
(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? •.kf.
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
•
Section 08 Technical Analysis Notes
•This source usedt eat,y)tlophof fn fleshedol sample to determine the anticipated HAP fractions of emissions.This is an acceptable methodobgy7-,L1-.5)-14,77-7). r'.r,'} rtyrz5 ,. y ?jl .
The source had slightly (gnu ryattveestlhletignsf.gstlymCalculations of combustion emissions(still below reporting thr eshold)than the method presented above,based on site-specific sampling.The source used the fas molecular weight,fraction of VOC .
by weight,and gross h abggyatde'o ,fla gad i,5rN arl to determine the PTE Flash O (MMBTU/year) 1
•
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point ti Process 0 SCC Code Pollutant Factor Control% Units
002 01 _5.02 Crude 011 Submerged Loading Normal S r c _ PM10 0 16/1,000 gallons transferred PM2.5 ___ 0 16/1,000 gallons transferred
SOx 3 13 0 lb/1,000 gallons transferred
NOx _.,_ 0 16/1,000 gallons transferred
VOC ._ 95 16/1,000 gallons transferred
CO _.__ 0 lb/1,000 gallons transferred
Benzene _-3. 95 lb/1,000 gallons transferred
Toluene 2.71 95 lb/1,000 gallons transferred
Ethylbenzene 0,C1C 95 lb/1,000 gallons transferred
Xylene 0.30 95 Ili/1,000 gallons transferred
n-Hexane 1.200 95 16/1,000 gallons transferred
224 TMP 9.12 95 '6/17,000 gallons transferred
3 of 12 C:\Users\Ilakocy\Desktop\Remote Working Docs\Package 0423156\20W E0202.CP1
Hydrocarbon Loadout Regulatory Analysts Worksheet
The regulatory requirements below ore determined based on requested emissions and throughput.
Colorado Regulation and 0•APEN and Permit Handsome.
ATTAINMENT
1.Are trolled actual emisslons from any alter,pollutants from this incliadual sauce greater than 2 TPy(Regulation 3,Partly Bectlon 0.0.2.a1?. •
2. Is to loatlout located:at an aplolation and production sire(Ng well paG lRegulatan 3,Part H,Section 11.0.1.11?
3. Is me loadout operation loading less than 30,000 gallons WS crude oil per day man annual average basis?
6. Is the loadout operation loading less than 6,]50660 per year of condensate via splash fill?
5. Is the loadout operation loading less thant6,30g lab's payees d condensate via submerged fill procedure?
E.Are taal facility uncontrolled PDC emissions greahrtans TM NON grater than 30 TPy a CO..km:greater than TO TM(Regulab'm 3,Part 0,Section llD.3)?
,aria n.ire Non.fitaturcent art,
NON.ATEA'NMENT
1.Are uncontrolled emissionsImm any criteria pork..firm Has individual source greater than lin'[Regulation 3,Part A,Section 0.0.2.21? tttlEtlatlkt:co m next question.
•
2. 0 the loadout looted at an exploration and production site(e.g.,well pad)(aegulatlon 3,Part B.Section zrePrirrth rto a the next question
Iz the loadoat operation loading less than Io 000 gallons WS BBL')or crude oil per day on an annual average basis? Y
a. h me loadout aperatfon loading less than 5250 Ws Per Year acontlensate Via P.M. estop
5. Is the loadout operation loading less than 16,303bbls per year of condensate via submerged fill procedure? NfithrO?i couestion
6. Are total facility uncontrolled VOC emisslons from the greater than 2 TPy,NOu greater than 5TPI or CO emlsslons greater than lO Tar(Regulation 3,Part b.stionll.o.Eli gy=.a'C?_a.₹.The aclout requires a permit
Colorado A anion ll.C5.
sthscondeensate storage tank hydrocarbon liquids loadout Mated at a well production facility,nature,gescompresserstaton or natural gaspraessirrgpknt? Nzahcarrithil Go ton.,question.
Does
2. the ny papa.N M1 of hydrocarbon vehicles q OOo barrels? Vaa ISounce is abject to Restalma Part O Section 0,5.
I-._ 7 n>1J6
Section S.a[i)-Complfarce Schedule
section'I.[S.a.liil-Operatlan wfrhaut Venting
SestionLCSaliiij-Load.Equipment Qcetal.and Maintenance
Section ll.C.S.a.(iv)-Load°.observations and Operator Training
SecbonS.a(v)-Records
Section II.Cs.a.Nll-Requirements tar Air Pollution control Equipment
Disclaimer
This document assists operefora with dolenntning applicability d certain loquirements of the Clean Air Act,as Implementing regulations,and Air Quality Control Commission regulations.This document is not a
rule or regulation,and the only sit onlelns may not apply to partku/ar situation based upon the individual facts and circumstances.This document does not change or substitute bevy/an,regulation,or
any other legally binding requirement and is not legally enforceable.In the event deny conflict between the language of this document and the language of the Clean Air Act„Its Implementing regulations,
ad Air Quality Control Commission regulations.the language of the statute on regulation will control.The usednonmandatoy language such as"meanmand,""may,""shout,"and'tan,"Is intended to
dosc to AFC('Interpretations and recommendations.Mandatory lerntinokgy such as'Moe end Kegdrec'unintended to describe 0mbolirg requirements under the trams of the Clean Air Act and Air
quality Control Commission regulations,but this document does nd establish legally birxbrg requirements in and d itself •
i. 1l9ffv inventory
Section 01-Administrative Information
'Facility AIRS ID: `a' 5 51GW'" .s.:a y7f ,_.. <' ., .,
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit Ta y fi 3iPvp&f'areiN .,� pt ``} tA" 'v
Description a'.,�"r>�..�rall,ns, ... �' a� ,.. , 'x"�:", 133 t��. .. . , ,..- ,':t`'.e rif' .. :s.
Emission Control Device r4.05ed$, rtyW eVace%:`.
Description: Lz "' ks*���-r' `% .4.4.vy'A , i .. . . -r:R
Requested Overall VOC&HAP Control Efficiency%:
Limited Process Parameter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= 021.050 O Barrels(bbl)per year
'Requested Permit Limit Throughput= ®?Barrels(bbl(per year Requested Monthly Throughput= PATTI;.0 Barrels(bbl)per month I
Potential to Emit(PTE)Condensate Throughput _,..:Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas °"'?'#,.` a -.' �'Btu/seF
Volume of waste Ii `gas emitted per BBL of liquids v� g, f s*n
produced= * ' ,-scf/bbl
Actual heat content of waste gas routed to combustion device= _2._48.11 MMBTU per year
Requested heat content of waste gas routed to combustion device= 12,898_1 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= I-658.1 MMBTU per year
Control Device
Pilot Fuel Use Rate: A ALAtwalv k scfh 1.3 MMscf/yr
Pilot Fuel Gas Heating Value: �, "m,'.,ss-- Btu/scf 2869-b MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions? •
Crude Oil Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Crude Oil (Crude Oil
Throughput) Throughput)
:x,5745461'
1;1972 =Mil=l'613k1,60'34133feq-tera46411i
Toluene
li9:12;;342%14,44.1%ritQl
Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) )Ib/bbi) Emission Factor Source
(waste heat (Crude Oil
combusted) Throughput)
1'66219 Plk6fAINVittgli*Var'65 :1 91''11
119141239913311%9911111,1451.292141199193;234,„.2541'
5215301159 26
,161.1006-9M12.11 ..r..
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source
(Pilot Gap Heat (Pilot Gas
Combusted) Throughput)
• A- x Rg
?, srxa. 4
= 6,4191'1 ISIMriterlftW.6-6,'9' .14114.00.4541t%1
Section OS-Emissions Inventor
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tans/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 1 0,1 _.1 3.1 5.1 10.fi
PM2.5 6.'. T.i _.a s.1
50x _.,. 0.0 0.0 0.0 1 0.8
Non .,.6 0.5 0.5 0.6 s 55,8
VOC j 332.4 377 0 18.5 333.4 942 2823.7
CO 2.6 2.2 2.2 2.9 _.5 341.5
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbsfyear) (lbs/year)
Benzene 2158.1 1805.8 30,3 2158.1 102.4
Toluene 1573.8 1314,.3 85.7 1576,8 78,8
Ethylbenzene .-_e.fi 1939.2 s.r. _.-TB 1-^8
5 of 12 C:\Users\Ilakocy\Desktop\Remote Working Docs\Package P423156\20WE0202.CP1
, Storage Tank(s)Emissions inventory
Xylene 443.5 369.6 13.5 443.5 22.2
n-Hexane 15852-1 14043.4 762.2 16852 1 142
224 TMP = 3.2 0.4 9.9 0.5
6 of 12 C:\Users\Ilakacy\Desktop\Remote Working Dacs\Package#423156\20WE0202.CP1
Stcr%gr (dl':14[c,r Emissons inveeircr'y
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B -_,. -0.55;5-
Regulation 7,Part D,Section I.C,D,E,F St3,3333iF.___ t ,van[0.13.4303- 303-
Regulation 7,Part D,Section 1.5,C Sra 7 3ot _ _,.30333-3 7.G
Regulation 7,Part D,Section 11.8,C.1,C.3 7373-3.3-3-333 3-3;40 R0030074 3 07_..t a.7...
Regulation 7,Part D,Section II.C.2 537,0074.3430. _ .a',3g:;:e ._ 1
Regulation 7,Part D,Section II.C.4.a.(i) sto^ ,,,__ 11 :e-t t.,Reg:-03n _ 5,33.
Regulation 7,Part 0,5ection II.C.4.a.(ii) Stomert.ar..s is ecs to 0340 lot c,.,.43-33 3.3.304-..r E -3
Regulation Regulation 6,Part A,NSPS Subpart Kb .34.03g0 734 si;rc.-Shot t0 r?Sc51ib
Regulation 6,Part A,NSPS Subpart 0000 S ne tar,::is.vis:1E47.t=_o30450000_
NSPS Subpart 0000a 5340303 310,3 iv n".at subinct to 315?5 00003
Regulation 8,Part E,MACT Subpart HH ..,ago`cant is no.33,03334 to 374013 40
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks,does the company use the state default emissions factors to
estimate emissions?
If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to he greater than or equal to 20 tons VOC per year OR are the 4,,..g,M7B1%PM55,
uncontrolled actual or requested emissions for a condensate storage tank estimated to he greater than orequal to 80 tpy? ff-tigllionskiqk,Zrt
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
permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample
should be considered representative which generally means site-specific and collected within one year of the application received 1
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?
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo Z0-02
Section 08-Technical Analysis Notes
f
7747
The volume of waste gas emitted per barrel includes both the flash GUI and th ewor.ing/breathing GOP. -
The combustion emissions from the gas combusted born the tank gases are based on the calculations provided by the source,which are based on mo e conservative e estimations for emissions,which considers the
fraction of VOc by weight,to consider the combustion:of all of the gas(notjusI VOC).For the calculation methods,see page 5 of record#123-ADC?4 The flash gas is calculated using the same methodology as the
working&breathing gas
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process# SCC Code Pollutant Factor Control% Units
703 01 PM10 __ _ lb/1,000 gallons Crude Oil throughput
PM2.5 .. lh/1,000 gallons Crude Oil throughput
SOx Win=.£, _ lb/1,000 gallons Crude Oil throughput
NOx 0 03 lb/1,000 gallons Crude Oil throughput
VOC 10.76 33 lb/1,000 gallons Crude Oil throughput
CO 0.13 „ lb/1,000 gallons Crude Oil throughput
Benzene v 55 lb/1,000 gallons Crude Oil throughput.
Toluene i 55 lb/1,000 gallons Crude Oil throughput
Ethylbenzene ,,.,__ 9.3 lb/1,000 gallons Crude Oil throughput
Xylene 3..1 91 lb/1,000 gallons Crude Oil throughput
n-Hexane G 41 93 lb/1,000 gallons Crude Oil throughput
224 TMP X u5 lb/1,000 gallons Crude Oil throughput
7 of 12 C:\Users\Ilakocy\Desktop\Remote Working Does\Package#423156\20WE0202.CP1
Source: Flash Liberation Analysis (taken 10/16/2019)
Tanks 4.0.9d Simulation
Total Emission
Emission Factor
Compound Weight Fraction (lb/bbl) of VOC Factor(W/B/Flash)
lb/bbl
Oxygen/Argon 1.8059 0.012721
Nitrogen 7.83020 0.055156
CO2 0.422200000 0.002974
CH4 0.33980 0.002394 _
Ethane 4.7285 0.033308
Propane 28.5606 0.201182
Isobutane 6.5721 0.046294 7.743
Butane 24.1043 0.169792 28.400
Isopentane 6.37770 0.044925 7.514
Pentane 7.8840 0.055535 9.289
Cyclopentane 0.667000 0.004698 0.786
n-Hexane 2.15620 0.015188 2.196 0.016965
Cyclohexane 0.53290 0.003754 0.628
Methylcyclohexane 4.39380 0.030950 5.177
Heptane 1.593900 0.011227 1.878
2,2,4-Trimethylpentane 0.0013000 0.000009 0.002 0.000010
Benzene 0.272500 0.001919 0.321 0.002179
Toluene 0.197000 0.001388 0.232 0.001576
Ethylbenzene 0.0271000 0.000191 0.032 0.000217
m-xylene 0.057000 0.000402 0.067 0.000456
Octane 0.68890 0.004853 0.812
Nonane 0.127900 0.000901 0.151
Decanes+ 0.659000 0.004642 0.776
VOC's 84.8732 0.597850 0.679
Hours/Year 8760
q any . A
f
VOC w/b (lb/bbl) 0.080929883
Gas Oil Ratio 5.4
Gas Molar Volume @ 60 F, : 379
Gas Molecular Weight 49.4387
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions.
Colorado Regulation 3 Parts A and B-OPEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY)Regulation 3,Part A,Section ll.D.1.al? - Source Requires an APES.Go to
2. Isthe constructiondate o 4/14/2014 and not modified after 4/14/14 with a storage tank throughput less than 40,000gallons per year(See P5 Memo 14-03 for additional guidance on grandfather applicability)? Go to next question
3 Are total facility ll d VOC emissions greater h 5TPY NO4 g h n 10TPY or CO emissions greater than St TPY(Regulation 3,Part 0 Section 5.0.3)? Source Requires a permit
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan 1TPy(Regulation 3,Part A,Section iiegiepfigj Source Requires an APEN.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 P5 Memo 1403 for additional guidance on grandfather applicability)? =000t next question
3. Are total facility uncontrolled VOC emissions greater than 2TPY,Nos greater than 5 TP5 or CO emissions greater than 10TPY(Regulation 3,Part B,Section 11.1.2)? . .Source Requires a permit
Colorado Regulation?,Part 0,Section I.C-F S G
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation],Part D,Section 1.4.1)7 -.h Continue-You have indicated th
2. Is this storage tank located at oil 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 7,Part o,Section l.A.11? Ifss Continue-You have indicated th
3. Is this storagetank located at a natural gas processing plant(Regulation?,Part D,Section I.0)? No Storage Tank is not subject to Re
4. uoesthisstonage tank contain condensate? n,_
5. Does Elk storegetank exhibit"Flash"(e.g.storing nun-stabilized liquids)emissions(Regulation 2,part 0,Seutlon 1.0.2)?
6. Are uncontrolled actual emissionsof this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part 0,Section l.D.3.a(ii))? ,",.l d t
Ix
Part D,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part D,Section 1.C.2—Emission Estimation Procedures
Part D,Section 1.0—Emissions Control Requirements
Part D,Section LE—Monitoring
PaKO,Section IS—Recordkeeping and Reporting
Part 0,Section l.G.2-Emissions Control Requirements
Part O,Section I.C.l.a and b—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Colorado Regulation 7.Part 0,Section II
I. Is this stonagetank located at a transmission/storage facility? No Continue-You have Indicated th
2. Is this storage tanks located at an oil and gas exploration and production operation,well production facility,natural gas compressor station'or natural gas processing plantt(Reguletion 7,Part 0,Section MC)? IIILL Go to the next question You ha
3. Does this storage tank have afxed roof(Regulation],Part D,Section ll.A.20)? {,a^y "atf 0o to the next question
4. Areuncomrolled actual emszons of this storage tank equal to or greater than 2tuns per year VOC(Regulation],Part o,Section ll.C.l.c)? Vr ,,.T4Source ssublectto parts of Reg
Part 0,Section ILE General.Provisions for Alr Pollution Control Equipment and Prevention of Emissions
Part 0,Section II.C.I-Emissions Control and Monitoring Provisions
Part 0,Section IIC.3 Recordkeepng Requirements •
5.-Does the storage tank contain only"stabilized"Iquds(Regulation 7,Part D,Section ll.C.2,h)? ?AI Sources subject to all provision.
fC: _.-
Part 0Section IIC2 Capture d M rt g for Storage ks fitted wthA Pollution Control Equipment
Is the controlled storage tank l t dat a well production facility, l g p- or station,or natural gas processing plant consructed on or after May 1,2020 or located at a faciBy that was modified on or after May 1,2020,such _
6 that an additional controlled storage vessel is constructed to receive an anticipated increase inthroughput of hydrocarbon liquids or produced water(Regulation],Part D,Sectior llC4ah)? t* )Storage Tanks not subject to Rs
Is the controlled storagetankl d at a wMI production facility,naturalgas compressor stati ural gas processing plantconstrusted on orafterlanuery 1,2021 or located at a tacitly that was modified on or afterlanuary 1,
] 2021,such that an additional controlled storage vessels constructed to receive an anticipated increase throughput of hydrocarbon liquids or produced water(Regulation'7,Part 0,Section llC4all)? ` B a�
40 CFR Part G Subpart Kb Standards of P K for Volatile Organic Liquid St Vessels
1. ls.the individual storage vessel p y g han or equal to]5 cubic meters(0)(-472 (40CFR 60.11ob(a))? ifia t3n]Siorage Tank's not subject NSP5
2. ooesthe storage vessel meet the following exemption 60.111b(d)(4).
a.Duesthe vessel has a design capacity less than or equal to 1,589.8]40'[-10,000 BBL]used for petroleum'or pro
cessed,stored, or treated prior to custody transfer'as 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 60.11ob(a))?
4. Does the tank meet the definition of"storage vessel"'in 60111b? • We,'S'S
5. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined in W.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a.Is the storagev sal a pressure sal designed to operate in excess of 204.9'Pa[t29.?pet and without emissions tothe atmosphere(60.110b(d)(2)1?;or "a,.
b.The d gn capacity is greater than or equal to 1510°(`950 BBL]and stores a liquid with a maximum true vapor pressures lessthan 3.5 kPa(60.110b(b))?;or
c The design capacity is greaterthan or equal to]5 Ms 1-4]2 BBL]but less than 1510'l`950 BBL]and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.11ob(b))? 4
7. Does the storage k meet either one of the following exemptions from control requirements: rte'_ ,
a.The design capacity is greater than or equal to 1510'[^950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to3.5kPa but less than 5.2kPa?;or l(�fi¢1aEI
b.The design capacity is greaterthan or equal 0075 M'[-4?2 BBL]but less than 151 m°['950 BBL]and stores a liquid with a maximum true vapor pressure greaterthan or equal to 15.0 Ma but less than 2].6 Oa? 6g421.1474
opssubiLif to NS,Kb
40 CFR,Part 60,Subpart 0000/0000e,Standards of Performance for Clyde Oil and Natural GasProduction,Tansmission and Distribution
1. Isthis storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of theindustry? Vas Continue-You have indicated th
2. Was this storag.vessel.constructed reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? „ ':t.-Storage Tanks not subject NSP5
3. Wasthls storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,2015? u5r1ztLi".jy^mfr Go to the next question
4 Are potential VOC emissions'from the individual storage vessel greaterthan or equal to 6t0ns per year? NEW?Storage Tanks not subject NSP5
5. Does this storage vessel meet the definition of"storage vessel'per 60.5430/6054300? dolly s`
6. Is the storage v selsubject to and controlled in accordance with requirements for storage vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? ft5/rx_.,
[Note:If a storage vessel Is previously determined to be subjectta SOPS 0000/00000 due to emissionsabove 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS 0000/0000a per
60.5365(e)(2)/60.5365a(ellel even if potential VOC emissions drop below 6 tons per year]
40 CFR,Part 63,Subpart MALT NH,Oil and Gas Production Facilities
1. Is the storagetank located at an oil and natural gas production facility that meets either of the following criteria: I-Les (Continue-You have indicated th
a.Afacility that processes,upgrades or stores hydrocarbon liquids'(63.]6u(a)(2));OR
h.Afacility that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user'(63.]60(a)(3)1?
2. Is the tank located at a facility that is major'for HAPs? 3u Storage Tank is not subject MAC
3. Does the tank meet the definition of'storage Vessel.*in 63.]61? ,
4. Does the tank meet the definition of"storage vessel wth the potential for flash emissons"'Par 63.761? 24,
5. Is the tank subjectto control requirements under 40 CFR Part 60-Subpart Kb or Subpart Oust?
SubpartA,General provisions per§63.764(a)Table t
§63.166-Emissions Control Standards
§53.773-Monitoring
§63.)74-Recardkeeping
§63:]]s-R5104i0g
RACF Review
PACT review is required if Regulation?does not apply AND tithe tank is In the non-attainment area.If the tank meets both criteria,then review PAR requirements.
Disclaimer
•
•
This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations,and Air Quality Contra/Commission regulations.This document is not
a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation,
or any other legally binding requirement and is not legally enforceable.In the event of any conf/ict between the language of this document and the language of the Clean Air Act„its implemening regulations,
and Air Quality Control Commssion regulations,the language of the statute or regulation will control.The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is intended to
describe-AP=interpretations and recommendations.Mandatory terminology such as"must"end"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air
Quality Control Commission regulations,but this document does not estaNlsh legally binding requirements in and of itself
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name HighPoint Operating Corporation •
County AIRS ID 123 History File Edit Date 5/2612020
Plant AIRS ID ARCS Ozone Status Non-Attainment
Facility Name Anschutz Equus Farms Fed 5.61-34 NESE Pro Last Modified By: Lauraleigh Lakocy
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total
Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 _ 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
001 OPUS Produced Water Tanks(2-400 bbl) 0.1 26.4 0.6 1.4 0.1 5.9 0.6 0.1 Newly requested emission source
002 20WE0202 Crude Oil Loading 0.1 68.9 0.5 2.2 0.1 3.4 0.5 0.1 Newly requested emission source
003 20WE0203 Crude Oil Tanks(10-500 bbl) 0.6 332.4 2.7 10.6 0.6 16.6 0.6 0.5 Newly requested emission source
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
APEN Exempt/insignificant Sources 0.0 0.0
External Combustion Sources-12 Heat( 0.3 0.3 4.2 0.2 3.5 0.0 0.3 0.3 4.2 0.2 3.5 0.0 From Form APCD-102 received 12/2019
Fugitives 0.5 0.0 0.5 0.0 From Form APCD-1O2 received 12/2019
0.0 0.0
0.0 0.0
FACILITY TOTAL 0.3 0.3 0.0 0.0 5.0 427.9 0.5 7.3 14.2 0.3 0.3 0.0 0.0 5.0 26.1 0.5 5.2 0.7 VOC: Syn Minor(NANSR and OP)
NOx:True Minor(NANSR and OP)
CO: True Minor(PSD and OP)
HAPS: Syn Minor n-hexane
Permitted Facility Total 0.3 0.3 0.0 0.0 5.0 427.9 0.0 7.3 14.2 0.3 0.3 0.0 0.0I 5.0 26.11 0.0 5.2 0.7 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions 0.3 0.3 0.0 0.0 5.0 26.1 0.0 5.2 pubcom required because new synthetic minor limits.
Modeling not required based on division guidelines.
Total VOC Facility Emissions(point and fugitive) 26.6 Facility is eligible for GP02 because<45 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) 26.1 Project emissions not less than 25 tpy-will go to
public comment
Note 1
Note 2
Page 11 of 12 Printed 5/26/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name HighPoint Operating Corporation
County AIRS ID 123
Plant AIRS ID A0C9
Facility Name Anschutz Equus Farms Fed 5-61-34 NESE Production Facility
Emissions-uncontrolled(lbs per year)
POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes _n-Hexane McOH 224 TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 GP08 Produced Water Tanks(2-400 bbl) 940 680 39 185 1017 1.4
002 20WE0202 Crude Oil Loading 442 320 44 93 3501 2 2.2
003 20WE0203 Crude Oil Tanks(10-500 bbl) 2134 1543 213 446 16887 11 10.6
0.0
0.0
0.0
0.0
APEN E 0.0
External Combustion Sources-12 Heaters 0.0
Fugitives 0.0
0.0
0.0
TOTAL(tpy) 0.0 0.0 0.0 1.8 1.3 0.1 0.4 10.7 0.0 0.0 0.0 0.0 14.2
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de rninimus
Emissions with controls(lbs per year)
POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 GP08 Produced Water Tanks(2-400 bbl) 47 34 3 9 51 0.1
002 20WE0202 Crude Oil Loading 22 16 2 5 175 0 0.1
003 20WE0203 Crude Oil Tanks(10-500 bbl) 107 77 11 22 844 1 0.5
0.0
0.0
. 0.0
0.0
APEN E 0.0
External Combustion Sources-12 Heaters 0.0
Fugitives 0.0
0.0
0.0
TOTAL(tpy) 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.7
12 20WE0202.CP1 E0202.C P1 5/26/2020
CDPHE Hydrocarbon Liquid Loading APEN
Form APCD-208
CO Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source(e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO)is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division(APCD)website at: www.colorado.;ov/cdphe/aped.
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: :kJ ��/ %� AIRS ID Number: t " 5 ,j7 1% 1,
jv
A;CD -
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Anschutz Equus Farms Fed 5-61-34 NESE Production Facility
Site Location
Site Location: NESE, Section 34, T5N, R61W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 555 17th St., Suite 3700
Denver, CO 80202 Contact Person: Marsha Sonderfan
Phone Number: 303-312-8524
E-Mail Address2: CDPHE_Corr@hpres.com
' Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Q3153 4:
w COLORADO
-Form APCD-2O$ Hydrocarbon Li o d Loading APEN Revision 3/2019 1 I ifterY ,r.
Permit Number: AIRS ID Number:
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)
O Change fuel or equipment ❑ Change company name3
❑ Change permit limit 0 Transfer of ownership4 0 Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Ft 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
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 9/16/2019
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes 0 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? ❑ Yes 0 No
Is this source located at an oil and gas exploration and production site? 0 Yes 0 No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual O Yes 0 No
average?
Does this source splash fill less than 6750 bbl of condensate per year? ❑ Yes 0 No
Does this source submerge fill less than 16308 bbl of condensate per year? ❑ Yes 0 No
COLOR4DO
,f 7, APCD 20 .ad,,),' bon Liy :d Loadln APEN FC ' x •2019 2 I .
Permit Number: AIRS ID Number:
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ID Crude Oil 0 Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: 985,500 bbt/year Actual Volume Loaded: 821 ,250 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 52 45 F
Saturation Factor: 0.6 bulk liquid loading:
Molecular weight of 68 lb/lb mol
True Vapor Pressure: 3,3559 Psia 60 'F displaced vapors: 'J
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year
Product Density: lb/ft'
Load Line Volume: ft'/truckload Vapor Recovery Line Volume: ft'/truckload
5 Requested values will become permit limitations. Requested limits)should consider future process growth.
COLORADO
3
Form A° 2C8 H d c b _iq+nd Load i� APFr! Pc„s i 3'20199 1 v.
Permit Number: AIRS ID Number:
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.354700/-104.186450
Discharge Height Above
Operator Ground Level Temp. Flow Rate Velocity
Stack ID No. (°F) (ACFM) (ft/sec)
(fit)
ECD TBD TBD TBD TBD
Indicate the direction of the stack outlet: (check one)
Upward ❑ Downward 0 Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter (inches): 84
❑Other(describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ Loading occurs using a vapor balance system: Requested Control Efficiency:
Used for control of: VOC, HAPs
Rating: TBD MMBtu/hr
Type: ECD Make/Model:Cimarron/Big Hurt
rn Combustion
ILjDevice: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A F Waste Gas Heat Content: 2,549 Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.24 MMBtu/hr
Pollutants Controlled:
❑ Other: Description: •
Requested Control Efficiency:
COLORADO
Form A33 3 8 F,r drocar bo., Lion id Loading ANN Pevisi jn 3/2019 4
Permit Number: AIRS ID Number: / /
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined)control efficiency(%reduction):
Overall Requested
Pollutant Description of Control Method(s) Control Efficiency
(%reduction in emissions)
PM
SOX
NO.
CO
VOC ECD 95%
HAPs ECD 95%
Other:
0 Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
0 Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
"! From what year is the following reported actual annual emissions data? 201 9
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)5
Pollutant
Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM
SOx
NOX 0.068 lb/MMBtu AP-42 0.09 0.11
CO 0.31 lb/MMBtu AP-42 0.41 0.49
VOC 0.1398 lb/bbl Eng.Est. 57.42 2.87 68.90 3.44
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission,Factor Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6
Number Basis Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 0.00045 Ib/bbl Eng.Est. 369 18
Toluene 108883 0.00032 lb/bbl Eng.Est. 267 13
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543 0.00355 lb/bbl Eng.Est. 2,917 146
2,2,4-
540841
Trimethyipentane
Other:
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave
blank.
otpr OiOR A D 0
Form APCD 208 rly c.rbon L!qu d oading APEII Revis,un 312019 5 I
EaG
Permit Number: AIRS ID Number:
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
Signature of Legally Authoriz 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:
fp Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303)692-3150
Denver,CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https:!/www.cotorado.gov;cdphe/apcd
[ COLORADO
r, APCD-2C8 HO;u rbv 1_ iid i_oadIng ADEN R_-1.,•-son 3 201c 6 I tl ,,..
CDPH Crude Oil Storage Tank(s) APEN
'4 Form APCD-210
CO ' Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require
payment for a new filing fee.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source(e.g.
condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the
General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A
list of alt available APEN forms and associated addendum forms can be found on the Air Pollution Control Division
(APCD)website at: www.colorado.govlpacificicdphe/air-permits.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number '! iJ r47 E t AIRS ID Number / ¢ r;2y/ !,,,( 3
;Pr I
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Anschutz Equus Farms Fed 5-61-34 NESE Production Facility
Site Location
Site Location: NESE, Section 34, T5N, R61W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip code) 555 17th St., Suite 3700
Denver, CO 80202 Contact Person: Marsha Sonderfan
Phone Number: 303-312-8524
E-Mail Address': 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 email to the address provided.
423152
COLORADO
Form APCD-21`J - Crude 0u:t Storogo Ta }k(s)APEN Rev-s;on 3 2319 1 , ....:
Permit Number: AIRS ID Number:
Section 2 - Requested Action
1❑ NEW permit OR newly-reported emission source
ID Request coverage under traditional construction permit
O Request coverage under General Permit GP08
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ Change permit limit O Transfer of ownership4 O Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
▪ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info&Notes:
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 Tank Battery
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 9/16/2019
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: Q Exploration E Production(E&P)site O Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? p Yes O No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes ❑Q No
805 series rules? If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual / Yes ❑ No
emissions≥ 6 ton/yr(per storage tank)?
COLORADO
E o rn'APCD 5lv C made Olttora e Talk(s) APEN Rcr1>ien 2 I crey ,,,., ..
Permit Number: AIRS ID Number: /
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits •
(bbl/year) (bbl/year)
Crude Oil Throughput: 821,250 985,500
From what year is the actual annual amount? 2019
Average API gravity of sales oil: 36.9 degrees RVP of sales oil: 6.9
Tank design: 0 Fixed roof O Internal floating roof O External floating roof
Total Volume of Installation Date of Most Date of First
Storage #of Liquid Manifold Storage
Storage Tank Recent Storage Vessel in Production
Tank ID Vessels in Storage Tank
(bbl) Storage Tank(month/year) (month/year)
Crude TKs 10 4,000 3/2019 9/2019
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) ❑
5 Requested values wilt become permit limitations. Requested limit(s)should consider future growth.
6 The EEP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.354700/-104.186450
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(feet) (°F) (ACFM) (ft/sec)
ECD TBD TBD TBD TBD
Indicate the direction of the stack outlet: (check one)
Q Upward O Downward O Upward with obstructing raincap
O Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
Q Circular Interior stack diameter(inches): 84
Interior
Square/rectangle Interior stack width(inches): n stack depth
h
{inches):
❑Other(describe):
pgi� toraaAoo
Form APCD-210 Crude Oil Storag-sank(s)APED Pension 3/2E19 3 I ma
Permit Number: AIRS ID Number: / /
a 3
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:
❑ Recovery
Unit (VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Pollutants Controlled: VOC, HAPs
Rating: TBD MMBtu/hr
Type: ECD Make/Model:Cimarron/Big Hurt
Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A Waste Gas Heat Content: 2,549 Btu/scf
Constant Pilot Light: ❑Q 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 (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —5 psig
Describe the separation process between the well and the storage tanks: Crude oil from the 3-phase inlet
separators go to the heated flash gas separators(heater treaters),then to the vapor recovery towers(VRTs),and then to the storage tanks.
COLORADO
Perm AP ` )I Crude O t Storage 1anki>) APE r ...�1 sion 3'2019 4
Permit Number: AIRS ID Number: / I
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall(or combined)control efficiency(%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%reduction in emissions)
VOC ECD 95%
NOx
CO
HAPs ECD 95%
Other:
From what year is the following reported actual annual emissions data? 2019
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor7 Actual Annual Emissions Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
I Uncontrolled Units (AP-42, Emissions Emissions8 Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
VOC 0.6745 lb/bbl Eng.Est. 276.97 13.85 332.36 16.62
NOx 0.068 Ib/MMBtu AP-42 0.50 0.59
CO 0.31 Ib/MMBtu AP-42 2.30 2.70
Non-Criteria Reportable Pollutant Emissions inventory
Chemical Emission Factor7 Actual Annual Emissions
Chemical Name Abstract Controlled
Uncontrolled Source Uncontrolled &
Service(CAS) Units (AP-42, Emissions Emissions
Number Basis Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 0.0022 lb/bbl Eng.Est. 1,779 89
Toluene 108883 0.0016 lb/bbl Eng.Est. 1,286 64
Ethylbenzene 100414
Xylene 1330207 0.0005 lb/bbl Eng.Est, 372 19
n-Hexane 110543 0.0171 lb/bbl _ Eng.Est. 14,073 704
2,2,4-
540841
Trimethylpentane
5 Requested values will become permit limitations. Requested limit(s)should consider future growth.
7 Attach crude oil laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave
blank.
'y �} /'� t COLORAD0
Form ADO 210 Crude 0 S vCa'3 ankl}1 APEN - r� y.y}l- 3;2019 5 v r r..i
Permit Number: AIRS ID Number: / f
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source
is and wilt be operated in full compliance with each condition of General Permit GP08.
1b—ba..1-2161
Signature of Legally Authorized on (not a vendor or consultant) Date
Marsha Sonderfan Senior EHS Specialist
Name(print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
Q Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303) 692.3150
Denver, CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.cotorado. ov:cd he'aocd
LAIN
COLORADO
F pcD 210 Cr i an Et 1; „_n.,_
,�, it � � z J Crude S��_3_'Ty ri151 'x�_,J P iS1�� 3='[+ 6 I
Hello