HomeMy WebLinkAbout20202941.tiff A0;111 COLORADO
Department of Public y
Public
Health b Environment RECEIVED
SEP 2 4 2020
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
September 21, 2020
Dear Sir or Madam:
On September 22, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
HighPoint Operating Corporation - Fox Creek 28 SWSE Production Facility. A copy of this public notice
and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below. .
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
w
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe TC`,
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director ',t. ,,.
Publ G Rev ;ec",► CC:PLerP)HL(cts)Pw(34/ER/CH/CIO, 2020-2941
09/30/20 O6(5M)
oqiasrza
4...Tx- Air Pollution Control Division
440. A
Notice of a Proposed Project or Activity Warranting Public
CDPHE
CM
Comment
Website Title: HighPoint Operating Corporation - Fox Creek 28 SWSE Production Facility - Weld County
Notice Period Begins: September 22, 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: Fox Creek 28 SWSE Production Facility
Well Production Facility
SWSE SEC 28 T12N R63W
Weld County
The proposed project or activity is as follows: HighPoint Operating Corporation is changing coverage of five
(5) 840 barrel crude oil tanks from GP09 to a traditional permit.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0586 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/pacificicdphe/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.Rov/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:
Diego Chimendes
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
1 ' AllW -°" Health&Environment
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0586 Issuance: 1
Date issued: XX/XX/XXXX
Issued to: HighPoint Operating Corporation
Facility Name: Fox Creek 28 SWSE Production Facility
Plant AIRS ID: 123/A095
Physical Location: SWSE SEC 28 T12N R63W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
Crude Tanks 005 Five (5) 840 bbl liquid manifold fixed roof Enclosed Flare
storage tanks used to store crude oil.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS)form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and
can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 9
r, COLORADO
411 444ANtatil Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
4. The operator must 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:
Tons per Year
Facility AIRS Emission
Equipment ID Point PM2.5 NO,t VOC CO Type
Crude Tanks 005 --- --- 9.7 2.0 Point
Note: See"Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria pollutants, must be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
based on the previous twelve months' data. The permit holder must calculate actual emissions
each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Page 2 of 9
r. COLORADO
> Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Crude Tanks 005 Enclosed Combustion Devices VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility Equipment ID AIRS Point Process Parameter Annual Limit
Crude Tanks 005 Crude oil throughput 825,840 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
Page 3 of 9
COLORADO
Air Pollution Control Division
CDPNE
Department of Pubttc Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING £t MAINTENANCE REQUIREMENTS
16. Upon startup of these points,the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit.;Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Permit Existing Emission Point New Emission Point
Number
GP09 123/A095/003 123/A095/005
20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a'change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
Page 4 of 9
r,.•:: COLORADO
6311 Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For 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 control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
21. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
Page 5 of 9
COLORADO
�� Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Diego Chimendes
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to HighPoint Operating Corporation.
Page 6 of 9
COLORADO
co ....60. Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: 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 650.8 32.5
Toluene 108883 454.2 22.7
Ethylbenzene 100414 61.6 3.1
005 Xylenes 1330207 126.4 6.3
n-Hexane 110543 5958.8 297.9
2,2,4-
540841 3.5 0.2
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per
year(lb/yr)are reportable and may result in annual emission fees based on the most recent'Air Pollution Emission
Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Process 01: Crude oil throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 3.5x10-3 3.5x10-3 AP-42
V0C 4.7x10-1 2.3x10-2 Site Specific E.F.
Page 7 of 9
C r 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
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
71432 Benzene 7.9x10-4 3.9x10-5 Site Specific E.F.
108883 Toluene 5.5x10-4 2.8x10-5 Site Specific E.F.
110543 n-Hexane 7.2x10-3 3.6x10"4 Site Specific E.F.
Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Site-specific emission
factors were developed using flash liberation analysis. Operator submitted flashed gas lab analysis to calculate
flash emissions and submitted a Tanks 4.0 simulation to calculate working and breathing losses. The site
specific sample was obtained on 04/24/2020 and analyzed on 04/29/2020. The sample pressure and
temperature are 12.9 psig and 74°F respectively. Operator used NOx and CO emission factors from AP-42 -
13.5 Industrial Flares. The NOx and CO AP-42 emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu
respectively) were converted to units of lb/bbl using a heat content of 2357.6 Btu/scf, molecular weight of
45.6 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole, and a VOC weight% of 80.43%. Actual
emissions are calculated by multiplying the emission factors in the table above by the total condensate
throughput routed directly from the VRT.
Process 02: Combustion of pilot light
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMSCF lb/MMSCF
CO 453.5 453.5 AP-42 Chapter
13.5
VOC 7.9 7.9 AP-42 Chapter
1.4 Table 1.4-2
Note: The CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 (0.31
lb/MMBtu) by a heat value of 1,463 Btu/scf. The VOC emission factor in the table above was obtained by
multiplying the AP-42 Chapter 1.4 emission factor (0.0054 lb/MMBtu) by 1,463 Btu/scf. Actual emissions are
calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas.
Pilot light gas fuel flow is based on a constant rate of 50 scf/hr. There are a total of five combustors used to
control emissions from the condensate storage vessels. As a result, the total pilot light gas fuel flow is 250
scf/hr. Monthly pilot gas throughput shall be determined by multiplying this hourly pilot gas throughput by
the enclosed combustor monthly hours of operation.
Total actual emissions are obtained from the sum of emissions resulting from the storage vessels
and combustion of waste gas from the storage vessels (process 01)and the combustion of pilot light
gas (process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN must be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Page 8 of 9
C , .+.. COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable Status
Requirement
Operating Permit True Minor Source of: HAPs. Synthetic Minor Source of: NOx, CO,
a VOC.
PSD True Minor Source of: CO. Synthetic Minor Source of: NOx Et
VOC.
NANSR Source Requirements: Not Applicable.
MACT HH Area/Major Source Requirements: Not Applicable.
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A -Appendix
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA- Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
,i
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: .Diego Chimendes
Package#: 432351
Received Date: 6/12/2020
Review Start Date: 8/18/2020
Section 01-Facility Information
Company Name: HighPoint Operating Corporation Quadrant Section Township Range
County AIRS ID: 123 SWSE 25 126 63 _
Plant AIRS ID: A095
Facility Name: Fox Creak 20.SWSE Production Facility
Physical
Address/Location:
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? No
If yes,for what pollutant?
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
005 Storage Tank Not provided Vex 201/V505-S5 1 Yes Issuance
Section 03-Description of Project
HighPoint Operating Corporation(l-IighPoint)submitted on 06/12/2019 two(2)APENs to change coverage of the crude oil tanks battery from GP09 to a traditional
permit,and to change the coverage of the produced water:tanks from GP09 to GP08.This preliminary analysis document will cover emission calculations and
regulatory applicability to the crude oil tank battery only.
Point source is APEN-required because uncontrolled criteria pollutants emissions are greater than 2 tpy and uncontrolled emissions of at least one non-criteria
pollutant is greater than 250 tpy(Regulation 3 Part A Section II.B.3.)Point source is permit-requiredbecause uncontrolled facility-a=ide VOC emissions are greater
than 5 tpy,and NOx and CO uncontrolled facili€ty-wide emissions are greater than 10 tpy.(Regulation 3 Part B Section lt.D.3.).
This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of the source in order
to avoid other requirements.(Regulation 3 Part B Sections III C.1.d.).Point source is subject to ambient air impact analysis,(Regulation,3 Part D Section II.A.44).
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting5ynthetic Valor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No -
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) q q Eli q q q
Colorado Air Permitting Project
Title V Operating Permits(OP) J .2/—
Non-Attainment New Source Review(NANSR) �.
Is this stationary source a major source? 1~ 1•;
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(P5O) _
Title V Operating Permits(OP) _ ❑
Non-Attainment New Source Review(NANSR)
Crude Oil Storage Tank(s) APEN
.Form APCD-210
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the
General APEN(Form APCD-2OO) is available if the specialty APEN options will not satisfy your reporting needs. A
list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division
(APCD)website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: (tie 955"g..(, AIRS ID Number: 123 /A095 / G ll
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Fox Creek 28 SWSE Production Facility
Site Location
Site Location:
SWSE Sec. 28, T12N, R63W County: Weld County
NAICS or SIC Code: 211111
Mailing Address:
(Include Zip Code) 555 17th Street, Suite 3700
Denver, Colorado 80202 Contact Person: Betsy McLaughlin
Phone Number: (303) 312-8542
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.
432347
COLORADO
Form APCD-210 - Crude Oil Stora e Tanius) ADEN Rei sio 12/2019 1 ( ASP °w.""�:�.;"" ",
Permit Number: AIRS ID Number: 123 /A095/
Section 2 - Requested Action
El NEW permit OR newly-reported emission source
O Request coverage under traditional construction permit
O Request coverage under General Permit GP08
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
El Change in equipment O Change company name3
O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-144)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Five (5) 840 bbl crude oil storage tanks
Company equipment Identification No. (optional):
For existing sources, operation began on: 03/14/2020
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s)located at: 0 Exploration Et Production(Uri')site O Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? O Yes 0 No
Are Flash Emissions anticipated from these storage tanks? 0 Yes ❑ No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes (] No
805 series rules?If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual El Yes O No
emissions≥6 ton/yr(per storage tank)?
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Permit Number: AIRS ID Number: 123 /A095/
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Crude Oil Throughput: 688,200 825,840
From what year is the actual annual amount? 2020
Average API gravity of sales oil: 34.6 degrees RVP of sales oil: 7.8
Tank design: 0 Fixed roof ❑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(month/year) (month/year)
Crude TKs 5 4,200 9/2019 3/2020
Wells Serviced by this Storage Tank or Tank Battery°(E&P Sites Only)
API Number Name of Well Newly Reported Well
See Well List Addendum O
O
--
0
0
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APEN5,including APEN updates.
°The E&P Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.9737751-104.434063
O Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (OF) (ACFM) (ft/sec)
ECD 25 TBD TBD TBD
Indicate the direction of the stack outlet: (check one)
0 Upward El Downward O Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter(inches): 84
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
} COLORADO
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Form fxf- 210 21�:; _ r t;;s al i:�.�.� �i�-'tSi �,r�s - Revisor.
Permit Number: AIRS ID Number: 1 23 /A095/
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: VOC, HAPs
Rating: TBD MMBtu/hr
Type: ECD Make/Model: (5) Cimarron Big Hurt
0 Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A Waste Gas Heat Content: 2,358 Btu/scf
Constant Pilot Light: r❑ Yes ❑ No Pilot Burner Rating: 0.37 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 12.9 psig
Describe the separation process between the well and the storage tanks: The well fluids initially flow
through the heated 3-phase inlet separators to two (2) heated flash gas separators (oil polishers),
then to the vapor recovery tower("VRT"), and lastly to the crude oil storage tanks.
COLORADO
Fo r r�Y';.D i i?.. _ _ J' t 1 -' `.')Y(>J E..° - �. t:'= 12/2319 4
Permit Number: AIRS ID Number: 123 /A095/
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? ID Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6): -
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
VOC ECD 100% 95%
NOx
CO
HAPs ECD 100% 95%
Other:
From what year is the foltowing reported actual annual emissions data? 2020
Use the following table to report the criteria pollutant emissions from source:
• Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP 42, Emissions Emissions8 Emissions Emissions
Basis Mfg„etc.)
(tons/year) (tons/year) (tons/year) (tons/year)
VOC 0 469 lb/bbl Flash 8 Tanks409d 161.25 8.06 193.51 9.68
NO,, 0.068 Ib/MMBIu AP-42 0.38 0.43
CO 0 31 Ib/MMBtu AP-42 1.72 1.96
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
7 Attach crude oil laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria ,❑Yes ❑ No
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions8
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0.00079 Iblbbl -Flash&Tanks409d 542.32 27.12
Toluene 108883 0.00055 101561 Flash&Tanks409d 378.27 18.91
Ethylbenzene 100414 _ -
Xylene 1330207
n-Hexane 110543 0.00722 Iblbbl Flash&Tanks4090 4.965.68 248.28
2,2,4-Trimethylpentane 540841
7 Attach crude oil laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
I-no"1 AP1C.D-210 C-de 0!l 0 0ra2e I:?r1kis) APEN - Pe{1 n 12,'2019 5 I a ViliV 142==
Permit Number: AIRS ID Number: 1 23 /A095/
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP06, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP08.
9/71 42,41 ///
(42/I ei 101-1(:)
SignatuPe of Legally Authorized Person(not a vendor or consultant) Date
Betsy McLaughlin Air Quality 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
Air Pollution Control Division OR
APCD-SS-B1 (303) 692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
• (303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
COLORADO
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