HomeMy WebLinkAbout20203654.tiff C x7 COLORADO
Department of Public
x'41 ii���� Health&Environment
RECEIVED
Weld County - Clerk to the Board NOV 3 0 2020
1150 O St WELD COUNTY
PO Box 758 COMMISSIONERS
Greeley, CO 80632
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 - Sprague 9H-N267 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 Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
Ot rQt
4300 Cherry Creek Drive 5.. Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe r ` ,
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director # #_
PV b l;c, Re v:e(,.) cc:PL.(TP),Ht.(Ds),Pw(TjEQ/cH/c() 2020-3654
O(1O-m)
12/16/2.0 12/10/20
0,141 Air Pollution Control Division
yam'_
Notice of a Proposed Project or Activity Warranting Public
CDPHE
" Comment
Website Title: Crestone Peak Resources Operating, LLC - Sprague 9H-N267 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: Sprague 9H-N267 Battery
This facility is a well production facility.
SESW Section 9, T2N, R67W
Weld County
The proposed project or activity is as follows: This permit action converts the condensate storage tank
point from coverage under a general permit (GP01) to an individual construction permit (20WE0387) with
site-specific emission factors. This permit action also permits natural gas venting from separators under an
individual construction permit (20WE0388) with site-specific emission factors.
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 20WE0387 and
20WE0388 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:
Elie Chavez
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
1 �3ii i HeaithFiEnvfronment
C ,„..„.• COLORADO
a >___ Air Pollution Control Division
• �� Department of Public Health b Envtronment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0387 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
Facility Name: Sprague 9H-N267 Battery
Plant AIRS ID: 123/9E32
Physical Location: SESW SEC 9 T2N R67W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID Point Description
TANKS 001 Sixteen (16) 500 barrel fixed roof storage Enclosed
vessels used to store condensate Combustor(s)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days
after commencement of operation under this permit by submitting a Notice of Startup
(NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division
of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1
and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self-
certify compliance as required by this permit may be obtained online at
Page 1 of 11
-*?:'T COLORADO
Air Pollution Control Division
CDP4E`
Department of Public Health&Enutronment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO„ VOC CO Type
TANKS 001 -- --- 19.5 3.4 Point
Note:See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 11
COLORADO
o �/ Air Pollution Control Division
��i�� Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
TANKS 001 Enclosed Combustor(s) VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Facility AIRS Process
Equipment Process Parameter Annual Limit
ID Point
01 Condensate 74,825 barrels
TANKS 001 throughput
02 Combustion of pilot 1.8 MMscf
light gas
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. Monthly hours of enclosed combustion device operation must be monitored and recorded
monthly in a log to be made available to the Division upon request. Monthly hours of
combustion device operation will be used to monitor compliance with the CO emission
limitation and pilot light gas throughput limitation. (Regulation Number 3, Part B, Section
III.E.)
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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) _
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
Page 3 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
13. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by
means of visual observation from the outside of the enclosed combustion device, or by
other means approved by the Division, determine whether it is operating properly.
(Regulation Number 7, Part D, Section I.C.) (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 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.
16. 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.
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 Et MAINTENANCE REQUIREMENTS
18. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
Page 4 of 11
•r..�__ Air
COLORADO
A Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
19. The owner or operator must complete site specific sampling including a compositional analysis
of the pre-flash pressurized condensate routed to these storage tanks and, if necessary for
emission factor development, a sales oil analysis to determine RVP and API gravity. The pre-
flash pressurized condensate sample must be obtained from the outlet of the low pressure
side of the high/low pressure separators. Testing must be in accordance with the guidance
contained in PS Memo 05-01. Results of the analysis must be submitted to the Division as part
of the self-certification and must demonstrate the emissions factors established through the
analysis are less than or equal to, the emissions factors submitted with the permit application
and established herein in the "Notes to Permit Holder" for this emissions point. If any site-
specific emissions factor developed through this Analysis is greater than the emissions factors
submitted with the permit application and established in the"Notes to Permit Holder" the
operator must submit to the Division within 60 days, or in a timeframe as agreed to by the
Division, a request for permit modification to address these inaccuracies.
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
21. This permit replaces the following permits and/or points, which are cancelled upon issuance
of this permit.
Existing Permit Existing
Number Emission Point New Emission Point
GP01 123/9E32/001 123/9E32/001
22. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
Page 5 of 11
C .y....r,.1. COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For 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.
23. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference:Regulation Number 3, Part D, V.A.7B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Emissions - tons per year
Facility AIRS Equipment Current
Equipment Point Descri tion Pollutant
ID p Threshold Permit
Limit
Condensate
TANKS 001 Storage
Vessels
Condensate Hydrocarbon
Loadout 009 Liquid
Loadout
Compressor VOC 50 37.8
COMP-7a 019 Engine
COMP-5a 020 Compressor
Engine
COMP-6a 021 Compressor
Engine
Page 6 of 11
mr,. COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
COMP-1a 022 Compressor
Engine
GM-1 023 Pump Jack
Engine
GM-2 024 Pump Jack
Engine
Buffer 025 Separator
Venting
Insignificant ___ ---
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources (excluding
fugitives)is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
24. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
25. if this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in alt respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization section
of this permit.
26. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
27. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
28. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
Page 7 of 11
� COLORADO
� Air Poilution Control Division
t,�epanment of Puhtic Health b Envtronment
Dedicated to protecting and impraving the health and environment of the peopie of Cotorad�
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
29. Section 25-7-114.7(2)(a), C.R.5. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Elie Chavez
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Crestone Peak Resources Operating,
LLC.
Permit for sixteen (16) condensate storage
vessels at an existing well production facility.
These storage vessels were previously permitted
under GP01.
Page 8 of 11
COLORADO
itrip Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 1,938 97
Toluene 108883 1,866 93
Ethylbenzene 100414 102 5
001 Xylenes 1330207 688 34
n-Hexane 110543 15,413 771
2,2,4-
540841 44 2
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Process 01: Condensate Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 0.0841 0.0841 AP-42 Chapter
13.5
Page 9 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
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
VOC 10.4212 0.5211 ProMax
71432 Benzene 0.0259 0.0013 ProMax
108883 Toluene 0.0249 0.0012 ProMax
1330207 Xylene 0.0092 0.0005 ProMax
110543 n-Hexane 0.2060 0.0103 ProMax
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.The VOC and HAP
emission factors in the table above are based on a representative pressurized liquid sample and ProMax
simulation. The pressurized liquid sample was obtained from the Sprague 9A 3AA 2 Phase Separator on
12/20/2019 at 146.7 psig and 87°F. The CO emission factor was obtained from AP-42, Chapter 13.5 (0.31
lb/MMBtu)and was converted to the lb/bbl emission factor listed in the table above using a gas-to-oil (GOR)
ratio of 104.8 scf/bbl and a heat content of 2,589 Btu/scf. Actual emissions are calculated by multiplying the
emission factors in the table above by the total condensate throughput.
Process 02: Pilot Gas Combustion
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMscf lb/MMscf
CO 310.0 310.0 AP-42 Chapter
13.5
Note:The CO emission factor listed in the table above was obtained by multiplying the AP-42 Chapter 13.5 emission -
factor(0.31 lb/MMBtu)by a heat content of 1,000 Btu/scf. Pilot light gas fuel flow is based on a constant rate
of 25 scf/hr per pilot.Monthly pilot light gas fuel flow shall be determined by multiplying the hourly pilot light
gas flowrate by the monthly hours of enclosed combustion device operation for all operating combustors.
Actual emissions are calculated by multiplying the emission factors in the table above by the total pilot light
gas fuel flow.
Total actual emissions are obtained from the sum of emissions resulting from the storage
vessels and combustion of waste gas from the storage vessels (Process 01) and the
combustion of pilot light gas (Process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, HAP (n-Hexane Et total)
Page 10 of 11
. COLORADO
Air Pollution Control Division
caves
Department of Public Heath 6,Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC
MACT HH Area Source Requirements: Not Applicable
Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN -Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: ElieChavez
Package#: 428336
Received Date: 4/3/2020.
Review Start Date: 10/7/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,LLC Quadrant Section Township Range
County AIRS ID: 123 SESW 9 2N 67
Plant AIRS ID: 9E32
Facility Name: Sprague 9H-N267 Battery
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
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
001 Storage Tank TANKS Yes 20WE0387 1 Yes Issuance
Section 03-Description of Project
Modification request to convert condensate storage tank point(AIRS 001)from General Permit(GP01)coverage to an individual construction permit(20WE0387),
and to permit natural gas flaring from separator venting(AIRS 025)on an individual construction permit(20WE0388)..In addition, cancellation request forms were
submitted for the produced water storage tanks(AIRS 002)and fugitive emissions(AIRS 005),as these sources have dropped below APEN(and,pursuant to
Colorado Regulation No.3,Part B,Section II.D.1.a.,permitting thresholds).An additional cancellation requested was submitted for a Compressoo 01230 Natural
Gas Compressor(COMP-3;AIRS 013)as this equipment no longer exists onsite.Note that this PA addresses only the condensate storage tank point(AIRS 001).
The condensate storage tank point consists of 16 500 bbl fixed roof atmospheric condensate storage tanks with the potential for flash emissions. This application
requests new emissions and throughput limits for the condensate storage tanks that are more reflective of current operating conditions.This modification results ..
in an overall decrease in VOC and CO emissions.
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? 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) J IJ 0 0 i
Title V Operating Permits(OP) J L 0 0 0 I Li
Non-Attainment New Source Review(NANSR) Li
Colorado Air Permitting Project
Is this stationary source a major source?
If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs.
Prevention of Significant Deterioration(PSD) DODEID []
Title V Operating Permits(OP) O O O O ❑ ODD
Non-Attainment New Source Review(NANSR) L1 �.
Storage Tank(s)Emissions Inventors
Section 01-Administrative Information
!Facility AIRS ID: 123 9E333� n0 -'"-
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid Condensate ,�
Detailed Emissions Unit Sixteen(16)500 barrel fixed roof storage vessels used to store condensat T Pol7cY„t, r ,t
Description:
Emission Control Device Enclosed combustion device `‘' -
Description
Requested Overall VOC&HAP Coetrol Efficiency/: 95.0
Limited Process Parameter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= 61,760.0 Barrels(bbl)per year
Requested Permit Limit Throughput= 74,825.0 Barrels(bbl)per year Requested Monthly Throughput= 2205._ Barrels(bbl)per month
Potential to Emit(PTE)Condensate Throughput .74,825.0 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 2588.7 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced= 104.8 scf/bbl
Actual heat content of waste gas routed to combustion device= 16,752.2 MMBTU per year
Requested heat content of waste gas routed to combustion device= 20,296 0 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 20,296.0 MMBTU per year
Control Device
Pilot.Fuel Use Rate: #1,,. 700 sefh 1.6 MMscf/yr
Pilot Fuel Gas Heating Value: . - 1000 Btu/sct 17i2.2 MMBTU/yr
ProMax Output-Oil Tank Vapors Stream
MW I_... 46.0431 lb/Ih-mol
Weight%
Oxygen/Argon 0.0111
CO2 0.9708
N2 0.0147
methane 2.8303
ethane 14.1967
propane 32.6603
isobutane 7.6586
n-butane 21.3335
isopentane 5.8635
n-pentane 6.5972
cyclopentane 0.3484
n-Hexane 1.6204
cyclohexane 0.4821
Isohexane 2.9101
heptanes 1.0704
methylcyclohexane 0.4367
224-TMP 0.0046
Benzene 0.2038
Toluene 0.1962
Ethylbenzene 0.0107
Xylenes 0.0723
C8+Heavies 0.5076
Total 99.9999
VOC Wt% 81.9701
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions? Yes
Emission Factors. Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 10.4212 S.52.11 Site Specific liViash)
Benzene 0.0259 > Site Specific", flash) •
Toluene 0.0249 Site Specific„,. `flash)
Ethylbenzene 0.0014 - Site Specific' esflash)
Xylene 0.0092 Site SpecificEF.(includes flash)
n-Hexane 0.2060 Site Specific.E.F.(includes flash)
224 TMP 0.0006 Site Specific E.F.(includes flash)
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
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StorageTank(s)Emissions Inventory
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 AP 42' ` Zi{PM10/PM 2 5( '
PM2.5 0.0075 AP 42' (6'M10/PM 2 5)
SOx 0,0006 AP-4 (SOo)
NOx 0.0680 AP-4 5 Industrial Flares(NO0)
CO 0.3100 AP-42, , e'35Industrial Flares(CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant )Ib/MMBtu) (lb/MMscf) Emission Factor Source
)Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 r 19,0 AP-42 Table 1.4-2(PM10/PM.2.5)
PM2.5 0.0075 ;0 AP-42Table1.42(PM10/PM.2.5),.`
SOx 0.0006 -:.32 AP-42 Table 1.4-2(50x)
NOx 0.0680 :?10 AP-42 Chapter 135 Industrial Hares(NCB:
VOC 0.0054 _.._ AP-42 Table 1.4-2(VOC)
CO 0.3100 S.30100 AP-42 Chapter 13.5Industrial Flares(CO)
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 01 OS 0,1 0.1 .-_ 14.0
PM2.5 0.1 0.1. _ 0. -.. 14.0
500 0.0 0.0 _._ 3 C _._
NOx 0-7 ,., 0.7 3.7 127.3
VOC 321 S 3899 _ ___3 301:2.2
CO - 25 2.3 3.4 e.. 500.9
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year( (lbs/year)
Benzene 2528.1 1599.7 80.0 1938 _,
Toluene 1806.2 1540.4 77.0 1866 93
Ethylbenzene 102.2 34,4 42 102 5
Xylene 48^a,1 568.0 25.:y 688 34
n-Hexane 154188.0 12721.8 636.'1 15413 771
224 TMP 43.8 36.1 12 44
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Storage Tanks;Emissions Inventory
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B ..>
Regulation 7,Part D,Section I.C,D,E,F 7. . ,.,ction i.C-F Regulation 7,Part D,Section'LA,C
Regulation 7,Part D,Section 11.8,Cl,. C.3
Regulation 7,Part D,Section II.C.2 - ...ion II.C.2
Regulation 7,Part 0,Section II.C.4.a.(i)
Regulation 7,Part D,Section II.C.4.a.(ii)
Regulation 6,Part A,NSPS Subpart Kb
•
Regulation 6,Part A,NSPS Subpart 0000
NIPS Subpart 0000a
Regulation 8,Part E,MACT Subpart HH StoraF,Ta, [ L 3,L3C,
(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 be grater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to BO tpy? "`„,N/A-site specific emission factors developed
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 ynn 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 date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to
use an alder 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 20-02
Section 08-Technical Analysis Notes
1.The operator submitted a representative pressurized condensate sample for the Sprague 9A facility,obtained on 12/20/2019 from the 3AA 2 phase separator,on which ProMax modeling for these condensate
storage tanks was based.Because this sample was not obtained at the Sprague 9H facility,initial sampling to verify the emission factors developed for this permit will be required as part of the self-certification
for this facility.The sample obtained shall be a pm-flashed sample of pressurized condensate in accordance with the guidance in PS Memo 05-01.In the event that this sample results in higher emission factors
than those listed in the permit,the operator must submit an application to modify this permit within 60 days.
2.This facility is controlled by a bank of combustors.Emissions from the condensate storage tanks,condensate truck loadout and separators are comingled in a waste gas header and routed to the combustors.
Pilot light emissions for this facility are conservatively estimated based on eight combustors operating at 8760 hours/year at a constant pilot flowrate of 25 scfh per pilot(200 scfh total),as requested in operator
correspondence received 11/11/2020.These pilot emissions were included in the emissions calculations for the condensate storage tanks only,as requested in operator correspondence received 10/20/2020.
Previously,pilot light emissions were assumed to be split between the condensate storage tanks,condensate truck loading and the separators.However,because these units do not have dedicated combustors
and are instead controlled by a bank of combustors,it was determined that for ease of monitoring compliance with pilot light throughput limitation that all pilot light emissions be accounted for with the
condensate storage tanks,as they are the highest emitting unit for both CO and VOC of the controlled units.
3.An updated ProMax run and GOR calculation were submitted on 10/15/2020.The ProMax tank losses stencil was updated to reflect 16 tanks and the GOR was updated using the standard vapor volumetric
flow of the"oil tank vapors"stream and the standard liquid volumetric flow of the"LP oil"stream obtained from the revised ProMax model.These alterations resulted in a GOR of 104.8 sef/bbl and a heat
content of 2,589 Btu/scf,which were used in the Division's preliminary analysis.
4.NOx emissions from this source are below APEN reporting thresholds.As such,emission limitations and emission factors for NOx were not included in the construction permit.
5.Ethylbenzene and 2,2,4-Trimethylpentane emissions are below APEN reporting thresholds.As such,emission factors were not included in the construction permit.
6.It should be noted that an emission factor for VOC associated with pilot light combustion is not incorporated into the permit.This is due to the fact that the pilot light only results in a negligible contribution of
VOC(0.005 tpy).This minimal amount of emissions does not impact the total VOC limit for this source and therefore can be ignored.
7.Actual emissions reported on.the APEN received with the 4/3/2020 permit modification application are calculated using previously approved emission factors.The actual emissions in this analysis do not match
with the information on the APEN because these actual emissions are calculated using the new emission factors requested in this application.Asa result,actual emissions for this source should be referenced on
the APEN submitted on 4/3/2020.
8.Initial and periodic visible emissions monitoring for the control device are addressed by the O&M plan.As such,this permit does not contain initial or periodic testing for visible emissions.
9.This facility is not yet subject to the storage tank measurement system requirements of Colorado.Regulation No.7,Part D,Section II.C.4.These requirements apply to existing controlled storage tanks that are
modified after 5/1/2020 such that an additional condensate storage vessel is added.Pursuant to the APEN received with the 4/3/2020 application,the date of last storage vessel installation was 7/2015.As such,
these condensate storage tanks are not subject to the provisions of Section II.C.4.
10.This facility is not subject to the storage vessel provisions of NIPS Kb as the vessels meet the exemption set forth in§60.110b(d)(4)which excludes storage vessels with a capacity less than or equal to
1,589.874 m3(`10,000 bbl)storing condensate prior to custody transfer.Each condensate storage vessel at this facility has a rapacity of 500 bbl.Custody transfer is defined in§60.111b as"the transfer of
produced petroleum and/orcondensate,after processing and/or treatment in the produang operations,from storage vessels or automatic transfer fa Imes to pipelines or any other forms of transportation..By
definition,a transfer of condensate from one facility to another must occur.Because the condensate stored at this facility is first treated at this facility and no transfer of facilities has occurred,the storage
vessels are located prior to custody.transfer,As such,these storage vessels fulfill both the capacity and custody transfer criteria of this exemption and are therefore not subject to NSPS Kb.
11.This facility is not subject to the storage vessel provisions of NIPS 0000 as potential VOC emissions,when considering enforceable controls in accordance with§60.5365(e(,are less than 6 tons/year.It
should also be noted that this storage tank has never been subject to NSPS 0000,as GP01 coverage is prohibited for condensate storage tanks subject to NIPS 0000/a.Because these storage vessels qualified
for GP01 coverage prior to this permit modification action,these storage vessels have never been subject to NIPS 0000/a.
12.This facility is not subject to the storage vessel provisions of NSPS 0000a as a result of this permit modification request.A"modification"for the purposes of New Source Performance Standards,as defined
in§60.2,"means any physical change in,or change in the method of operation of,en existing facility which increases the emountof any air pollutant(to which asfendard applies)".NSPS 0000a.governs VOC
emissions from certain oil and gas sources,including storage vessels located at well production facilities.However,this permit modification request resuitedin a decrease in emissions from these condensate
storage tanks,Further,no physical change or operational change results from this modification.As such,this permit modification request does not constitute a'"modification"as defined in 560.2 and therefore
does not trigger NIPS 00000 requirements for this facility.
13.This facility is not subject to the storage vessel provisions of MACT HH as individual and total HAP emissions from this facility are below the 10 tons/year individual HAP and 25 tons/year total HAP major
source thresholds.Storage vessel requirements apply only to major sources of HAP.Because facility-wide HAP emissions at this facility are below the major source thresholds for HAP,this facility is not subject to
the storage vessel provisions of MACT HH.
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
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Storage nkEq--issicrts inventory
Uncontrolled
Emissions
AIRS Point ft Process A SCC Code Pollutant Factor Control%Units
101 01 c `` •V` = - •'y "tfi t A 8 PM30 0 5 r Ib I,000 gallons Condensate throughput
j { ga
PMZ.5 3 05 0 lb/1,000 gallons Condensate throughput
SOx 0.00 C lb/1,000 gallons Condensate throughput
NOx 0.2E 0 lb/1,000gallons Condensate throughput
VOC 04&.S3 es lb/1,000 gallons Condensate throughput
CO 2.17 ., lb/1,000 gallons Condensate throughput
Benzene C.61 ass lb/1,000 gallons Condensate throughput
Toluene O.a9 95 lb/1,000 gallons Condensate throughput
Ethylbenzene u.-33 45 lb/1,000 gallons Condensate throughput
Xylene C.22 3s lb/1,000 gallons Condensate throughput
n-Hexane ,-.03 95 lb/1,000 gallons Condensate throughput
224 TMP 0 C 95 lb/1,000 gallons Condensate throughput
•
•
fi oft K:\PA\2020\20WE0387.CP1
•
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)?
2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS.Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B,Section II.D.3)?
'you have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3,Part A,Section II.D.1.a)?
2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B,Section II.D.2)?
'Source requires a permit
Colorado Regulation 7,Part D,Section I.C-F&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 7,Part D,Section I.A.1)?
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 I
3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part D,Section I.G)?
4. Does this storage tank contain condensate?
5. Does this storage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation 7,part D,Section I.G.2)?
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section I.D.3.a(ii))?
'Storage tank is subject'to Regulation 7,Part Et,Section I.C.;-F
Part D,Section I.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part D,Section I.C.2—Emission Estimation Procedures
Part D,Section I.D—Emissions Control Requirements
Part D,Section I.E-Monitoring
Part D,Section I.F—Recordkeeping and Reporting
Storage Tank is not subject to Regulation 7,Section l.Ca
Part D,Section I.G.2--Emissions Control Requirements
Part D,Section I.C.1.a and b —General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Colorado Regulation 7,Part D,Section II
1. Is this storage tank located at a transmission/storage facility?
2. Is this storage tank'located at an oil and gas exploration and production operation ,well production facility2,natural gas compressor station'or natural gas processing plant4(Regulation 7,Part D,Section II.C)?
3. Does this storage tank have a fixed roof(Regulation 7,Part D,Section II.A.20)?
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section II.C.1.c)?
'Storage tank is subject to Regulation 7,Part 0,Section 11,Ei,C,1&C,3
Part D,Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D,Section Il.C.1-Emissions Control and Monitoring Provisions
Part D,Section II.C.3 Recordkeeping Requirements
5. Does the storage tank contain only"stabilized"liquids(Regulation 7,Part D,Section II.C.2.b)?
Storage tank is subject to Regulation 7,Part 0,Section II.C.2
•Part D,Section II.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified on i
6. 1,2020,such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part D,Section II.C.4.a.(i)?
Storage Tank is not subject to Regulation"7,mart Gb,Section
Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or after January 1,2021 or located at a facility that was modified
7. January 1,2021,such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part D,Section II.C.4.a.(ii
'Storage Tank is not subject to itegulaaticars 7,Part D,Section ll.A.4.adi),kr-f
40 CFR,Part 60,Subpart Kb.Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters(m 3)["472 BBLs](40 CFR 60.110b(a))?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3["10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined in 60.1111
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984(40 CFR 60.110b(a))?
4. Does the tank meet the definition of"storage vessel"3 in 60.111b?
5. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined in 60.111b?
6.- Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa["29.7 psi]and without emissions to the atmosphere(60.110b(d)(2))?;or
b. The design capacity is greater than or equal to 151 m3[ 950 BBL]and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa(60.110b(b))?;or
c. The design capacity is greater than or equal to 75 M3[ 472 BBL]but less than 151 m3[ 950 BBL]and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11ob(b))?
7. Does the storage tank meet either one of the following exemptions from control requirements:
a.The design capacity is greater than or equal to 151 m3[R950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?;or
b.The design capacity is greater than or equal to 75 M'[ 472 BBL]but less than 151 m3["950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less thar
!dotage Tank hs not subject to icarto Kb
40 CFR,Part 60,Subpart OOOO/OOOOa,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distributior
1. Is this 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 the industry?
2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015?
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,2015?
4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year?
5. Does this storage vessel meet the definition of"storage vessel"2 per 60.5430/60.5430a?
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
IStorat„e,Tank is rsnt subject to NSPS OOOO
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS
OOOO/OOOOa per 60.5365(e)(2)/60.5365a(e)(2)even if potential VOC emissions drop below 6 tons per year]
40 CFR,Part 63,Subpart MACT HH,Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.760(a)(2));OR
b.A facility 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 Z(63.7(
2. Is the tank located at a facility that is major'for HAPs?
3. Does the tank meet the definition of"storage vesseli4 in 63.761?
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart OOOO?
MA(,1 -Y
Subpart A,General provisions per§63.764(a)Table 2
§63.766-Emissions Control Standards
§63.773-Monitoring
§63.774-Recordkeeping
§63.775-Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria,then review RACT requirements
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations, and Air Quality Control Commission regulation.
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 chat
substitute for any law,regulation,or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the Ian!
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
"recommend,""may,""should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to de.
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
wt.
. COLORADO
Air Pollution Control Division
CDP}tE'
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0388 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
Facility Name: Sprague 9H-N267 Battery
Plant AIRS ID: 123/9E32
Physical Location: SESW SEC 9 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 natural gas during vapor
recovery unit (VRU) downtime vented from
Buffer 025 the low pressure sides of six (6) High/Low Enclosed
Pressure (HLP) Separators and routed Combustor(s)
through the buffer house.
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.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-
Page 1 of 11
COLORADO
Air Pollution Control Division
COPSE
Department of Public Health&Envtronment
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. 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:
AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOx VOC CO Type
Buffer 025 --- --- 10.2 --- 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.
Page 2 of 11
COLORADO
Air Pollution Control Division
CPP s
Department of Pubic Health 6 Ery ronment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
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.)
Equipment AIRS Control Device Pollutants
ID Point Controlled
Emissions from the low pressure sides of six
(6) HLP separators are routed to enclosed
Buffer 025 VOC and HAP
combustor(s) during vapor recovery unit
(VRU) downtime.
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
Equipment ID AIRS Process Parameter Annual Limit
Point
Natural gas venting from the low
Buffer 025 pressure sides of the HLP separators 4.6 MMSCF
routed through the buffer house to
the enclosed combustor(s)
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the low pressure sides of the HLP Separators 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
Page 3 of 11
COLORADO
r
Air Pollution Control Division
Department of Publie Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
11. 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)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The combustion device(s) covered by this permit are 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 separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or
after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oit 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.
15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING £t MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
Page 4 of 11
COLORADO
Air Pollution Control Division
CDPki: ..
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
Page 5 of 11
-� : COLORADO
Air Pollution Control Division
COPFIE
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
20. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Emissions - tons per year
Facility AIRS Equipment Current
p
Equipment Point Description
Pollutant
ID Threshold Permit
Limit
Condensate
TANKS 001 Storage
Vessels
Condensate Hydrocarbon
Loadout 009 Liquid
Loadout
COMP-7a 019 Compressor
Engine
COMP 5a 020 Compressor
Engine
COMP-6a 021 Compressor
Engine VOC 50 37.8
COMP-1a 022 Compressor
Engine
GM-1 023 Pump Jack
Engine
GM-2 024 Pump Jack
Engine
Buffer 025 Separator
Venting
Insignificant
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources(excluding
fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
Page 6 of 11
C , ,,, ...r...:f. COLORADO
‘ Air Pollution Control Division
Department of Public Health{r Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization section
of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
Page 7 of 11
COLORADO
Air Pollution Control Division
cow
Department of Public Health Fr Enufronment
Dedicated to protecting and improving the health and environment of the people of Colorado
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Elie Chavez
Permit Engineer
Permit History
Issuance Date Description
Issued to Crestone Peak Resources Operating,
LLC.
Issuance 1 This Issuance Permit for natural gas flaring from the low
pressure sides of six (6) HLP Separators at an
existing well production facility.
Page 8 of 11
-, . COLORADO
Air Pollution Control Division
Wei
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) (lb/yr)
Benzene 71432 693 35
Toluene 108883 505 25
Ethylbenzene 100414 22 1
Buffer 025 Xylenes 1330207 130 7
n-Hexane 110543 5608 280
2,2,4-
540841 2 0
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 11
COLORADO
etE
Air Pollution Control Division
Department of Public 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:
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
(lb/MMscf) (lb/MMscf)
VOC 89091.0722 4454.5536 Gas Analysis
71432 Benzene 150.5594 7.5280 Gas Analysis
108883 Toluene 109.7641 5.4882 Gas Analysis
110543 n-Hexane 1219.1258 60.9563 Gas Analysis
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.The VOC and HAP
emission factors listed in the table above are based on a site-specific extended gas analysis obtained from
the outlet of the buffer house(liquids knockout for the low pressure gas vented from the low pressure sides
of the HLP separators)on 4/9/2018 at 25 psig and 68°F. The weight%values (79.1%VOC, 0.13% Benzene,
0.10%Toluene, 1.08%n-Hexane)and molecular weight(42.7 lb/lbmol)were used with the displacement
equation (EPA Emission Inventory,Improvement Publication, Volume II, Chapter 10)to determine the emission
factors.Actual emissions are calculated by multiplying the emission factors listed in the table above by the
total metered low pressure gas vented from the low pressure sides 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 arinual 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, HAP (n-Hexane a total)
PSD 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
NSPS Part 60, Appendixes Appendix A - Appendix I
Page 10 of 11
: '- COLORADO
Air Pollution Control Division
• trex`
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permittirig Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Elie Chavez
Package#: 428336
Received Date: 4/3/2020
Review Start Date: 10/8/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,LLC Quadrant Section Township Range
County AIRS ID: 123 SESW 9 2N 67
Plant AIRS ID: 9E32
Facility Name: Sprague 9H-N267 Battery t '
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
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
025 Separator Venting Buffer Yes 20WE0388 1 Yes Issuance
Section 03-Description of Project
Modification request to convert condensate storage tank point(AIRS 001)from General Permit(GP01)coverage to an individual construction permit(20WE0387),and to permit
natural gas flaring from separator venting(AIRS 025)on an individual construction permit(20WE0388).In addition,cancellation request forms were submitted for the produced
water storage tanks(AIRS 002)and fugitive emissions(AIRS 005),as these sources have dropped below APEN(and,pursuant to Colorado Regulation No.3,Part B,Section
II.0.1.a.,permitting thresholds).An additional cancellation requested was submitted for a Compressco:GJ230 Natural Gas Compressor(COMP-3;AIRS 013)as this equipment no
longer exists onsite.Note that this PA addresses only the natural gas venting from separators point(AIRS 025).
The separator venting point consists of six(6)high/low pressure separators.Each separator has a high pressure side,the gas from which is routed to a VRU and then to the sales
line.Each separator also has a low pressure side,which is routed to a vapor recovery unit(VRU)and then to the sales line.In the event of VRU downtime for the low pressure gas,
the low pressure side of the separators are routed to enclosed combustor(s)for destruction.This application requests an initial permit for the venting of low pressure gas during
VRU downtime from the HLP separators.
Sections 04,OS&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? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) LILL Li U U
Title V Operating Permits(OP)
Non-Attainment New Source Review(NANSR) U
Is this stationary source a major source? No
Colorado Air Permitting Project
If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 T5P HAPs
Prevention of Significant Deterioration(PSD) LJ U U LJ L) L_I
Title V Operating Permits(OP) U U LJ LJ U LJ U LJ
Non-Attainment New Source Review(NANSR) ❑ ❑
Em)ss(ons.inventor
Section 01-Administrative Information 123 9E32 025
Facility Allis ID: County Plant Point
Section 02-Equipment Description Details
Flaring of natural gas during vapor recovery unit(VRU)downtime vented from the low pressure sides of six(6)High/low Pressure(HIP)
Detailed Emissions Unit Description: Separators and routed through the buffer house
- - Enclosed Combustion Device during vapor recovery unit(VRU)downtime
Emission Control Device Description:
Requested Overall VOC&HAP Control Efficiency%: 95 .
Limited Process Parameter
Gas meter . )f.e3 e`da
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput= '...MMscf per year
Requested Permit Limit Throughput= -4,6 MMscf per year Requested Monthly Throughput= r.i MMscf per month
Potential to Emit(PTE)Throughput= -..6 MMscf per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: 2447.0 Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput: scf/bbl
Control Device -
Pilot Fuel Use Rate: 4?scfh 5.9 MMscf/yr *Pilot light emissions are caputred at the condensate storage tanks(AIRS 001,20WE0387)
Pilot Fuel Gas Heating Value: ''Btu/scf
Section 04-Emissions Factors&Methodologies
Description
Eighteen(18)wells at this facility produce to six(6)high/low pressure(HIP)separators.The high pressure gas from the high pressure side of the HIP separators is routed to the sales line via vapor recovery units.If this
sales line becomes unavailable,the facility shuts in.The low pressure gas from the low pressure side of the HIP separators is typically routed through a buffer house(liquids knockout)and then to the sales line via vapor
recovery units.During vapor recovery unit downtime,the low pressure gas vented from the low pressure side of the HIP separators is routed through a buffer house(liquids knockout)and then to the enclosed
combustor(s).In order to develop site specific emission factors,the operator obtained a gas sample from the outlet of the buffer house on 4/9/2018.This gas sample is representative of only low pressure gas vented
from the low pressure side of the HIP separators and routed through the buffer house and then to the enclosed combustor(s).The sample temperature and pressure are 68°F and 25 psig respectively.The molecular
weight and weight%values from the sample were used in conjunction with the Displacement Equation listed below to develop the site specific emission factors.
MW I 42.7 lb/Ib-mol Displacement Equation
Ex=Q*MW*Xx/C
Weight%
Oxygen/Argon 0.0470:.
CO2 1.0834
N2 0.1655'
methane 5.3473 •
ethane 14.3013
propane 36.7717
isobutane 8.1645
n-butane 19.7454
isopentane 4.5271>>..
n-pentane 4.9141
cyclopentane 0.2652.. •
n-Hexane 1.0818
cyclohexane 0.2598.
Other hexanes 1.8742
heptanes 0.5861
methylcyclohexane 0.2202.
224-IMP 0.0004
Benzene 0.1336.
Toluene 0.0974.
Ethylbenzene 0.0043
Xylenes 0.0251
C8+Heavies 0.3847
Total
VOC Wt%
3 of 6 K:\PA\2020\20WE0388.CP1
Separator Venting Emissions inventory
Emission Factors Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (Ih/MMscf( (Ib/MMscf)
(Gas Throughput) (Gas Throughput)
VOC ended gas.analysis
Benzene 53-� EXtettded gas anaysis �;
Toluene R_ irded gaSanalysis `
Ethylbenzene =-__ _. _:#zt idedgas analysis .1-'n'
Xylene _ _ ._-3 =s':£xtenriedgasonalysis -ms's '
n-Hexane __ __,-_ �_ `:=,"Extended gas analysis
224 TMP . _ ,-=_'£ictended gasanalysis '
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) Ih/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.0075 ;`. AP-42Tab(o1.42(PM10/PM.2.5)
PM2.5 0.0075 __. AP-42Table 1.4-2(PM10/PM.2.5)
500 0.0006 - ' AP-4ZTahle1.4-2(50x)
NOx 0.0680 AP-42 Chapter 13.5 industrial Flares{hFO*)
CO 0.3100 _5,-23 AP=4Z Chapter 73.51pdustrial Flares(C 2
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) Ih/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10 0.0075 __ AP-42TabfeL42(PM10/PM.2.5)
PM2.5 0.0075 AP-41Tahte 1,4-2(PM10/PM.2.5
SOx 0.0006 _ _AP-42Table 1.42(50x)
NOx 0.0680 _ ._. AP-42 Chanter 13.5 industrial Flares(NO
VOC 0.0054 __ =AP-442 Table 1.42(VOC) .
CO 0.3100 x`22 AP•42Chapler 13..5 industrial Flares(C0)5
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 ... . 22_
PM2.5 2 2, -.
SOx ,u _ ,.
NOx .-- ., _ .-_
VOC
CO - __. ,. .,
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 - r _ -..
Toluene _ _ 22
Ethylbenzene ..
Xylene 232
n-Hexane >.,_ - _ - .._
224 TMP _ 2
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B SOUrca reyuir 5.a pc,mit
Regulation 7,Part D,Section 11.8,F SCAtace is subject o Regulation 7,Fart D,Section g a 2.'
Regulation 7,Part D,Section II.B.2.e ':.'5a cont,al d S1 t for this separator s not subi Sulotimi' '
(See regulatory applicability worksheet for detailed analysis)
4 of 6 K:\PA\2020\20WE038S.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 gy 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? sZgtrft
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?
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 88L 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? 54 x
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
'You have indicated aUu-e that tee re tertiu ad pi v.as oars:earn, aao:ic pi.g ,...s.:.0
a✓//i;":5'/Za'Tl'MO/5'fii's'finiii2 V 'i/ / X64 fci r',Pr . ,
019#4400t3w0alic4,104fASELiftVARAMEEMnaniiiaiii:iiil:POWV,41144.1".90137)
%aG
144017.7441,1041,0,4:101,0"A„, "1,0?Vert4/64,0114WW*VSFPOOVAtte,:644#51;i4
av r,?",;,'J r i�,:/`-i 'a?l a'./,ad,r. '.014 . -1'- 'lr` a`i:t,.. 14%1'4'D/ 3s, f o, g'4
Section 08-Technical Analysis Notes
1.Per operator correspondence received 10/19/2020 and 11/11/2020,the six HLP separators addressed by this AIRS point 025 include two HLP separators to which gas from multiple wells is sent,while the other four HLP separators are
dedicated to one well each).The HLP separators that process multiple wells are known at the facility as"bulk heater treaters",however,their operation is identical to the HLP separators processing one well each.The two bulk heater
treaters have a high and low pressure side,analogous to the four single well HLP separators permitted under this point.As with the HLP separators,high pressure gas from the bulk heater treaters are routed to the sales line via VRU.Low
pressure gas is also routed to a VRU,and,if this VRU is down,the the enclosed combustor(s)for destruction.Note that the facility shuts in should the sales line shut down and it was confirmed in the operator correspondence that there is
not a scenario where the high pressure side of the HLP separators and bulk heater treaters would be routed to the combustor.
2.The buffer house is a small liquids knockout vessel upstream of the VRU/combustors,through which gas from the low pressure side of the HLP separators is sentto remove entrained liquids prior to compression,or if the VRU is
experiencing downtime,combustion.Gas from all separators is comingled into a common header prior to being routed to the buffer house.
3.The gas sample used for emissions calculation purposes was obtained from the Sprague 9H facility at the outlet of the buffer house on 4/9/2018.This sample was obtained more than a year prior to the permit application submittal,
however,no well producing into these separators has been restimulated after the sample date.Initial sampling was therefore not required for this point. - -
4.In operator correspondence received 10/15/2020,it was stated that the flowmeter,which is currently installed and operational,is located downstream of the valve that routes the separator gas exiting the buffer house to the enclosed
combustor(s)during VRU downtime.As such,this flowmeter directly measures only the amount of separator gas that is actually sentto the combustor(s).R is therefore not necessary to monitor VRU downtime to determine the amount of
gas actually routed to the combustor(s),because this gas in directly measured.
5.NOx and CO emissions from this source are below APEN reporting thresholds.As a result,limits and emission factors are not included in the permit for NOx or CO.
6.Benzene,toluene and n-Hexane are the only reportable HAPs.As a result,they are the only HAPs for which emission factors are included in the permit.
7.Initial and periodic visible emissions checks for the control device are addressed by the O&M plan.As a result,the permit does not contain initial or periodic opacity:testing.
8.Pilot light emissions for the bank of combustors controlling this source are addressed at the condensate storage tanks(AIRS 123-9E32-001;20WE0387). .,
9.The wells at this production facility were constructed after 8/1/2014.As such,this facility is subject to the control requirements for separators set forth in Colorado Regulation No.7,Part 0,Section II.F. •
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
AIRS Point II Process N SCC Code Pollutant Uncontrolled Emissions Factor Control% Units
025 01 3-'9,331833 elegant PM10 18.2 0 le,,28211SCF
PM2.5 12.2 le/MMSCF
SOx 1.4 0 ib/M M/CF
NOx 166.4 1 ib/MM115CF
VOC 89001.1 95. )h/MrMSC9
CO 759.€ 0 lb/ttMt1F
Benzene 163.6 95 IbiMM5cr
Toluene 0.9.1 93 lb/,812,15C9
Ethylbenzene 4.0 95 lb/M'$bCF
Xylene 28.3 95 ib/MtvISSC8
n-Hexane 1219.1 95 'h,1„"SCF
224TMP 3 3 99 )L/'MSCF
S oft K:\PA\2020\2oWE0388:CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B,Section II.D.3)?
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3,Part A,Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3,Part B,Section II.D.2)?
Colorado Regulation 7,Part D,Section II
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014?
Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F-Control of emissions from well production facilities
Alternative Emissions Control(Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed?
Section 11.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control
Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts
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 el
conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations
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 APC
interpretations and recommendations. Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Condensate Storage Tank(s) APEN
C41.:1 Form APCD-205
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source(e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all
available APEN forms and associated addendum forms can be found on the 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: 21,DIVE03 F7 AIRS ID Number: 123 / 9E32/001
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Sprague 9H-N267 Battery
Site Location
Site Location:
SESW Section 9, T2N, R67W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 10188 East 1-25 Frontage Road
Firestone, CO 80504 Contact Person: Sabrina Pryor
Phone Number: (303) 774-3923
E-Mail Address2: sabrina.pryor@crestonepr.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
428333
COLORADO
der
Form APCD-2O5 Condensate Storage T ankiCi APEN kF yi°;c s 112,20191 I OW tri0,
Page 5 of 72
Permit Number: AIRS ID Number: 123 /9E32/001
Section 2 - Requested Action
® NEW permit OR newly-reported emission source
• Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP01 ❑ 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 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
El APEN submittal for permit exempt/grandfathered source
O Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes: Requesting source be converted from a GP01 to an
individual construction permit.
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate storage tanks
Company equipment Identification No. (optional): TANKS
For existing sources, operation began on: 7/24/2015
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s)located at: 0 Exploration Et Production(E&P)site O Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? 0 Yes O No
Is the actual annual average hydrocarbon liquid throughput≥500 bbl/day? O Yes 0 No
If"yes", identify the stock tank gas-to-oil ratio: m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑✓ Yes ❑ No
805 series rules?If so, submit Form APCD-105.
Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual ❑ Yes ✓❑ No
emissions≥6 ton/yr(per storage tank)?
�/1►rz COLORADO
For„ AP D-205 Condensate Storage Tank(s) APEN Revision 12 2 19 2 I ` '°
Page 6 of 72
Permit Number: AIRS ID Number: 123 /9E32/001
Section 4- Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbUyear) (bbUyear)
Condensate Throughput: 61,760 74,825
From what year is the actual annual amount? 2019
Average API gravity of sales oil: 52.6 degrees RVP of sales oil: 11.5
Tank design: El Fixed roof ❑ Internal floating roof 0 External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
TANKS 16 8,000 7/2015 7/2015
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 - 23977 Sprague 13-9 0
05 - 123 - 24905 Sprague 14-9 0
05 - 123 - 27346 Sprague 24-9 0
05 - 123 - 24118 Sprague 2-4-9 0
05 - 123 - 31705 Sprague 2-8-9 0
s Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 The EEtP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.148409/-104.899036
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec)
Indicate the direction of the stack outlet: (check one)
❑Upward ❑Downward 0 Upward with obstructing raincap
❑Horizontal 0 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):
Ase COLORADO
Form Condensate SCurage Tanks(s) APEN - l�estsi r_ 12/2019 3 I °.p,.,...�waa
Page 7 of 72
Permit Number: AIRS ID Number: 123 /9E32/001
1 k ,J 10anslt L7 .<poor"a a]11 toga'J
Section 6 -Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
❑ Recovery
Unit(VRU): Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented):
Pollutants Controlled: VOCs, HAPs
Rating: NA MMBtu/hr
Type: Enclosed Combustor Make/Model: NA
Combustion Controlcenc
❑ Device: Requested Efficiency: 95 EJC per
Manufacturer Guaranteed Control Efficiency: 98 % 2 589 email redid
Minimum Temperature: NA Waste Gas Heat Content: 2,596 Btu/scf 11/16/2020
Constant Pilot Light: ❑f Yes ❑ No Pilot Burner Rating: 0.025 MMBtu/hr
Description of the closed loop system:
o Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 45 psig
Describe the separation process between the well and the storage tanks: Wellhead production to
high-low pressure three-phase separators, high-pressure gas to sales, low-pressure gas tojsaies via VRU, and
if VRU is down to enclosed combustor. Condensate and produced water to storage tank battery. EJC per
email recd
11/16/2020
jee COLORADO
Form ttP',.P-20 Condensate Stn.age Tani=-:(S) A?C.N Re—/61w) 12._2)1 4 `,
Page 8 of 72
Permit Number: AIRS ID Number: 123 /9E32/001
,"N H. a'' ,k .-i , , ,n I it[.''t I ... S In
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑r Yes ❑No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured '
by control equipment) emissions)
VOC Enclosed Combustor(ECD) 100% 95%
NOx
CO
HAPs Enclosed Combustor(ECD) 100% 95%
Other:
From what year is the following reported actual annual emissions data? 201 9
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 Emissions Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
VOC 1096 110.42 j lb/bbl Site Specific 38.84 1.94 41004 389.9 20-50 19.5
NOx 0.068 Ib/MMBtu AP-42 -- 0.05 - 961 0.7
CO. 0.31 Ib/MMBtu AP-42 -- 0.24 - 276 3.4
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider EJC per
future process growth. Requested values are required on all APENs,including APEN updates. ,
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site email reed
specific emissions factors according to the guidance in PS Memo 14-03. 11/16/2020
e Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria 0 Yes O No
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, .Emissions Emissionse
Number Mfg.,etc.) (Ibs/year) Ohs/year)
Benzene 71432 266E-02 2.59E-02 lb/bbl Site Specific 229 11 P*
Toluene 108883 2,56E-022.49E-02 Ibmbl Site Specific 371 19 EJC per
Ethylbenzene 100414 1-41E-0as 1.37E-03 Ib/bbt Site Specific 426 21 ,
Xylene 1330207 9-42€-03.9.20E-03 'Mb' Site Specific 235 12 email reed
n-Hexane 110543 2A6E-412.06E-01 lb/bbl Site Specific 2,989 149 11/16/2020
2,2,4-Trimethylpentane 540841 609E-04 5.85E-04 tb/bbl Site Specific 148 7
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
COLORADO
Form A-CD-205 Condensate d lnsate Storage I ankrs) Ai'EN - Revision 12/2019 506. > rN .
Page 9 of 72
Permit Number: AIRS ID Number: 123 /9E32/001
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
3/31/2020
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:
El 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
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
iietkoOk COLORADO
Ferri AP OD 205 Condensate state Storage i ankis APEN Re‘risier, 12 2019 6 I IMP ita04v ac weu
xe.mscnmanemm
Page 10 of 72
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: Crestone Peak Resources Operating,LLC
Source Name: Sprague 9H-N267(TANKS)
Emissions Source AIRS ID2: 123/9E32/001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05- 123-39267 Sprague 3A-9H-N267 ❑
05-123-40292 Sprague 3Aa-9H=N267 ❑
05-123-39272 Sprague 3B-911-N267 ❑
05- 123-39266 Sprague 3C-9H-N267 ❑
05-123-39271 Sprague 3D-911-N267 ❑
05- 123-39268 Sprague 3E-911-N267 ❑
05- 123-39274 Sprague 3F-9H-N267 ❑
05- 123-39270 Sprague 3G-9H-N267 ❑
05-123-39273 Sprague 311-9H-N267 ❑
05-123-39269 Sprague 31-911-N267 ❑
05-123-39275 Sprague 3J-911-N267 ❑
05- 123-31686 Sprague 4-6-9 ❑
05- 123-30824 Sprague 4-8-9 ❑
- - ❑
- - ❑
- - ❑
- - ❑
Footnotes:
Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD. enter
N/A
Form APCD-212 B2-APEN FORM 212-TANKS-Wellsite Addendum
Page 11 of 72
11/16/2020 State.co.us Executive Branch Mail-Crestone Sprague Draft Permits for Review-20WE0387,20WE0388
STATE OF Chavez-CDPHE, Elie<elie.chavez@state.co.us>
COLORADO
Crestone Sprague Draft Permits for Review - 20WE0387, 20WE0388
Sabrina Pryor<Sabrina.Pryor@crestonepr.com> Mon, Nov 16, 2020 at 10:38 AM
To: "Chavez-CDPHE, Elie" <elie.chavez@state.co.us>
Elie,
• Both redline APENS are acceptable.
• Attached is an Excel version of the Form-102
• I am looking into the well documentation to support when it was last restimulated.
I'll get back to you.
[Quoted text hidden]
Sprague9H-Form102_2020.11.xlsx
116K
https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-f%3A1683539774943736889&simpl=msg-f%3A16835397749... 1/1
L7!'
04,
Gas Venting APEN - Form APCD-211
C iiiwww- Air Pollutant Emission Notice (APEN) and
CDPHE 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: ZIT iklEb3SE. AIRS ID Number: 1 23 /9E32 / CZ-5
I_t,..•Eh-_,...ap..L.i Sr i ' c _ i s'�p . ..,_ FiF.)i
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Sprague 9H-N267 Battery
Site Location: SESW Section 9, T2N, R67W Site Location 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@crestonepr.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 wilt require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
428334
COLORADO
tit
drwk
Form APCD-211 Gas Vo;ili„g APErd -Revision 722U f 1 I ...
Page 12 of 72
Permit Number: AIRS ID Number: 123 /9E32/
„PCD tia5 ?"r er issi,inec a permit P And
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 O Change company name3 O Add point to existing permit
❑ Change permit limit O Transfer of ownership4 ❑ Other(describe below)
-OR
• APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info 8 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: 4/1/2020
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 O No
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of(HAP) Emissions? ID Yes No
Is this equipment subject to Colorado Regulation No. 7, Yes ❑ No
Section XVII.G?
COLORADO
Form r PCD-311 Gas Venting'WEN Revision 12.'20 9 2 Inwoon
Page 13 of 72
Permit Number: AIRS ID Number: 1 23 I 9E32
l a,r . ,, APCD rcai a;:a-rpa, :Ir.0 AIRS irri
Section 4 - Process Equipment Information
El Gas/Liquid Separator
❑ Well Head Casing
O 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? 0 Yes O No
Vent Gas 2,447 BTU/SCF
Gas Venting Heating Value:
Process Parameters5: Requested: 1.56 4.6 ( MMSCF/year Actual: __ MMSCF/year
EJC per email
OR- recd 11/16/2020
Liquid Throughput
Process Parameters5 Requested: bbl/year Actual: bbl/year
Molecular Weight:
VOC (Weight%)
Benzene(Weight%)
Vented Gas Toluene(Weight%)
Properties: Ethylbenzene(Weight%)
Xylene(Weight%)
n-Hexane(Weight%)
2,2,4-Trimethylpentane(Weight%)
Additional Required Documentation:
❑ Attach a representative gas analysis(including BTEX£t n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX£t 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
Fora AP D 2 i": Gas Venting APEN Revision 12:20(9 3 12 N "
Page 14 of 72
Permit Number: AIRS ID Number: 123 /9E32/
Sive:=Idy assIgned_rcf, 1,=(i AIR',Ems,
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.148409/-104.899036
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Discharge Height
Operator Temp. Flow Rate Velocity
Above Ground Level
Stack ID No. CF) (ACFM) (ft/sec)
(Feet)
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward O Upward with obstructing raincap
O Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter (inches):
O Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑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.
Pollutants Controlled:
Size: Make/Model:
O 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: 2,447 Btu/scf
Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating: 0.025 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
COLOR ?
FOrtll A ) 11 G35 Venting APEN Revisli;'r 12:'201Cf 4 °'mAD
Page 15 of 72
Permit Number: AIRS ID Number: 123 I 9E32/
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? ❑Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant Control Equipment Descri Lion Collection Efficiency Control Efficiency
p (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
SOx
NOx
CO
VOC Enclosed Combustor 100% 95%
HAPs Enclosed Combustor 100% 95%
Other:
From what year is the following reported actual annual emissions data? --
Use the following table to report the criteria pollutant emissions from source:
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)s
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled (AP-42,
Basis Units ( Emissions Emissions6 Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tans/year) (tons/year)
PM
SOx
NOx 0.068 Ib/MMBtu AP-42 -- -- -- 639 0.4
-
CO 0.31 Ib/MMBtu AP-42 -- -- .- 1-76 f 1.7
VOC 89,091 Ib/MMscf Site specific -- _ 202:62 204.9 10:15.110.2
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider EJC per
future process growth. Requested values are required on all APENs,including APEN updates. email reed
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide 11/16/2020
projected emissions.
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑No
pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions6
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 151 Ib/MMscf Site specific 686 693 1 34-2a 135
Toluene 108883 110 Ib/MMsd Site specific 500 505 I 25
Ethylbenzene 100414 4.85 Ib/MMscf Site specific
Xylene 1330207 28.29 lb/MMscf Site specific
n-Hexane 110543 1,219 Ib/MMsd Site specific 5;554[5,608 [ 277,681280 1
2,2,4-Trimethylpentane 540841 0.45 ib/MMsd Site specific
Other: EJC per
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide email reed
projected emissions. 11/16/2020
'.COLORADO
Form APB 17-2 PI Gas Venting APEN - Revision 12'2019 5 j soy moir,
Page 16 of 72
Permit Number: AIRS ID Number: 123 /9E32/
leave latank -s) pe.i70, atm AiRSIDI
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
{ i
4 t 3/31/2020
r
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
D 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-B1 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
se COLORADO
Form APCD-211 Gas Venting APEN - Revistnn 12 2C+v 6
Page 17 of 72
11/16/2020 State.co.us Executive Branch Mail-Crestone Sprague Draft Permits for Review-20WE0387,20WE0388
"v4 \: STATE OF
Vr COLORADO Chavez-CDPHE, Elie<elie.chavez@state.co.us>
Crestone Sprague Draft Permits for Review - 20WE0387, 20WE0388
Sabrina Pryor<Sabrina.Pryor@crestonepr.com> Mon, Nov 16, 2020 at 10:38 AM
To: "Chavez-CDPHE, Elie"<elie.chavez@state.co.us>
Elie,
• Both redline APENS are acceptable.
• Attached is an Excel version of the Form-102
• I am looking into the well documentation to support when it was last restimulated.
I'll get back to you.
[Quoted text hidden]
abi Sprague9H-Form102_2020.11.xlsx
116K
https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-f%3A1683539774943736889&simpl=msg-f%3A16835397749... 1/1
Hello