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HomeMy WebLinkAbout20203706.tiff 4 COLORADO Department of Public Health&Environment RECEIVED Weld County - Clerk to the Board 1150 o St PO Box 758 NOV 3 0 2020 Greeley, CO 80632 WELD COUNTY COMMISSIONERS November 23, 2020 Dear Sir or Madam: On November 24, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Crestone Peak Resources Operating, LLC - Echeverria 2A-2B Battery. 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 8t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ( : ks'r Jared Potis, Governor I Jilt Hunsaker Ryan,MPH, Executive Director Pub I ;C Rev-, e14 cc'.PL err) 1-11..(Ps),Pw(3MIER/cH/cw) 2020-3706 12./2 1 /20 OG(3 M) l2hl/2.O .M��.M Air Pollution Control Division 4C Notice of a Proposed Project or Activity Warranting Public DPHE Comment Website Title: Crestone Peak Resources Operating, LLC - Echeverria 2A-2B Battery - Weld County Notice Period Begins: November 24, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Crestone Peak Resources Operating, LLC Facility: Echeverria 2A-2B Battery Oil and gas well production facility NENW Section 2, T2N, R67W Weld County The proposed project or activity is as follows: Applicant proposes to combust gas from gas/liquid separators during gas collection system downtime at an existing well pad. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0492 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: Brad Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO as Department of Public 1 I Health 6 Enviromnem •»• COLORADO Wily Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0492 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: Echeverria 2A-2B Battery Plant AIRS ID: 123/1426 Physical Location: NENW Section 2 T2N R67W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Equipment Description Emissions Control ID Point Description Flaring of gas vented from the low pressure side of two (2) high/low pressure (HLP) Enclosed Buffer 006 separators and routed through the buffer Combustor(s) house during vapor recovery unit (VRU) downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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.govtpacific/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- Page 1 of 10 -x.�:<x COLORADO Air Pollution Control Division tile Department of Pubitc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Within one hundred and eighty days (180) after issuance of this permit, the operator must install a flow meter to monitor and record volumetric flow rate of gas vented from the low pressure side of the HLP separators covered by this permit. Until the flow meter is installed, the operator must monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 55.6 scf/bbl estimated in the permit application. 5. 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.) 6. 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 7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type Buffer 006 --- --- 4.1 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. Page 2 of 10 ,,,.r- COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and demonstrate compliance with the limits in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled Emissions from the low pressure side of two (2) high/low pressure (HLP) separators are Buffer 006 routed through the buffer house to VOC and HAP enclosed combustor(s) during vapor recovery unit (VRU) downtime. PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Equipment AIRS Process Parameter Annual Limit ID Point Natural gas vented from the low pressure side of the HLP Buffer 006 separators and routed through 2.23 MMSCF the buffer house to the enclosed combustor(s) The owner or operator must monitor monthly process rates based on the calendar month. Page 3 of 10 CC �r�+,� COLORADO 0* Air Pollution Control Division Department of Pubhc Health Fr Environment: Dedicated to protecting and improving the health and environment of the people of Colorado 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. 11. Upon installation of the flow meter, the owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the low pressure side of the HLP separators and routed through the buffer house to the enclosed combustor(s) using an operational continuous flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)I.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 15. The separators covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Page 4 of 10 CM V.I. COLORADO Air Pollution Control Division ��33ii���� Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 this point, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record-keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. 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, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,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 Page 5 of 10 C •r COLORADO Ir. :arf Air Pollution Control Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B). 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 alt 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. Page 6 of 10 Cz�:,,. COLORADO _ Air Pollution Control Division IDepartment of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer Permit History Issuance Date Description Issued to Crestone Peak Resources Operating, LLC Issuance 1 This issuance Permit for flaring of low pressure gas vented from the low pressure side of HLP separators at an existing synthetic minor well production facility. Page 7 of 10 C *:<r 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-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (Ib/yr) Benzene 71432 790 39 Toluene 108883 1067 53 Ethylbenzene 100414 38 2 Buffer 006 Xylenes 1330207 235 12 n-Hexane 110543 6874 344 2,2,4- 540841 5 <1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 C -Ail- COLORADO h3i ir Air Pollution Control Division Department of Pubhc Health&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 006: Natural gas vented from the low pressure side of the HLP separators and routed through the buffer house to the enclosed combustor(s): Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMSCF) (lb/MMSCF) VOC 71,976.39 3,598.82 Gas Analysis 71432 Benzene 353.69 17.68 Gas Analysis 108883 Toluene 477.68 23.88 110543 n-Hexane 3,078.19 153.91 Gas Analysis Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The VOC and HAP emission factors listed above are based on a site specific extended gas analysis obtained from the outlet of the buffer house (liquids knockout for low pressure gas vented from the low pressure side of the HLP separators) on 01/28/2020. The weight%values and molecular weight (39.55 lb/lbmol)from the sample along with the displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10)were used to determine the emission factors. Actual emissions are calculated by multiplying the emission factors in the table above by the total metered low-pressure gas vented from the low-pressure side of the HLP separators and routed through the buffer house to the enclosed combustor(s). 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 NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU Page 9 of 10 is .." COLORADO z* Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Bradley Eades Package#: 427115 Received Date 4/9/2020 Review Start Date: 10/2/2020 Section 01-Facility Information Company Name: Creston Peak Resources Operating,LLC Quadrant Section Township Range County AIRS ID: 123 NENW 2 2N 67 Plant AIRS ID: 1426 Facility Name: Echeverria 2A-25 Battery �" ; r.- yc � �;� Physical Address/Location: County: [Weld County Type of Facility: Exploration&Production Well Pad What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit Initial 006 Separator Venting Buffer Yes 20WE0492 1 s Yes Issuance Section 03-Description of Project Applicant is requesting a permit to combust gas from a gas/liquid separator in an enclosed combustor(during VRU gas collection system downtime)at an existing well pad.In addition,well pad is changing its name to reflect P&A of 2 wells at the facility. Applicant identifiesthe emitting equipment as a"buffer house"since this is the last stage of separation(liquid knockout)prior to combusting the gas.However,the emitting unit is the low pressure portion of the HLP separators(gas from HP side is always directed to sales). 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-W4de Stationary Source Classification Is this stationary source a true minor? No. Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) — Title V Operating Permits(OP) ✓ ❑ ❑ Non-Attainment New Source Review(NANSR) ✓ Is this stationary source a major source? No. If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) _ _ ❑ ❑ Non-Attainment New Source Review(NANSR) Separator Venting Emissions Inventory Section 01-Administrative Information 123 1426 006 Facility AIRs ID: ' County Plant Point Section 02-Equipment Description Details Venting of gas from two(2)low pressure separators to enclosed combustors when vapor recovery unit(VRU)is ffli +F" -s _ I Enclosed combrlstzr. Emission Control Device Description: +2,", Requested Overall VOC&HAP Control Efficiency%: 95 Limited Process Parameter NaturalG, `Vented Gas meter Yes meterwi1l be install (+within 180 dayri Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator ... Actual Throughput= ':w' MMscf per year IRequested Permit Limit Throughput= 2.23 MMscf per year Requested Monthly Throughput= ,.. MMscf per month Potential to Emit(PTE)Throughput= ' MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: !2229.4 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: 55.62 scf/bbl Control Device Pilot Fuel Use Rate: 25 scfh _ MMscf/yr Pilot Fuel Gas Heating Value: . 1000 Btu/scf Section 04-Emissions Factors&Methodologies Description Applicant pulled a pressurized liquid sample from HLP separator(117 psig,75F).In addition,applicant completed an extended gas analysis of sales gas emitted from HP side of HLP separator(113 psi,66f).These sample results were recombined using ProMax at the well head conditions and modeled through the HLP separator,and storage tanks.The resulting scf/bbl(as reported above as scf of gas emitted from the buffer house per bbl of sales oil produced)was used to estimate gas volumes:emitted from.the LP separator.Gas composition(as Indicated below)is based on an extended gas analysis of separator gas emitted from the"buffer house"(11 psig, 75F).The buffer house is the liquid scrubber downstream of the LP separator.Gas from the buffer house is directed to the combustors when the VRU is offline. MW I 39.6 Ib/Ib-mol Displacement Equation Ex=Q.MW'Xx/C Weight Helium CO2 2.7 N2 0.1 methane 12.1 ethane propane c.l.,'21.8 isobutane 5.2 n-butane :: 14.7 isopentane ..5.5 n-pentane cydopentane 0.4 n-Hexane 2.9 cydohexane 0.8 Other hexanes :.4.4 heptanes 2.6 methylcydohexane 1.1 224-IMP 0.0 Benzene 0.3 Toluene 0.5 Ethylbenzene 0.0 Xylenes 0.1 C8+Heavies 1.8 Total VOC Wt% .,..... 2 of 5 C:\Users\beades\Desktop\Remote Work\My Packages\Package 427115(Crestone Echeverria 2A-2B)\20WE0492.CP1 Separator V ntn Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ih/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 71976.39 359x.5'195 Extended gas analysis Benzene 353.69 17.6047 Extended gas analysis Toluene 477.65 23.8840 Extended gas analysis Ethylbenzene 16.80 0.8401 Extended gas analysis Xylene 105.41 5.27,05 Extended gas analysis n-Hexane 307,8.19 159 9096 Extended gas analysis 224 TMP 2,19 0.1996 Extended gas analysis Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 .x_1 AP-42 Table 1.4-2(PM10/PM.2.5) PM2.5 0.0075 ..61_4 AP-42 Table 1.4-2(PM70/PM.2.5) SOx 0.0006 1.3114 AP-42'Fable.1.4-2(50x) NOx 0.0680 _:..,5005 AP-42 Chapter 13.5 Industrial Flares(NOx) CO 0.3100- 690.__01 AP-42 Chapter 13,5 Industrial Flares(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) Ih/MMscf Emission Factor Source / (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0075 7.4510 AP-42 Table L4 (PM10/PM.2.5) PM2.5 - 0.0075 7.4510 AP-42 Table 1,4-2(PM10/PM.2.5) ntmp SOx 0.0006 0.5832 AP 42 Table 1.4-2(SOx) h NOx 0.0680, a..df 58.3600 AP-42 Chapter 13.5Indostrial Flares(NOx) t VOC '1111 0-10000 e ' CO 0.3100 3?0,0000 AP-42 Chapter 13.5 Industrial Flares(CO) x Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.0 0.0 0.3 ... 0.02 3 PM2.5 - 0.0 0.0 0.0 :. _. 0.02 3 SOx 0.0 0,0 0,0 _,O0 0.00 0 NOx I 0.2 0_0 0.0 0.18 0.18 30 VOC 80.4 0.0 4.0 50.36 4.02 6683 CO 0.8 0.0 0.0 0.31 0,81 137 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled . (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 790 0 0 790 39 Toluene 1067 0 0 1067 53 Ethylbenzene 31 0 0 33 2 • Xylene 235 4 0 - 235 12 — n-Hexane 0874 0 0 6374 344 224 TMP 5 0 4.0 0.2 i Sectiorr 06-Regulatory Summary Analysis Regulation 3,Parts A,B =_-.s -_,;sires a permit Regulation 7,Part D,Section II.B,F _--_, inject to Regulation 7,. - - Regulation 7,Part D,Section 11.0.2.0 -. _:ce for this seuarasor is .,,7,Part 0,Section 0 1.2.0 (See regulatory applicability worksheet for detailed analysis) • 3 of5 C4Users\beades\Desktop\Remote Work\My Packages\Package 427115(Crestone Echeverria 2A-2B)\20WE0492.CP1 Separator venting Emissions inventory Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID,and should have been collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific out sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area? If yes,the permit will contain: -An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? No If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. 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 20-02 Section 08-Technical Analysis Notes See section 04 emission calculation description for more information on sampling and process simulation used to estimate emissions. Applicant has indicated on the ADEN that source is not subject to Section XVII.G.(revised version citation is Regulation 7,Part D,II.F.Per this section,gas produced from wells that were constructed,hydraulically fractured or recompleted on or after 8/1/14 are subject to control requirements.Based on the APENs submitted for storage tanks,no new wells have been added at this facility. Applicant had originally requested to monitor emissions and process limits based on liquid throughput.However,it was communicated to the applicant that sources in NAA with uncontrolled emissions 0 50 tpy VOC would require meters.The.. operator agreed and will be given up to 180 days from issuance of permit to install and operate a meter. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only), AIRS Point P Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 006 01 3.10-001-80 Fla:as PM10 17.3 0 PM2.5 - 17.3 0 It;,"R sa- SOx 1.4 0 lb,r,V4Icy NOx 158,3 - 0 lb."//,SC' VOC 71976.4 95 Ib/N"1SCF CO 721.5 0 Il-'WhuS r Benzene 353,7 95 lbir7tslscF Toluene 477.7 95 ib NV.VSCF Ethylbenzene 16,8 95 h/'s=MSCF Xylene 105.4. 95 ibitiiitf:SCF n-Hexane 3078.2 95 i1/1‘1,05,:c 224 TMP 2,2 95 10/1,:15GF • 4 of 5 C:\Users\beades\Desktop\Remote Work\My Packages\Package 427115(Crestone Echeverria 2A-2B)\20WE0492.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN end Permit Reouirements IS1itce is in the Non-Atteinment..._:; ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? .� 2. Are total facility uncontrolled VOC emissions greater than STPV,NOx greater than 10 TPV or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.2.31? !Ohs bass indicated that s;stsa is Is tha Non-A?-tab:„ens Area NON-ATTAINM EMT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPV(Regulation 3,Part A,Section 11.0.1.a)? Ye.: lsource Re 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPV,NOx greater than 5 TPY or CO emissions greater than 30 TPV(Regulation 3,Part B,Section 11.0.21? 2s Source Re IScurce requims0 par_sit Colorado Regulation 7,Part D,Section II • 1. Was the well newly constructed,hydraulically fractured,or reoxmpleted on or after August 1,2014? ho (source is ISca._ .snot subloctts Regulation 7,Port 0,Sectic '1,0.2,P Section 11.8.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section n.E-Control of emissions from well production facilities Afternative Endsslons Control(Optional Sectlont a. Is the separator controlled by a back-up or alternatecombustion device(I.e.,not the primary control device)that is not enclosed? 'iis0, i^tij I'r is not satdastss._„at.0n7 Parr O,Sactiat.t8..o Section 11.8.2.0-Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is note 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 notlegally enforceable.la the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing . regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control.The use of non-mandatory language such as"recommend;"may,"'should,"and'can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as'must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. �;�:��r Gas Venting APEN - Form APCD-211 4 Air Pollutant Emission Notice (APEN) and CCDPHE Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /,/1 /E�1�4, AIRS ID Number: 123 / 1426 /otzJ `U cavo t- arik _,nt aPCD I rtrr:i t1 �_sr;3 d ,no mitt Inc;; ;IP ID Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC 4,0,9 e Site Name: Echeverria 2A-2B Battery Site Location Site Location: NENW Sec. 2, T2N, R67W Weld County: NAICS or SIC Code: 1311 Mailing Address: 10188 East 1-25 Frontage Road (Include Zip Code) g Firestone, CO 80504 Contact Person: Sabrina Pryor Phone Number: (303) 774-3923 E-Mail Address2: sabrina.pryor@crestonepccom 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. . gsk--COLORADO Foi m APCD-2 I i Gas Venting APEN - Revision 12 2019 1 , auf-Page 11 of 66 Permit Number: AIRS ID Number: 1 23 /1426/ [.1A'CC u'?n t i reran 'ariaAir6'D Section 2 - Requested Action NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 0 Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ 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: Buffer(separator)gas venting controlled by enclosed combustor Company equipment Identification No. (optional): Buffer For existing sources,operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 5/1/2020 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS 0 Yes ❑ No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes 0 No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No. 7, 0 Yes 0 No Section XVII.G? Ank COLORADO Farm APCD-2'11 Gas Venting,ADEN - Revisi€;n 12 2C 19 2 I sew °`°'""'"'°"""" Page 12 of 66 Permit Number: AIRS ID Number: 123 /1426i rryt, nl >: fiPCD r . ;3#rn:: „ig�?_.i ern . �i A'F;; ID] Section 4 - Process Equipment Information r❑ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes 0 No *Per revised calcs recieved 10-14-20. -B.E. Vent Gas 2 229 BTU/SCF Gas Venting Heating Value: , Process Parameters5: Requested: 2.23 MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput n Process Parameters5: Requested: 40,150 bbl/year Actual: bbl/year Molecular Weight: 39.55 VOC (Weight%) 68.97 Benzene(weight%) 0.3389 Vented Gas Toluene(Weight%) 0.4577 Properties: Ethylbenzene(Weight%) 0.0161 Xylene(Weight%) 0.1010 • n-Hexane(Weight%) 2.9494 2,2,4-Trimethylpentane(Weight%) 0.0021 Additional Required Documentation: ❑Q Attach a representative gas analysis(including BTEX Et n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis (including BTEX Et n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable, and should consider future process growth. Requested values are required on all APENs,including APEN updates. COLORADO Form APCD-211 Gas Venting APEN - Revision 12,2019 3 I > ® Page 13 of 66 Permit Number: AIRS ID Number: 123 /1426/ Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.1 70887/-104.861179 El Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Discharge Height Temp. Flow Rate Velocity Stack ID No. Above Ground Level (.F) (ACFM) (ft/sec) (Feet) Indicate the direction of the stack outlet: (check one) ❑ Upward O Downward O Upward with obstructing raincap ❑ Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter(inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth(inches): ❑ Other(describe): Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOCs, HAPs Rating: NA MMBtu/hr Type: Enclosed Combustor Make/Model: N/A Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 95 % Minimum Temperature: NA Waste Gas Heat Content: 2,229 Btu/scf Constant Pilot Light: ❑ Yes O No Pilot burner Rating: 0.025 MMBtu/hr Pollutants Controlled: O Other: Description: Requested Control Efficiency: % y ► COLORADO i Fou APCD-21+ Gas Venting APEN - Revision 12,2019 2019 4 I kit Page 14 of 66 Permit Number: AIRS ID Number: 123 /1426/ (Leave f!_..ik,gym' APCD tl,y, a•e i i J ssi2,e 1 ,;a=rt -t ='and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? El Yes 0 No If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SO. NO. CO VOC Enclosed Combustor(ECD) 100% 95% HAPs Enclosed Combustor(ECG)) 100% 95% Other: From what year is the following reported actual annual emissions data? NA Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP 42, Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NO. 0668 IbIMMBtu AP-42 -- 0.17 0.18 CO 0.31 Ib/MMBtu AP-42 -- 0.70 0.81 VOC 71.976 Ib/MMscf Site spec -35,.16 80.37 3.76.4,07 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes 0 No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions6 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 353.69 lb/MMscf Site specific -X39790 36-94 39 Toluene 108883 47768 lb/MMscf Site specific ees 1067 49-89 53 Ethylbenzene 100414 16.80 lb/MMscf Site specific s 38 t-?e 2 Xylene 1330207 105.41 lb/MMscf Site specific 224 235 l ll 12 n-Hexane 110543 3,078 IbIMMscf Site specific 6;498 6874 3a+a 344 2,2,4-Trimethylpentane 540841 2.19 IbIMMscf Site specific 5 023 0.2 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. COLORADO Form APCD-211 Gas Venting APEN - Revision 12 r20-(9 5 Id'."°-:, Page 15 of 66 Permit Number: AIRS ID Number: 123 /1426/ [' ,rt< <u❑ sAFC-7t , .. pE=rr t �:eARS'.Di1 Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. . • a r f t ' (1 r 04/06/2020 Signature of Legally Authorized Person(not a vendor or consultant) Date Sabrina M. Pryor Air Quality Engineer Name(print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 APCD-SS-B 1 OR 4300 Cherry Creek Drive South (303)692-3148 Denver,CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment COLONADO Form APCD 211 Gas Venting APEN - Revision 12i 20 19 6 I Page 16 of 66 Hello