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Home My WebLink About20201580.tiff M ,, COLORADO Department of Public g (OP"E Health b Environment RECEIVED Weld County - Clerk to the Board 1150 0 St 2020PO Box 758 APR Z 7 Z� Greeley, CO 80632 WELD COUNTY COMMISSIONERS April 22, 2020 Dear Sir or Madam: On April 23, 2020, the Air Pollution Control Division will begin a 30-day public notice period for HighPoint Operating Corporation - Wetco 4-63-4 SW . 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 8 Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4 .j 4300 Cherry Creek Drive S., Denver,CO 80246-153O P 303-692-2000 www.colorado.gov/cdphe I {i:Fi Jared Potis,Governor I Jill Hunsaker Ryan,MPH, Executive Director 1 µ } F'.'bI;c Re v i e J cc:PL(TP),HLO.X),Pw(sh/ER/CH/CK), 2020-1580 643 /2 O O6(VA) 5/t8'/.W CM.M.M Air Pollution Control Division CDPHE-�11 Notice of a Proposed Project or Activity Warranting Public Comment Website Title: HighPoint Operating Corporation - Wetco 4-63-4 SW - Weld County Notice Period Begins: April 23, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: HighPoint Operating Corporation Facility: Wetco 4-63-4 SW Oil and gas well production facility NWSW Sec 4, T4N, R63W Weld County The proposed project or activity is as follows: Applicant proposes to operate well production facility servicing production from seven (7) wells. Permit includes condensate storage tanks, produced water storage tanks, and condensate loadout emission points. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0942 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 1I COLORADO as Department of Public Health fi Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Timothy Sharp Package #: 419853 Received Date: 9/23/2019 Review Start Date: 11/18/2019 Section 01 - Facility Information Company Name: HighPoint Operating Corporation Quadrant Section Township Range County AIRS ID: 123 NWSW 4 4N 63 Plant AIRS ID: A08F Facility Name: Wetco 4-63-4 SW Production Facility Physical Address/Location: NWSW quadrant of Section 4, Township 4N, Range 63W 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 Condensate Tank CDTK 1-10 Yes 19WE0942 1 Yes Issuance Permit Initial 002 Produced Water Tank PWT 1-4 Yes 19WE0942 1 Yes Issuance Permit Initial 003 Liquid Loading TLO-01 Yes 19WE0942 1 Yes Issuance Section 03 - Description of Project New well production facility consisting of seven (7) wells which began producing June 2019. Applicant completed site-speific sampling and developed site-specific emission factors for storage tanks and loadout. Wellhead fluids at this facility are processed through an inlet 3 -phase separator, condensate continues to 2-phase heater treater, and continues to a vapor recovery tower (VRT) operating at approximately 6 psig prior storage in tanks. Gas f rom inlet 3-phase separators is sent to 2 compressors and transported offsite or used for gas lift. Gas from 2 -phase separators and VRTs is commingled and routed to five (5) electric driven compressors routed to pipeline or used for gas lift. Applicant is assuming no downtime of the gas collection system where gas would be ro uted to atmosphere or to combustors. 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 Requiremeni 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: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) J J ✓ Title V Operating Permits (OP) J J J J Non-Attainment New Source Review (NANSR) J J Is this stationary source a major source? No If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) _ Title V Operating Permits (OP) I F? ■ ■ Non-Attainment New Source Review (NANSR) Condensate Storage Tank(s ) Emissions Inventory Section 01 - Administrative Information Facility AIRs ID: 123 A08F 001 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit 10x400bbl Condensate Storage Tank Description: Emission Control Device ECD Description: Requested Overall VOC & HAP Control Efficiency %: 95.0 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 1,035,595.0 Barrels (bbl) per year Requested Permit Limit Throughput = 1,242,714.0 Barrels (bbl) per year Requested Monthly Throughput = 105545.6 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = 1,242,714.0 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2817.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 4.1 scf/bbl Actual heat content of waste gas routed to combustion device = 11,908.3 MMBTU per year Requested heat content of waste gas routed to combustion device = 14,290.0 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 14,290.0 MMBTU per year Control Device Pilot Fuel Use Rate: 0.0004 scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: 2817 Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Yes Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (Ib/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 9.130E-01 4.5650E-02 Site Specific E.F. (includes flash) Benzene 3.48E-03 1.7425E-04 Toluene 3.71E-03 1.8564E-04 Ethylbenzene 2.48E-04 1.2408E-05 Xylene 1.16E-03 5.8000E-05 n-Hexane 2.62E-02 1.3115E-03 224 TMP 0.00E+00 0.0000E+00 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 0.0000 PM2.5 0.0000 NOx 0.0680 7.819E-04 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 3.565E-03 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Combusted) Throughput) PM10 0.0000 ..,,' ' PM2.5 0.0000 NOx 0.0680 191.5560 AP-AZ Chapter 13.5_induYtrial F --,,-$,.-- 'NC-PA . CO 0.3100 873.2700 AP4 caper 13.5 industckil F , c;s (C(2) 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) VOC 557.3 472.7 23.6 567.3 28.36 4318.2 PM10 0.0 0.0 0.0 0.0 0.00 0.0 PM2.5 0.0 0.0 0.0 0.0 0.00 0.0 NOx 0.5 0.4 0.4 0.5 0.49 82.5 CO 2.2 1.8 1.8 2.2 2.21 376.2 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 4330.8 3609 180 4331 217 Toluene 4614.0 3845 192 4614 231 Ethylbenzene 308.4 257 13 308 15 Xylene 1441.5 1201 60 1442 72 n-Hexane 32596.8 _ 27164 1358 32597 1630 224 TMP 0.0 0 0 0 0 2 of 12 C:\Users\beades\Desktop\TJ's PERMITS\Ready for PubCom\419853\19WE0942.CP1 Condensate Storage Tank(s ) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage tank is not subject to NSPS OOOO. NSPS Subpart OOOOa Storage Tank is not subject to NSPS OOOOa Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the c. facility being permitted? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. es. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? Na If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes _ .�a�si vc= .w - i is „�' a •::st [.'i;c r�^ u :: ..r -:s)ttr;p s,, sa..- )x .yA [ ..: .. -x,� . :"Nil i`� ! � - _ : :r [ 3`•r I Y��c,� ''1 .:;£ ' r— :G:iiE;im..: i��u.'.• 8 !': 'r."`�:x;.:Jw-if'6A�. _ �w� 'i�^ ""':i ?s':.�'#rzd�- y.. .. ... . rum. 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S:i .-•...e.,:=: :tr^.. ._•„';'.:n tt"ur-.u'z ts� a%:ei truss .ca•: r-w-- • ..d, It .1, ,1s-.«.[.)'' _ ae• -. i5sr, R x„„ =- ^.,.:.-^:zs...s.. -• 7 E, •n; .' i 3 [.°zwwl-'. - . ' )•c3�_g„ 'rS..: [ Cr $ • a::=»�•�..=�. ?su•s'"t�•m II .LT: �5" � '��7' iicix't��. o; c'D'.-4�x-s '7fin�.. 5 > i iT>, ,4 •. .E6f,.. •��E�W:- �:x .rx..E Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 01 4-04-003-11 Fixed Roof Tank, Condensate, working+breathing+flashing losses PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.02 0 lb/1,000 gallons condensate throughput VOC 21.7 95 lb/1,000 gallons condensate throughput CO 0.08 0 lb/1,000 gallons condensate throughput Benzene 0.03 95 lb/1,000 gallons condensate throughput Toluene 0.09 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 Ib/1,000 gallons condensate throughput Xylene 0.03 95 lb/1,000 gallons condensate throughput n-Hexane 0.62 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 12 C:\Users\beades\Desktop\T1's PERMITS\Ready for PubCom\419853\19WE0942.CP1 Condensate 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 11.0.3)? 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)? Yes Source Requires an APEN. Go to 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)? -No Go to next question 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)? Yes. Source Requires a permit Source requires a permit Colorado Regulation 7.Section XII.C-F 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue- You have indicated th 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? Yes Continue-You have indicated th 3. Is this storage tank located upstream of a natural gas processing plant? ;its Source is subject Storage tank is subject to Regulation 7, Section XIi.C-F Section XII.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section XII.C.2— Emission Estimation Procedures Section XII.D— Emissions Control Requirements Section XII.E— Monitoring Section XII.F— Recordkeeping and Reporting Colorado Regulation 7.Section XII.G 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Continue - You have determined 2. Is this storage tank located at a natural gas processing plant? No Storage Tank is not subject to Re 3. Does this storage tank exhibit "Flash" (e.g. storing non-stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? [Yes es Source is subject Storage Tank is not subject to Regulation 7, Section XIL.G Section XII.G.2 - Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section XII.C.2— Emission Estimation Procedures • Colorado Regulation 7,Section XVII 1. Is this tank located at a transmission/storage facility? No Continue -You have indicated th 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station3or natural gas processing plant? Yes Go to the next question -You ha 3. Is this condensate storage tank a fixed roof storage tank? Yes Go to the next question 4. Are uncontrolled actual emissions`of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to parts of Reg; Storage tank Is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only"stabilized" liquids? 14o Source is subject to all provision: Storage tank is subject to Regulation 7, Section XVIi.C.2 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 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 (m3) [^'472 BBLs]? No Storage Tank is not subject NSPS 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 transfer2 as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 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)'s 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 (60.11ob(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 pressure6 less than 3.5 kPa (60.11ob(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 pressure6 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 [-950 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 M3 (-472B81] 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 than 27.6 kPa? Storage Tank Is not subject to NSPS Kb 40 CFR, Part 60,Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution 1. Is this condensate 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? Yes Continue - You have indicated th 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? No Storage Tank is not subject NSPS 3. Was this condensate storage vessel constructed, reconstructed,or modified (see definitions 40 CFR, 60.2)after September 18, 2015? Yes Go to the next question 4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not subject NSPS 5. Does this condensate 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? Storage Tank is not subject to NSPS 0000a [Note: If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a 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: Yes Continue -You have indicated th 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' (63.760(a)(3))? 2. Is the tank located at a facility that is major3 for HAPs? No Storage Tank is not subject MAC 3. Does the tank meet the definition of"storage vessel"" in 63.761? ' 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subject to MACT NH 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 regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act., its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend," "may," "should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Produced Water Storage Tank(s) Emissions Inventory Section 01 - Administrative Information Facility AIRS ID: 123 A08F 002 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit 4x400bbl PW Tank Description: Emission Control Device ECD Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 813,786 Barrels (bbl) per year Requested Permit Limit Throughput = 976,544 Barrels (bbl) per year Requested Monthly Throughput = 82939 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = 976,544 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 961.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 9.0 scf/bbl Actual heat content of waste gas routed to combustion device = 7038.4 MMBTU per year Requested heat content of waste gas routed to combustion device = 8446.1 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 8446.1 MMBTU per year 0.287168388 Control Device Pilot Fuel Use Rate: 0.0004 scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: 2817 Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Ye ''`:` Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) VOC 6.73E-02 3.365E-03 Site SpecificE.F. (includes flash) Benzene 1.43E-03 7.164E-05 Toluene 1.15E-03 5.726E-05 Ethylbenzene 6.48E-05 3.240E-06 Xylene 2.83E-04 1.413E-05 n-Hexane 7.31E-04 3.655E-05 224 TMP 0.00E+00 0.000E+00 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 0.00000 PM2.5 0.00000 NOx 0.06800 0.00059 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.31000 0.00268 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 ;:v vM'=:.Y y* Etis:, PM2.5 0.0000 NOx 0.0680 0.0000 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 0.0000 AP-42 Chapter 13.5 industrial Flares (CO) Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 32.9 27.4 1.4 32.86 1.64 279.1 PM10 0.0 0.0 0.0 0.00 0.00 0.0 PM2.5 0.0 0.0 0.0 0.00 0.00 0.0 NOx 0.3 0.2 0.2 0.29 0.29 48.8 CO 1.3 1.1 1.1 1.31 1.31 222.4 , 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 1399.2 1166.0 58.3 1399 70 Toluene 1118.4 932.0 46.6 1118 56 Ethylbenzene 63.3 52.7 2.6 63 3 Xylene 276.0 230.0 11.5 276 14 n-Hexane 713.9 594.9 29.7 714 36 224 IMP 0.0 0.0 0.0 0 0 5 of 12 C:\Users\beades\Desktop\TJ's PERMITS\Ready for PubCom\419853\19WE0942.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage Tank is not subject to NSPS 00O0a (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. • Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes « «.< «. >.<� a� :: «< «. « < • n .,. , m , „«..� « ..,n n -, .„ «.. «N, u « «.. �« ,.is -CO and NOx factors not confirmed. Resulting difference in methods are <1% of site threashold. `• s c. > rs^s i s r >Nix 2 t".. . x, 'txt_ E sty's tui�E - tp ..�: .. . ;.Ii. .. ::.z. ... ........«...........,..........._....;..... _..,.........._.,.. ..i t I >.i -SSEFs developed using flash liberation analysis of a site-specific sample. ...t .... _. : �: _•. :.x. ... : _.. __. .:::�:�:•:�M�.:.._...•�:�•......._.��..._.. .__..._.................. 2...x.�_t,....,.....c:.. as o y p s p �� -��•�� - �......._.__... { . ..` • < tt � it .. .. '.:<:: _:....- ,..:...�...: .. .. .�... -.._ . .. ',:' .... .. .. .......-. ..._.... ...........� ., ,......,......«.. ,�,:»..e.....-,w. , ..r«..,w....,. .a...a .. ,,,,,u,,,wE Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 002 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses PM10 0.0000 0.0 lb/1,000 gallons liquid throughput PM2.5 0.0000 0.0 lb/1,000 gallons liquid throughput NOx 0.0140 0.0 lb/1,000 gallons liquid throughput VOC 1.6024 95.0 lb/1,000 gallons liquid throughput CO 0.0638 0.0 lb/1,000 gallons liquid throughput Benzene 0.0341 95.0 lb/1,000 gallons liquid throughput Toluene 0.0273 95.0 lb/1,000 gallons liquid throughput Ethylbenzene 0.0015 95.0 lb/1,000 gallons liquid throughput Xylene 0.0067 95.0 lb/1,000 gallons liquid throughput n-Hexane 0.0174 95.0 lb/1,000 gallons liquid throughput 224 TMP 0.0000 95.0 lb/1,000 gallons liquid throughput 6 of 12 C:\Users\beades\Desktop\TJ's PERMITS\Ready for PubCom\419853\19WE0942.CP1 Produced Water 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 operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 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)? Yes, Source Requires an AP 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) No Go to next question 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)? Yes Source Requires a perr Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? No Continue -You have in 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor station3 or natural gas processing plant? Yes Continue - You have in 3. Is this produced water storage tank a fixed roof storage tank? Yes Go to the next questio 4. Are uncontrolled actual emissions`of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to pa Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Source is subject to all Storage tank is subject to Regulation 7, Section XVII.C.2 Section XV1I.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 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 (m3) (-472 BBLs)? No Storage Tank is not sul 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 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 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)"s 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 (60.11ob(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 pressures less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 [-472 BBLJ but less than 151 m3 [^550 BBL] and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(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 ["950 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 M3 ["'472 BBLJ 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 than 27.6 kPa? Storage Tank is not subject to NSP5 Kb 40 CFR, Part 60. Subpart OOOO/0000a. Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution 1. Is this produced water 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? Yes Continue - You have in 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? No Storage Tank is not sul 3. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? Yes Go to the next questio 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not sul 5. Does this produced water 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? Storage Tank is not subject to LAMPS 0000a [Note: If a storage vessel is previously determined to be subject to NSPS OOOO/0000a due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO/OOOOa per RACY Review RACY 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 regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend," "may," "should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Hydrocarbon Loadout Emissions Inventory Section 01 - Administrative Information 123 'IMF Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Hydrocarbon liquid loadout Description: Emission Control Device ECD Description: Is this loadout controlled? Yes Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 1,035,595 Barrels (bbl) per year Requested Permit Limit Throughput = 1,242,714 Barrels (bbl) per year Requested Monthly Throughput = 105546 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 1,242,714 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2817 Btu/scf Actual Volume of waste gas emitted per year = 1765665 scf/year Requested Volume of waste gas emitted per year = 2118798 scf/year Actual heat content of waste gas routed to combustion device = 4,974 MMBTU per year Requested heat content of waste gas routed to combustion device = 5,969 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 5,969 MMBTU per year Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: 2817 Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? No Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? ,Yes The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Loading Loss Equation L = 12.46*S*P*M/T Factor Meaning Value Units /�, Source S Saturation Factor 0.5 rerfrfy '� AP-42 Chapter 5.2 Table 5.2-1 Submerged Loading: Dedicated Normal Service (5=0.6) P True Vapor Pressure 8.52 psia M Molecular Weight of Vapors 48.07 Ib/Ib-mol T Liquid Temperature 523.67 Rankine L Loading Losses 5.846895271 lb/1000 gallons 0.245569601 lb/bbl 0.216248591 lb/bbl [C] 88.06% [C] VOC content of Vapors Component Mass Fraction Emission Factor Units Source Benzene 0.001576812 0.000387217 lb/bbl Toluene 0.001447049 0.000355351 lb/bbl Ethylbenzene 9.04406E-05 2.22095E-05 lb/bbl Xylene 0.000463999 i 0.000113944 lb/bbl n-Hexane 0.02054967 0.005046374 lb/bbl 224 TMP 0 lb/bbl Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 2.162E-01 1.081E-02 Site Specific - AP-42: Chapter 5.2, Equation 1 Benzene 3.872E-04 1.936E-05 Toluene 3.554E-04 1.777E-05 Ethylbenzene 2.221E-05 1.110E-06 Xylene 1.139E-04 5.697E-06 n-Hexane 5.046E-03 2.523E-04 224 TMP 0.000E+00 0.000E+O0 - Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 10 0.00E+00 PM2.5 0.00E+00 SOx 0.00E+00 NOx 0.0680 3.266E-04 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 1.489E-03 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) P M 10 0.0000 PM2.5 0.0000 SOx 0.0000 _ NOx 0.0680 191.5560 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 873.2700 AP-42 Chapter 13.5 Industrial Flares (CO) 8 of 12 C:\Users\beades\Desktop\TJ's PERMITS\Ready for PubCom\419853\19WE0942.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.00 0.00 0.00 0.01) 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 S0x 0.00 0.00 0.00 0.00 0.00 0 N0x 0.20 0.17 0.17 0.20 0.20 34 V0C 134.37 111.97 5.60 134.37 6.72 1141 CO 0.93 0.77 0.77 0.93 0.93 157 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 481 401 20 431 24 Toluene 442 368 18 442 22 Ethylbenzene 28 23 _ 28 1 Xylene 142 118 6 142 7 n-Hexane 6271 5226 261 6271 314 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements pv - ah°: Does the company request a control device efficiency greater than 95% for a flare or combustion device? :•k.'. ;.: :b: . r.: : oa .:`. If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors Uncontrol ed Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 003 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred S0x 0.00 0 lb/1,000 gallons transferred N0x 0.01 0 lb/1,000 gallons transferred V0C 5.1 95 lb/1,000 gallons transferred CO 0.04 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.01 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n-Hexane 0.12 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 9 of 12 C:\Users\beades\Desktop\TJ's PERMITS\Ready for PubCom\419853\19WE0942.CP1 Hydrocarbon Loadout 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 loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? • 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? 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)? Yep Go to next 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? Yes ` Go to the n 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No : Go to next • 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next • 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes The Ioadou Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.0.2.a)? Yes The loadou The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend,""may,""should,""should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name HighPoint Operating Corporation County AIRS ID 123 History File Edit Date 3/2012020_ Plant AIRS ID A08F Ozone Status Non-Attainment Facility Name Wetco 4-63-4 SW EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0942 Condensate Tanks 0.5 567.3 2.2 21.6 0.5 28.4 2.3 1 .1 Site specific EFs updated 002 19WE0942 Prod Water Tanks 0.3 32.9 1.3 1 .8 0.3 1 .7 1 .4 0.1 003 19WE0942 Loadout 0.2 134.4 0.9 3.7 0.2 6.7 0.9 0.2 004 GP02 Waukesha 1680hp 1 .1 1 .1 215.8 5.7 181 .7 1 .4 1 . 1 1 .1 11 .4 5.7 24A 1 .4 005 GP02 Waukesha 1680hp 1 .1 1 .1 215.8 5.7 181 .7 1 .4 1 .1 1.1 11 .4 5.7 24.4 1 .4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Process Heaters 0.200 0.200 3.1 0.20 2.6 0.0 0.200 0.200 3.1 0.20 2.6 0.0 Fugitives 0.6 0 0 0 6 0.0 FACILITY TOTAL 2.5 2.5 0.0 0.0 435.6 746.1 0.6 370.4 29.9 2.5 2.5 0.0 0.0 26.9 48.4 0.6 56.0 4.1 VOC: Syn Minor (PSD/NANSR and OP) NOx: Syn Minor (PSD/NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor B. T. X. HCHO & Total HH: Syn Minor + no TEG Dehy affected Area 117/: Syn Minor Permitted Facility Total 2.3 2.3 0.0 0.0 432.5 745 9 0.0 367.8 29.9 2.3 2.3 0.0 0.0 23.8 48.2 0.0 53.4 4. 1 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 2.3 2.3 0.0 0.0 23.8 48.2 0.0 53.4 PubCom is required for new syn minor limits. Modeling not required based on project increases. Total VOC Facility Emissions (point and fugitive) 49.0 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 48.2 Project emissions less than 25/50 tpy Note 1 Although facility emissions are greater than 45 tpy VOC, source still qualifies for GP02 since GP02 applications for Point 004 & 005 were received prior to January 2020 (see GP02 language) Note 2 Source is required to track insignificant activities to demonstrate that emissions remain below 50 tpy VOC. Page 11 of 12 Printed 3/20/2020 s COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID A08F Facility Name Wetco 4-63-4 SW Emissions - uncontrolled ilbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethytbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0942 Condensate Tanks 4331 4614 308 1442 32597 21 .6 002 19WE0942 Prod Water Tanks 1399 1118 276 714 1 .8 003 19WE0942 Loadout 481 442 _ 6271 3.7 004 GP02 Waukesha 1680hp 1622 324 305 355 1 .4 005 GP02 Waukesha 1680hp 1622 324 305 355 1 .4 0.0 0.0 0.0 0.0 0.0 XA Process Heaters 0.0 Fugitives 0.0 TOTAL (tpy) 1 .6 0.3 0.3 3.3 3.1 0.2 0.9 19.8 0.4 0.0 0.0 0.0 29.9 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year' POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL itpy) !Previous FACILITY TOTAL 0 0 0 4 0 0 0 0 0 4 0 0 0 0 0.0 001 19WE0942 Condensate Tanks 217 231 15 72 1630 1 .1 002 19WE0942 Prod Water Tanks 70 56 14 36 0.1 003 19WE0942 Loadout 24 22 1 314 0.2 004 GP02 Waukesha 1680hp 1622 324 305 355 1 .4 005 GP02 Waukesha 1680hp 1622 324 305 355 1 .4 0.0 0.0 0.0 0.0 0.0 XA Process Heaters 0.0 Fugitives 0.0 TOTAL (tpy) 1 .6 0.3 0.3 0.3 0.2 0.0 0.0 1.0 0.4 0.0 0.0 0.0 4.1 12 19WE0942.CP1 3/20/2020 COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0942 Issuance: 1 Date issued: Issued to: HighPoint Operating Corporation Facility Name: Wetco 4-63-4 SW Production Facility Plant AIRS ID: 123/A08F Physical Location: NWSW SEC 4 T4N R63W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Ten (10) 400 barrel fixed roof storage CDTK 1-10 001 vessels used to store condensate Enclosed Flare PWT 1-4 002 Four (4) 400 barrel fixed roof storage Enclosed Flare vessels used to store produced water TLO 01 003 Truck loadout of condensate by submerged Enclosed Flare fill This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. Page 1 of 12 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 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.) 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 Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO CDTK 1-10 001 --- --- 28.4 2.3 Point PWT 1-4 002 --- --- 1.7 --- Point TLO-01 003 --- --- 6.7 1.0 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 Page 2 of 12 gw�:�-- COLORADO t j Air Pollution Control Division �i.„ Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total emissions from the facility, including all permitted emissions and potential to emits from all insignificant activities, must be less than: • 50 tons per year of VOC 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Control.Device ID Point Controlled CDTK 1-10 001 Enclosed Flare VOC and HAP PWT 1-4 002` Enclosed Flare VOC and HAP TLO-01 003 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID CDTK 1-10 001 Condensate throughput 1,242,714 barrels Page 3 of 12 COLORADO Ihoof Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Equipment Point Process Parameter Annual Limit ID PWT 1-4 002 Produced water throughput 976,544 barrels TLO-01 003 Condensate Loaded 1,242,714 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 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 I I I.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. Point 001, 002: This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: - • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate 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, Section XII.C.) (State only enforceable) 14. Point 001,002: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.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 XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; 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 following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. Page 4 of 12 c•.M_ COLORADO Air Pollution Control Division CDPHE Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 15. Point 001,002: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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. Point 001,002: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. 17. Point 003: This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Regulation 3, Part B, III.D.2) 18. Point 003: All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 19. Point 003: The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B, III.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. C. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. Page 5 of 12 a .-- COLORADO 444k- Air Pollution Control Division CDP HE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 20. Point 003: For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. OPERATING a MAINTENANCE REQUIREMENTS 21. 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 OaM 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 22. Point 001,002: The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen-minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 23. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 24. 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 Page 6 of 12 .M!"°.M- COLORADO J Air Pollution Control Division a ® Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or 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 controlequipment 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. 25. 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). GENERAL TERMS AND CONDITIONS 26. 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. 27. 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. 28. 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 Page 7 of 12 aN 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 representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 29. 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. 30. 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 b 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. 31. 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. 32. 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation. Page 8 of 12 N.TM^- COLORADO Air Pollution Control Division CDPHE 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. A 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 4,331 217 Toluene 108883 4,614 231 001 Ethylbenzene 100414 308 15 Xylenes 1330207 1,442 72 n-Hexane 110543 32,597 1,630 Benzene 71432 1,399 70 Toluene 108883 1,118 56 002 Ethylbenzene 100414 63 3 Xylenes 1330207 276 14 n-Hexane 110543 714 36 Benzene 71432 481 24 Toluene 108883 442 22 003 Ethylbenzene 100414 28 1 Xylenes 1330207 142 7 Page9of12 •; - COLORADO - -- 441 11:---48" Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado n-Hexane 110543 6,271 314 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: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 3.565E-03 AP-42 VOC 9.130E-01 4.5650E-02 ProMax 71432 Benzene 3.490E-03 1.7450E-04 ProMax 108883 Toluene 3.710E-03 1.8550E-04 ProMax 100414 Ethylbenzene 2.490E-04 1.2450E-05 ProMax 1330207 Xylene 1.160E-03 5.8000E-05 ProMax 110543 n-Hexane 2.620E-02 1.3100E-03 ProMax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 002: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC 6.730E-02 3.365E-03 ProMax 71432 Benzene 1.430E-03 7.150E-05 ProMax 108883 Toluene 1.140E-03 5.700E-05 ProMax 100414 Ethylbenzene 6.480E-05 3.240E-06 ProMax 1330207 Xylene 2.820E-04 1410E-05 ProMax 110543 n-Hexane 7,310E-04 3.655E-05 ProMax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 003: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 1.489E-03 AP-42 VOC 2.162E-01 1.081E-02 ProMax 71432 Benzene 3.669E-04 1.834E-05 ProMax 108883 Toluene 3.364E-04 1.682E-05 ProMax 100414 Ethylbenzene 2.087E-05 1.044E-06 ProMax 1330207 Xylene 1.081E-04 5.403E-06 ProMax 110543 n-Hexane 4.781E-03 2.391E-04 ProMax The uncontrolled V0C emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T Page 10 of 12 C .Me,1,.: COLORADO �"Y Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 8.52 psia M (vapor molecular weight) = 48.07 lb/lb-mol T (temperature of liquid loaded) = 523.67 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) 1n accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC, CO, NOx NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area 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 Page 11 of 12 »:-M- COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 12 of 12 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0942 Issuance: 1 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: escriptio,n: HighPoint Operating Corporation Wetco 4-63-4 SW Production Facility 123/A08F NWSW SEC 4 T4N R63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point EquipmentDescription Emissions Control Description CDTK 1-10 001 Ten (10) 400 barrel fixed roof storage vessels used to store condensate Enclosed Flare PWT 1-4 002 Four (4) 400 barrel fixed roof storage vessels used to store produced water, Enclosed Flare TLO-01 003 Truck loadout of condensate by submerged fill Enclosed Flare 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. Page 1 of 12 is ;MM- COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 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 CDTK 1-10 001 --- --- 28.4 2.3 Point PWT 1-4 002 --- --- 1.7 --- Point TLO-01 003 --- --- 6.7 1.0 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 Page 2 of 12 NM,M. COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Control Device ID Point Controlled CDTK 1-10 001 Enclosed Flare VOC and HAP PWT 1-4 002 - Enclosed Flare VOC and HAP TLO-01 003 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID CDTK 1-10 001 Condensate throughput 1,242,714 barrels Page 3 of 12 ari,, COLORADO Air Pollution Control Division COP HE Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Equipment Point Process Parameter Annual Limit ID PWT 1-4 002 Produced water throughput 976,544 barrels TLO-01 003 Condensate Loaded 1,242,714 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 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 I I I.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. Point 001, 002: This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate 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, Section XII.C.) (State only enforceable) 14. Point 001,002: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.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 XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; 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 following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. Page 4 of 12 ha, COLORADO 4440 Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 15. Point 001,002: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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. Point 001,002: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. • 17. Point 003: This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Regulation 3, Part B, III.D.2) 18. Point 003: All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 19. Point 003: The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Regulation Number 3, Part B, III.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. C. Inspect thief hatch seals annually for integrity and replace as necessary.Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. Page 5 of 12 . - COLORADO • % Air Pollution Control Division ® Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 20. Point 003: For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. i OPERATING a MAINTENANCE REQUIREMENTS 21. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 22. Point 001,002: The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen-minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 23. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 24. 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 Page 6 of 12 a.a .Mt^4M- COLORADO . Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For volatile organic compounds (VOC) and nitrogen oxides sources (N0X) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 25. 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). GENERAL TERMS AND CONDITIONS 26. 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. 27. 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. 28. 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 Page 7 of 12 4 .CD-He PHa E ts_ COLORADO __ Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 29. 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. 30. 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. 31. 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. 32. 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation. Page 8 of 12 a „Ms COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 4,331 217 Toluene 108883` 4,614 231 001 Ethylbenzene 100414 308 15 Xylenes 1330207 1,442 72 n-Hexane 110543 32,597 1,630 Benzene 71432 1,399 70 Toluene 108883 1,118 56 002 Ethylbenzene 100414 63 3 Xylenes 1330207 276 14 n-Hexane 110543 714 36 Benzene 71432 481 24 Toluene 108883 442 22 003 Ethylbenzene 100414 28 1 Xylenes 1330207 142 7 Page 9 of 12 4., COLORADO • j Air Pollution Control Division ® Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado n-Hexane 110543 6,271 314 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: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 3.565E-03 AP-42 VOC 9.130E-01 4.5650E-02 ProMax 71432 Benzene 3.490E-03 1.7450E-04 ProMax 108883 Toluene 3.710E-03 1.8550E-04 ProMax 100414 Ethylbenzene 2.490E-04 1.2450E-05 ProMax 1330207 Xylene 1.160E-03 5.8000E-05 Prois/tax 110543 n-Hexane 2.620E-02 1.3100E-03 ProMax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 002: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl VOC = 6.730E-02 3.365E-Q3 ProMax 71432 Benzene 1.430E-03 7.150E-05 ProMax 108883 Toluene 1.140E-03 5.700E-05 ProMax 100414 Ethylbenzene 6.480E-05 3.240E-06 ProMax 1330207 Xylene 2.820E 04 1.410E-05 ProMax 110543 n-Hexane 7.310E-04 3.655E-05 ProMax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 003: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 1.489E-03 AP-42 VOC 2.162E-01 1.081E-02 ProMax 71432 Benzene 3.669E-04 1.834E-05 ProMax 108883 Toluene 3.364E-04 1.682E-05 ProMax 100414 Ethylbenzene 2.087E-05 1.044E-06 ProMax 1330207 Xylene 1.081E-04 5.403E-06 ProMax 110543 n-Hexane 4.781E-03 2.391E-04 ProMax The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T Page 10 of 12 a .Ir. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 8.52 psia M (vapor molecular weight) = 48.07 lb/lb-mol T (temperature of liquid loaded) = 523.67 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas.Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC, CO, NOx NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area 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.goy/ 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 Page 11 of 12 , COLORADO Air Pollution Control Division CDPHE • Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 12 of 12 I\ SEP 2 3 2019 Ala P H E Condensate Storage Tank(s) APEN CD Form APCD-205 CO Air Pollutant Emission Notice(APEN)and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates.Incomplete APENs wilt 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 at:www.colorado.govipacifickdohe/air-permits. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3,Part A,iI.C.for revised APEN requirements. Permit Number: fq(idEf:6qAIRS ID Number: 123 iA(p8fi a�4 [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 1 -Administrative Information Company Name': HighPoint Operating Corporation Site Name: Wetco 4-63-4 SW Production Facility Site Location Site Location: NWSW Sec 4, T4N, R63W County: Weld NAiCS or SIC Code: 1311 Mailing Address: (Include Zip Code) 555 17th Street, Suite 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number: (303)312-8524 E-Mail Address2: cdphe_corr@hpres.com 'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that wilt 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. 4196'5' AV COLORADO Form APCD-205 -Condensate Storage Tank(s)APEN Revision 3/2019 1 1 BiiV ""'"::-Z Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly-reported emission source Q Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GP0$ 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 O Change company name3 ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(NAPS)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: Condensate storage tanks at a newly permitted production facility with site specific emission factors. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-1O6)must be submitted. 'For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3-General information General description of equipment and purpose: Condensate Tank Battery Company equipment Identification No. (optional): CDTK 1-10 For existing sources,operation began on: For new or reconstructed sources,the projected start-up date is: 06/24/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: ❑ Exploration&Production(E&P)site O Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? Q Yes O No Are Flash Emissions anticipated from these storage tanks? ❑ Yes O No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? 0 Yes O No If"yes",identify the stock tank gas-to-oil ratio: 4.08 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 a 6 ton/yr(per storage tank)? COLOR:DO Form APCD-205 Condensate Storage Tank{s)APEN- Revision 3/2019 2 I -V Permit Number: AIRS iD Number: 123 / [Leave blank unless APCD has already assigned a permit * and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 1,035,595 From what year is the actual annual amount? Average API gravity of sates oil: degrees Tank design: 0 Fixed roof 0 Internal floating roof N/A 1,242,714 RVP of sates oil: 0 External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Ciioix 1-10 10 4,000 01/2019 06/2019 Wells Serviced by this Storage Tank or Tank Battery' (E&P Sites Only) API Number Name of Well Newly Reported Well See attached form APCD 212 O - - ■ - - O - • - - O 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report alt wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack information Geographical Coordinates (Latitude2ongitude or i1TM) 40.339824/-104.449947 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) EDD 1-3 30 1,831 550 66 Indicate the direction of the stack outlet: (check one) Q Upward O Downward O Horizontal O Other (describe): O Upward with obstructing raincap indicate the stack opening and size: (check one) ❑+ Circular Interior stack diameter (inches): 84 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 3/2019 3 AY COLORADO hy.,,, urrna w man Permit Number: AIRS ID Number: 123 / / [Leave blank untess APCD has already assigned a permit a and AIRS ID] Section 6-Control Device Information El Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC/HAPs Rating: 1.68 MMBtuthr -We: (3)ECo Make/Model: Cimarron/Big Hurt Q Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2,817 Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: 0.0004 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 6 psig Describe the separation process between the well and the storage tanks: Wellhead stream is directed to a high pressure 3-phase separator. Gravimetrically separated hydrocarbon liquids are first routed to a heater treater,then a Vapor Recovery Tower(VRT)and finally to atmospheric tanks for storage until removal from site. Ay COLOR*00 Farm APCD•2O5 Condensate Storage Tanks)APEN• Revision 3/2019 4 I � Permit Number: AIRS ID Number: 123 / / [Leave blank Mess APCD has already assigned a permit«and AIRS ID] Section 8-Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control NMethod(s) Efficiency (%reduction in emissions) VOC ECD 95 NOx NIA 0 CO N/A 0 HAPs ECD 95 Other: N/A o From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor7 Actual Annual EmissionsEmission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions° Emissions Emissions MJg.,etc.) (tans!year) (tons/year) (tons/year) (tons/year) VOC 9.13E-01 lb/lab! SSEF 472.5 23.6 567.1 28.4 NOx 6.80E-02 lb/MMBtu AP-42 - 0.5 - 0.5 CO 3.10E-01 lb/MMBtu AP-42 - 2.3 - 2.3 Non-Criteria Reportable Pollutant Emissions inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units e Number Basis (AP-42, Emissions Emissions Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 3.49E-03 Ib/bbl SSEF 3.609 180 Toluene 108883 3.71E-03 Ib/bbl SSEF 3,845 192 Ethylbenzene 100414 2.49E-04 lb/bbl SSEF 257 13 Xylene 1330207 1.16E-03 Ib/bbl SSEF 1,200 60 n-Hexane 110543 2.62E-02 Ibibbl SSEF 27,164 1,358 2,2,4- 540841 0.00E-00 Ib/bbl SSEF 0 0 Trimethylpentane 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. 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. a Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. ANY COLORADO Form APCD-2O5 Condensate Storage Tank(s)APEN- Revision 3/2019 5 i A� ',-,.=",=', Permit Number: AIRS ID Number: 123 / / (Leave blank unless APCD has already assigned a permit and AIRS ID) Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct.If this is a registration for coverage under General Permit 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. Signature of Legally Authorized Person not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name(print) Title Check the appropriate box to request a copy of the: QQ Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A,II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdaheiatxd COLORADO Form APCD-205 Condensate Storage Tank(s)APEN-Revision 3/2019 6 I COLORADO A»'t E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Formt Company Name: Highpoint Resources Source Name: Wetco 4-63-4 SW Production Facility Emissions Source AIRS ID=: 123/4og't-co/ Wells Services by this Storage Tank or Tank Battery(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123 48493 Wetco#4-03-05-5764DB 05-123-48494 Wetco#4-63-5-4033B 05-123-48495 Wetco#4-63-05-4033CB Egi 05-123-48496 Wetco#4-63.5-41488 ►� 05-123-48497 Wetco#4-63-5-56488 ►�� 05-123-48498 Wetco#4-63-5-57648 ►Zt 05-123-48499 Wetco#4-63-5-5649C ►1 O O O - - O O O - O O O O - O O 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 2ca APCD-212-EP-StorageTank-APEN-Addendum.docx SEp 23201. CDPHE Produced Water Storage Tank(s) A 1. ► APEN - Form APCD-207 CO -� Air Pollutant Emission Notice(APEN)and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities,including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly,is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks,condensate storage tanks, hydrocarbon liquid loading,etc.). In addition,the General APEN (Form APCD-200)is available if the specialty APEN options wilt not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at:www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements. Permit Number: j 1 UU r 9i/2— AIRS iD Number: 123 /Ac)$F'D a. [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': HighPoint Operating Corporation Site Name: Wetco 4-63-4 SW Production Facility Site Location: Site Location NWSW Sec 4, T4N, R63W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 555 17th Street, Suite 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number: (303) 312-8524 E-Mail Address2: cdphe_corr@hpres.com 'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 419851 mgy COLORADO Form APCD-207 Produced Water Storage Tank(s)APEN Revision 312019 1 I Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCO has already assigned a permit#and AIRS ID] Section 2- Requested Action 0 NEW permit OR newly-reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP05 O GP08 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- O MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR- • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: Water storage tanks at a newly constructed production facility with site specific emission factors. 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: Water Storage Tanks Company equipment Identification No. (optional): PWT 1.4 For existing sources,operation began on: For new or reconstructed sources,the projected start-up date is: 06/24/2019 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 O No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes 0 No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? O Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes 0 No 805 series rules?If so,submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual ❑ Yes ❑ No emissions a 6 ton/yr(per storage tank)? miter CO LOR 100. Form APCD-207 Produced Water Storage Tank(s)APEN -Revision 3/2019 2 I AS : Permit Number: AIRS ID Number: 123 / [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 4-Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Produced Water Throughput: 813,786 976,544 From what year is the actual annual amount? N/A Tank design: ['Fixed roof 0 Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Storage Tank Recent Storage Vessel in Production Tank ID Vessels in Storage Tank (bbl) Storage Tank(month/year) (month/year) WT 1-4 4 1,600 01/2019 06/2019 Wells Serviced by this Storage Tank or Tank Battery'(E&P Sites Only) API Number Name of Well Newly Reported Well - • See attached form APCD 212 0 0 - - ❑ 0 0 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. 'The E£eP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5-Stack Information Geographical Coordinates (Latftudeltong(tude or UTM) 40.339824/-104.449947 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) ECD 1-3 30 1,831 550 66 Indicate the direction of the stack outlet: (check one) Q Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal ❑other(describe): Indicate the stack opening and size: (check one) ['Circular interior stack diameter(inches): 84 ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ['Other(describe): CO.ORADO Form APCD-2O7- Produced Water Storage Tank(s)APEN -Revision 3/2019 3 �� "" `m` Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 6-Control Device Information Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC/HAPs Rating: 1.68 MMBtu/hr Type: (3) ECD Make/Model:Cimarron/Big Hurt a Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2,817 Btu/scf Constant Pilot Light: ❑ Yes 0 No Pilot Burner Rating: 0.0004 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -270 psig Describe the separation process between the well and the storage tanks: Wellhead stream is directed to a high pressure 3-phase separator.Gravimetrically separated produced water is directed to atmospheric storage tanks for storage until removal from site. COLORADO Form APCD-207- Produced Water Storage Tank(s)APEN -Revision 3/2019 4 I AT Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 8- Emissions inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) VOC ECO 95 NOx NSA 0 CO N/A 0 HAPs EC) 95 Other: N/A a From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions inventory RequestEmission Factor? Actual Annual Emissions Emission� i Permit ( Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Bash Units (AP-42. Emissions Emissions8 Emissions Emissions Mfg.,etc.) (tans/year) (tons/year) (tons/year) (tons/year) VOC 6.73E-02 Ib/bbl SSEF 27.4 1.37 32.9 1.64 • NOx 2.49E-04 Ib/bbl CDPHE — 0.10 - 0.12 CO 6.32E-04 Ib/bbl CDHPE — 0.26 - 0.31 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor? Actual Annual Emissions Abstract Chemical Name service(CAS) Uncontrolled Source Uncontrolled Controlled BasisUnits (AP-42, Emissions Emhstons NumberMfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 1.43E-03 lb/bbl SSEF 1,166 58 Toluene 108883 1.14E-03 lbibbl SSEF 932 47 Ethylbenzene 100414 6.48E-05 Ib/bbl SSEF 53 3 Xylene 1330207 2.82E-04 Iblbbl SSEF 230 11 n-Hexane 110543 7.31E-04 lb/bbl SSEF 595 30 2,2,4- 540841 0.00E-00 Ib/bbl SSEF 0 0.00 Trimethylpentane S Requested values will become permit limitations.Requested timit(s)should consider future growth. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating,leave blank. COLORADO Form APCD-207- Produced Water Storage Tank(s)APEN . Revision 3/2019 5 I "" °""` Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP05 or GP08,I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person( t a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3,Part A,1I.C.for revised APEN requirements. • Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-81 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.gov/cdphe/apcd coLon.ao Form APCD-207 Produced Water Storage Tanks)APEN- Revision 3/2019 6 I �1 " "�"`"` E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: Highpoint Resources Source Name: Wetco 4-63-4 SW Production Facility Emissions Source AIRS ID2: 123/Mgr/ O0 2 Wells Services by this Storage Tank or Tank Battery(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123 48493 Wetco#4-63-05-5764DB ►�� 05-123-48494 Wetco#4-63-5-4033B ►.� 05-123-48495 Wetco#4-63-05-4033CB ►� 05-123-48496 Wetco#4-63-5-4148D 121 05-123 48497 Wetco#4-63-5-5648B ►24 05-123-48498 Wetco#4-63-5-5764B (� 05-123-48499 Wetco#4-63-5-5649C O O O O _ O - - O O O _ - ❑ O - - O O 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 2da APCD-212-EP-StorageTank-APEN-Addendum.docx Sep ��P � Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice(APEN)and Application for Construction Permit AU 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 locks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g.amine sweetening unit,glycol dehydration unit, condensate storage tanks,etc.). In addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.colorado.Rov/cdphe/aped. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc:).See Regulation No. 3,Part A,II.C.for revised APEN requirements. Permit Number: j q IJE05 9f 2-- AIRS ID Number: 123 / t/063 [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 1 -Administrative Information Company Name': HighPoint Operating Corporation Site Name: Wetco 4-63-4 SW Production Facility Site Location Site Location: NWSW Sec 4, T4N, R63W County: Weld NAICS or SIC Code: 1311 Mailing Address: (include Zip Code) 555 17th Street, Suite 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number: (303) 312-8524 E-Mail Address2: cdphe_corr@hpres.com 'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on alt 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. 419852 Mr COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 3/2019 1 I """ "" Permit Number: AIRS ID Number: 123 I I )Leave blank unless AFCD has already assigned a permit a and AIRS ID) Section 2-Requested Action • • NEW permit OR newly-reported emission source 0 Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that oppties) • Change fuel or equipment O Change company name3 ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -AoomoiAs_PERNvr Acnotis- ❑ Limit Hazardous Air Pollutants(NAPS)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info rt Notes: Newly constructed production facility with condensate loadout equipped with vapor collection return. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-1O6)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: Hydrocarbon liquids are removed from the site via truck loadout.Truck loadout vapors are routed to the ECD knockout drum and directed to the ECDs for control. Company equipment Identification No. (optional): TLO-01 For existing sources,operation began on: For new or reconstructed sources, the projected start-up date is: 06/24/2019 Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes i] No emissions? Does this source load gasoline into transport vehicles? O Yes ❑ No Is this source located at an oil and gas exploration and production site? ❑Q Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual Yes O No average? Does this source splash fill less than 6750 bbl of condensate per year? O Yes No Does this source submerge fill less than 16308 bbl of condensate per year? O Yes 0 No COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN- Revision 3/201 2 1 `` ""` Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit"and AIRS ID] Section 4- Process Equipment Information Product Loaded: ❑i Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 1,242,714 bbl/year Actual Volume Loaded: 1,035,595 bbt/year This product is loaded from tanks at this facility into: Tank Trucks (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions,complete the following: Average temperature of Saturation Factor: 0.6 bulk liquid loading: 64 .F True Vapor Pressure: ' Molecular weight of 8.52 48.07 lb/lb-mol Psia @ 60F displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: tb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations.Requested limits)should consider future process growth. CO LON ADO Form APCD-208- Hydrocarbon Liquid Loading APEN Revision 3/2019 3 i A Itpdvp kf Permit Number: AIRS ID Number: 123 [Leave blank untess APCD has already assigned a permit ft and AIRS ID] Section 5- Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.339824/-104.449947 Discharge fieight Above Flow Rate Velocity operator. Ground Level �en** Stack la No. (� fAcn+) utise) ECD 1-3 30 1,831 550 66 indicate the direction of the stack outlet: (check one) 0 Upward O Downward 0 Upward with obstructing raincap 0 Horizontal O Other(describe): Indicate the stack opening and size: (check one) Q Circular interior stack diameter(inches): 84 ❑Other(describe): Section 6-Control Device Information Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: VOC/HAPs Rating: 1.68 MMBtu/hr Type: (3)ECDs Makeimodel:Cimarron/Big Hurt n Combustion Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A 'F Waste Gas Heat Content: 2,817 Btu/scf Constant Pilot Light: Q Yes 0 No Pilot Burner Rating: 0.0004 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: % COLORADO Form APCD-208- Hydrocarbon Liquid Loading APE, Revision 3/2019 4 ( ANY " ""°" Permit Number: AIRS ID Number: 123 I / (Leave blank unless APCD has already assigned a permit=and AIRS ID) Section 7- Emissions Inventory information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction In emissions) PM N/A 0 SOx N/A 0 NOx N/A 0 CO NIA 0 VOC ECD 95 HAPs ECD 95 Other: N/A 0 El Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane 0 Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0 Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions° Emissions Emissions Mfg.,etc.) (tons/yam) (tons/year) (tons/year) (tons/year) PM 40.0 ugA AP-42 N/A <0.1 N/A <0.1 SOx 2.10E-03 Ib/MMBTU AP-42 N/A <0.1 N/A <0.1 NOx 6.80E-02 Ib/MMBTU AP-42 N/A 0.2 N/A 0.2 CO 0.310 kt/MMBTU AP-42 N/A 1.0 N/A 1.0 VOC 0.216 lb/bbl AP-42 134.2 6.7 134.2 6.7 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Units (AP-42, Emissions Emissions° Number Basis Mfg.,etc.) (pounds/year) (ponds/year) Benzene 71432 3.23E-04 lb/bbl AP-42 401 20 Toluene 108883 2.96E-04 lb/bbl AP-42 368 18 Ethytbenzene 100414 1.84E-05 lb/bbl AP-42 23 1 Xylene 1330207 9.51E-05 lb/bbl AP-42 118 6 n-Hexane 110543 4.21E-03 lb/bbl AP-42 5,226 261 2,2,4- Trimethylpentane 540841 0.00E-00 lb/bbl AP-42 0.00 0.00 Other: S Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLOR DO" �" Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 3/2019 5 1 AV t . °" Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 8-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. if this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Signature of Legally Authorized Pers (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name(print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.). See Regulation No. 3,Part A,II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aocd COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 6 1 � SEP232019 D P H Condensate Storage Tank(s) APEN Form APCD 205 CO � Air Pollutant Emission Notice(APEN)and Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal.Your APEN will be rejected if it is filled out incorrectly,is missing information,or lacks payment for the filing fee. The re-submittal will require payment 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 wilt not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at:www.cotorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A,iI.C.for revised APEN requirements. Permit Number: fE 5 AIRS ID Number: 123 '/ 8 f " col (Leave blank unless APCD has already assigned a permit:C and AIRS ID; Section 1 -Administrative Information Company Name: HighPoint Operating Corporation Site Name: Wetco 4-63-4 SW Production Facility Site Location Site Location: NWSW Sec 4, T4N, R63W County: Weld NAICS or sic Code: 1311 Mailing Address: (include Zip code) 555 17th Street, Suite 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number: (303)312-8524 E-Mail Address2: cdphe_corr@hpres.com Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on alt documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices wilt be issued by the APCD via e-mail to the address provided. 41965 ,3 COLORADO Form APCD-2O5 - Condensate Storage Tank(s)APEN Revision 3/2019 1 1 kir f. "x. Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 2-Requested Action O NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GPM 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 O Change company name3 ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: Condensate storage tanks at a newly permitted production facility with site specific emission factors. 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 Tank Battery Company equipment Identification No. (optional): CDTK 1-10 For existing sources,operation began on: For new or reconstructed sources, the projected start-up date is: 06/24/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration&Production(EFtP)site ❑ Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? ❑Q Yes O No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? 0 Yes O No If"yes",identify the stock tank gas-to-oil ratio: 4.08 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) Yes r 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 ❑,, O YesNo emissions a 6 ton/yr(per storage tank)? pew CO.ORADO Form APCD-2O5 Condensate Storage Tank(s)APEN • Revision 3/2019 2 1 `" ,r...enkF Permit Number: AIRS ID Number: 123 / [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 4-Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbilyear) I Condensate Throughput: 1,035,595 1,242,714 From what year is the actual annual amount? N/A Average API gravity of sales oil: degrees RVP of sates oil: Tank design: 0 Fixed roof Q Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(monthlyear) (month/year) CNDTK too 10 4,000 01/2019 06/2019 Wells Serviced by this Storage Tank or Tank Battery'(E&P Sites Only) API Number Name of Well Newly Reported Well See attached form APCD 212 O - O • O S Requested values will become permit limitations. Requested limit(s)should consider future growth. 6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5-Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.339824/-104.449947 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) ECD 1-3 30 1,831 550 66 Indicate the direction of the stack outlet:(check one) 0 Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size:(check one) 0 Circular Interior stack diameter(inches): 84 O Square/rectang(e Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): wqr COLOR:.,.!.!>A Form APCD-2O5 e Condensate Storage Tankis)APEN -Revision 3/2019' 3 I *AR ° Permit Number: AIRS ID Number: 123 / / [Leave blank untess APCO has already assigned a permit and AIRS ID] Section 6-Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: 0 Recovery Unit(VRU): Requested Control Efficiency: % VRU Downtime or Bypassed(emissions vented): % Pollutants Controlled: VOC/HAPs Rating: 1,68 MMBtu/hr Type: (3) ECD Make/Model: Cimarron/Big Hurt Q Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 9$ % Minimum Temperature: N/A Waste Gas Heat Content 2,817 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.0004 MMBtu/hr Description of the closed loop system: Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: % 11i 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)? 6 psig Describe the separation process between the welt and the storage tanks: Wellhead stream is directed to a high pressure 3-phase separator. Gravimetrically separated hydrocarbon liquids are first routed to a heater treater,then a Vapor Recovery Tower(VRT)and finally to atmospheric tanks for storage until removal from site. Aky COLORADO Form APCD-205 Condensate Storage Tank(s)APEt4- Revision 3/2019 4 I Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit.and AIRS ID] Section 8-Emissions inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (X reduction in emissions) VOC ECD 95 NOx WA 0 CO NIA 0 HAPs ECD 85 Other: NIA n From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)s Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP.42, Emissions Emissiaua Emissions Emissions Basis Mfg.,etc.) (tonslyear) {fors/year) (tons/year) (tons/year) VOC 9.13E-01 Ib/bbl SSEF 472.5 23.6 567.1 28.4 NOx 6.80E-02 Ib/MMBtu AP-42 — 0.5 — 0.5 CO 3.10E-01 Ib/MMBtu AP-42 — 2.3 — 2.3 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor7 Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 3.49E-03 Ib/bbl SSEF 3,609 180 Toluene 108883 3.71E-03 iblbbl SSEF 3,845 192 Ethylbenzene 100414 2.49E-04 Ibibbl SSEF 257 13 Xylene 1330207 1.16E-03 Ib/bbl SSEF 1,200 60 n-Hexane 110543 2.62E-02 lb)bbi SSEF 27,164 1,358 2,2,4- 540841 0.00E-00 Ib/bbl SSEF 0 0 Trimethylpentane 5 Requested values will become permit limitations. Requested limits)should consider future growth. 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. a Annual emissions fees will be based on actual controlled emissions reported.if source has not yet started operating,leave blank. COLORACO Form APCD-2O5 Condensate Storage Tank(s)APEN -Revision 3/2019 5 I N _, Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit x and AIRS ID] Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit 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. l2-s.�pt-1� Signature of Legally Authorized Person not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3,Part A, II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692.3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Qov/cdphe/aped ACOLORADO Form APCD-205 Condensate Storage Tank(s)APEtt-Revision 3/2019 6 I E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: Highpoint Resources Source Name: Wetco 4-63-4 SW Production Facility Emissions Source AIRS 11)2: 1231456,1-f,X�/ Wells Services by this Storage Tank or Tank Battery(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-48493 Wetco#4-63-05-5764DB ►e 05-123—48494 Wetco#4-63-5-4033B 05-123-48495 Wetco#4.63-05-4033CB 05-123—48496 Wetco#4-63-5-4148D ►� 05-123-48497 Wetco#4-63-5-5648B 05-123-48498 Wetco#4-63-5-5764B 05-123-48499 Wetco#4-63-5-5649C O O - - ❑ O O O O O O - - ❑ - - ❑ - - ❑ 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 2ca APCD-212-EP-StorageTank-APEN-Addendum.docx 2i CDPHE Produced Water Storage Tank(s) A` APEN - Form APCD-207 CO � Air Pollutant Emission Notice(APEN)and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities,including APEN updates.incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly,is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations: If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks,condensate storage tanks, hydrocarbon liquid loading,etc.). In addition,the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at:www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No.3,Part A, II.C.for revised APEN requirements. Permit Number: 15i/tic 09'/2-- AIRS iD Number: 123 1A$EF1c?2 [Leave blank unless APCD has already assigned a permit f and AIRS ID] Section 1 -Administrative Information Company Name': HighPoint Operating Corporation Site Name: Wetco 4-63-4 SW Production Facility Site Location Site Location: NWSW Sec 4, T4N, R63W County: Weld NAICS or SIC Code: 1311 Mailing Address: (include Zip code) 555 17th Street, Suite 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number: (303)312-8524 E-Mail Address2: cdphe_corr@hpres.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that wilt appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices wilt be issued by the APCD via e-mail to the address provided. 419851 COLORADO Form APCD-207 Produced Water Storage Tank(s)APEN Revision 3/2019 1 ( A ' Permit Number: AIRS ID Number: 123 / [Leave btank untess APC0 has atready assigned a permit a*and AIRS ID] Section 2- Requested Action ✓❑ NEW permit OR newly-reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 O 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 O Change company name3 ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) - -ADomoNAL PERMIT ACTIONS- ❑ APEN submittal for permit exerrpt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PIE) Additional Info Et Notes: Water storage tanks at a newly constructed production facility with site specific emission factors. 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: Water Storage Tanks Company equipment identification No. (optional): PWT 1-4 For existing sources,operation began on: For new or reconstructed sources,the projected start-up date is: 06/24/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration ft Production(E&P)site O Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? Ej Yes O No Are Flash Emissions anticipated from these storage tanks? ✓❑ Yes O No Are these storage tanks located at a commercial facility that accepts oil production O Yes ❑ No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? O Yes ❑✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes Q No 805 series rules?If so,submit Form APCD-105. Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actualLti Yes O No emissions a 6 ton/yr(per storage tank)? caLoesoo Form APCD-207 Produced Water Storage Tank(s)APEN -Revision 3/2019 2 Ay Permit Number: AIRS ID Number: 123 / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4-Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbllyear) (bbilyear) Produced Water Throughput: 813,786 976,544 From what year is the actual annual amount? N/A Tank design: Q Fixed roof 0 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) WT 1-4 4 1,600 01/2019 06/2019 { Wells Serviced by this Storage Tank or Tank Batter?(EfcP Sites Only) API Number Name of Well Newly Reported Well See attached form APCD 212 0 0 s Requested values will become permit limitations.Requested limit(s)should consider future growth. 6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5-Stack Information Geographical Coordinates (Lotitude/Longitude or UTM) 40.339824/-104.449947 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (1tlsec) ECD 1-3 30 1,831 550 66 Indicate the direction of the stack outlet: (check one) ❑1 Upward O Downward 0 Upward with obstructing raincap ❑Horizontal ❑other(describe): Indicate the stack opening and size:(check one) ®Circular Interior stack diameter(inches): 84 ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): COLORADO Form APCD-207 Produced Water Storage Tanks)APEN -Revision 3/2019 3 Permit Number: AIRS ID Number: 1 Z3 / / [Leave blank unless APCD has already assigned a permit,4'and AIRS ID] Section 6-Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOCIHAPs Rating: 1.68 MMBtu/hr Type: (3) ECD Make/Model:Cimarron/Big Hurt a Combustion Requested Control Efficiency: gg Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2817 Btu/scf Constant Pilot Light: ❑ Yes O No Pilot Burner Rating: 0.0004 MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: • Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -270 psig Describe the separation process between the welt and the storage tanks: Wellhead stream is directed to a high pressure 3-phase separator.Gravimetrically separated produced water is directed to atmospheric storage tanks for storage until removal from site. �p L R COOA Form APCD-207-Produced Water Storage Tank(s)APEN - Revision 3/2019 4 �C� �DO Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form'. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Methods) Efficiency %reduction in emissions) VOC LCD 95 NOx WA 0 CO WA o HAPs LCD 9$ Other: WA o From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory 7 Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(a)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Units (AP-42, Emissions Emisionse Emissions Emissions Basis Mfg.,etc.) (tons!year) (tons/year) (tons/year) (tons/year) VOC 6.73E-02 lb/bbl SSEF 27.4 1.37 32.9 1.64 N0x 2.49E-04 lbtbbl CDHHE — 0.10 — 0.12 CO 6.32E-04 lb/bbl CDHPE — 0.26 — 0.31 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor? Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service((A$) Uncontrolled Units (AP�2, Emissions Emisstonsa Number Basis Mfg.,etc.) (pow/!eor) (pounds/year) Benzene 71432 1.43E-03 lb/bbl SSEF 1,166 58 Toluene 108883 1.14E-03 lb/bbl SSEF 932 47 Ethylbenzene 100414 6.48E-05 lb/bbl SSEF 53 3 Xylene 1330207 2.82E-04 lb/bbl SSEF 230 11 n-Hexane 110543 7.31E-04 lb/bbl SSEF 595 30 2,2,4- 540841 0.00E-00 Ib/bbl SSEF 0 0.00 Trirnethylpentane 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site • specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. AV °47,77,7:g.,::,,..,, LORADO AV Form APCD-207--Produced Water Storage Tank(s)APEN -Revision 3/2019 5 I ` Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit g and AIRS ID] Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP05 or GPM,I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person( t a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name(print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.sov/cdphe/apcd COLORADO Form APCD-207 Produced Water Storage Tank(s)APEN- Revision 3/2019 6 IAly, t =. E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: Highpoint Resources Source Name: Wetco 4-63-4 SW Production Facility Emissions Source AIRS ID2: 123/Mgr/ v°2 Wells Services by this Storage Tank or Tank Battery(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123 48493 Wetco#4-63-05-5764DB 05-123-48494 Wetco#4-63-5-4033B ►�� 05-123-48495 Wetco#4-63-05-4033CB 05-123-48496 Wetco#4-63-5-4148D El 05-123 48497 Wetco#4.63-5-5648B 05-123-48498 Wetco#4-63-5-5764B 05-123-48499 Wetco#4-63-5-5649C ►�+ - _ ❑ O - - ❑ -- - ❑ O O O O O O - - ❑ - - ❑ 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 2da_APCD-2 12-EP-StorageTank-APEN-Addendum.docx SEP23cti/9 c D P H E Hydrocarbon Liquid Loading APEN Form APCD-208 CO ' Air Pollutant Emission Notice(APEN)and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities,including APEN updates. Incomplete APENs wilt be rejected and wilt require re-submittal. Your ADEN will be rejected if it is filled out incorrectly,is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g.amine sweetening unit,glycol dehydration unit, condensate storage tanks,etc.).In addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.cotorado.Rov/cdphe/aped. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3,Part A, II.C.for revised APEN requirements. Permit Number: q W60142— AIRS ID Number: 123 /Aftir/OO3 (Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': HighPoint Operating Corporation Site Name: Wetco 4-63-4 SW Production Facility Site Location Site Location: NWSW Sec 4, T4N, R63W County: Weld NAICS or SIC Code: 1311 Mailing Address: (include Zip Code) 555 17th Street, Suite 3700 Denver, CO 80202 Contact Person: Marsha Sonderfan Phone Number. (303)312-8524 E-Mail Address2: cdphe_corr@hpres.com 'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that wilt 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. 419852 pp CQLOPAOO Form APCD-2O8 Hydrocarbon Liquid Loading APEN - Revision 3/2019 1 ( 46, ' A Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit 4'and AIRS ID] Section 2 Requested Action ❑i NEW permit OR newly-reported emission source 0 Request coverage under construction permit O Request coverage under General Permit GP07 if General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 o Change permit limit O Transfer of ownership's O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Newly constructed production facility with condensate loadout equipped with vapor collection return. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-1O6)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-1O4)must be submitted. Section 3 -General Information General description of equipment and purpose: Hydrocarbon liquids are removed from the site via truck loadout.Truck loadout vapors are routed to the ECD knockout drum and directed to the ECDs for control. Company equipment Identification No. (optional): TLO-01 For existing sources,operation began on: For new or reconstructed sources,the projected start-up date is: 06/24/2019 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP) emissions? 0 Yes No Does this source load gasoline into transport vehicles? O Yes 0 No Is this source located at an oil and gas exploration and production site? ® Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual j Yes O No average? Does this source splash fill less than 6750 bbl of condensate per year? O Yes El No Does this source submerge fill less than 16308 bbl of condensate per year? O Yes El No COLORADO Form APCD-2O8- Hydrocarbon Liquid Loading APEN Revision 3/2019 2 AB, �`°"` Permit Number: AIRS ID Number: 123 1 1 [Leave blank unless APCD has already assigned a permit«and AIRS ID] Section 4 Process Equipment Information Product Loaded: 0 Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: x,242,714 bbl/year Actual Volume Loaded: 1,035,595 bbtlyear This product is loaded from tanks at this facility into: Tank Trucks (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions,complete the following: Average temperature of Saturation Factor: 0.6 bulk liquid Loading: 64 e F True Vapor Pressure: C2 Psia®60'`F Molecular weight of 848.07 lb/lb-mol .5displaced vapors: v If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbUyear Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload s Requested values wilt become permit limitations.Requested timit(s)should consider future process growth. p COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN- Revision 3/2019 3 Nvin BF ns^er Permit Number: AIRS ID Number: 123 I I [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5- Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.339824/-104.449947 Operator Discharge Height Above Temp. now Rate velocity Stack ID No. Level ( (All) Ut/sic) fl�l ECD 1-3 30 1,831 550 66 Indicate the direction of the stack outlet: (check one) 0✓ Upward O Downward O Upward with obstructing raincap O Horizontal O Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 84 O 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. O Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: VOC/HAPs Rating: 1.68 MMBtu/hr Type: (3)ECDs Make/Model:Cimarron/Big Hurt 0 Combustion Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A 'F Waste Gas Heat Content: 2,817 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.0004 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: % COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 4 1 AN, Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit»and AIRS ID) Section 7-Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6,the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM N/A 0 SOx NIA 0 NOx N/A 0 CO N/A o VOC ECD 95 HAPs ECD 95 Other: N/A 0 O Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limft(sjs Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions° Emissions Emissions Mfg.,etc,) (tons/year) (tau/year) (tau/year) (tans/year) PM 40.0 ugf AP-42 N/A <0.1 N/A <0.1 SOX 2.10E-03 Ib/MMBTU AP-42 N/A <0.1 N/A <0.1 NOx 6.80E-02 Ib/MMBTU AP-42 N/A 0,2 N/A 0.2 CO 0.310 b/MMBTU AP-42 N/A 1.0 N/A 1.0 VOC 0.216 lb/bbl AP-42 134.2 6.7 134.2 6:7 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical NameAbstra cAS Uncontrolled Source Uncontrolled Controlled Units (AP-42, Emissions Emissions Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 3.23E-04 ib/bbl AP-42 401 20 Toluene 108883 2.96E-04 Ib/bbl AP-42 368 18 Ethylbenzene 100414 1.84E-05 _ lb/bbl AP-42 23 1 Xylene 1330207 9.51E-05 lb/bbl AP-42 118 6 n-Hexane 110543 4.21E-03 Ib/bbl AP-42 5,226 261 2,2,4- 540841 0.00E-00 lb/bbl AP-42 0.00 0.00 Trimethylpentane ytp Other: 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. °Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 5 1 AV "rr..?,°° Permit Number: AIRS iD Number: 123 / / [Leave blank unless APCD has already assigned a permit#and AIRS ID) Section 8-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP07,I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. LAAJDVUEliti"—Sakt-kr4".,_ - Signature of Legally Authorized (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name(print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase,increase production, new equipment,change in fuel type,etc.).See Regulation No. 3,Part A,II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.govicdphe/apcd �� o Ay COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/201 Mr Hello